August 20, 2021

Contact: Eric W. Boyer, Esq.
Managing Partner
305.670.1101 Ext. 1023



Howard B. Hayden

NASHVILLE, Tenn. ― Howard B. Hayden, a partner in the Nashville and Memphis, Tennessee offices of Quintairos, Prieto, Wood & Boyer, P.A., was granted a protective order involving abusive Rule(30)(b)(6) regarding deposition notices served to his client, a skilled nursing facility and its management company presently defending a claim involving a resident’s fall, hip fracture and death.

Plaintiff’s counsel filed boilerplate deposition notices for the designated representatives of both defendants that included exhaustive lists of areas of inquiry that were intended to advance the plaintiff’s standard “profits over people” case theme. In response, defendants filed a motion for protective order seeking to quash both deposition notices in their entirety on the grounds the areas of inquiry were irrelevant, unduly burdensome, and solely designed to run up defense costs and harass the defendants.

The issues were fully briefed and following a hearing before the Honorable Thomas Brothers in Nashville, the court granted the defendants’ motion in its entirety and quashed both depositions ruling that the information sought either did not exist, was totally irrelevant to providing the elements of a health care liability action, or was not the subject of dispute between the parties. The court then entered defendants’ proposed order over the competing order submitted by plaintiff’s counsel. 

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Howard B. Hayden is co-managing partner of the Memphis and Nashville offices. He focuses on defending long-term care providers, assisted living facilities, healthcare providers, hospitals, nurse staffing, home health agencies and skilled nursing facilities in arbitration/mediation, trial and appeal on claims of negligence, alleged elder abuse and Board Complaints throughout Tennessee and Mississippi.  Mr. Hayden is listed by the Tennessee Supreme Court as a Rule 31 General Civil Mediator.  He has attained the highest Peer Review Rating™ of AV® Preeminent™ from Martindale-Hubbell Legal Directory. Mr. Hayden received his Juris Doctor from the University of Tennessee College of Law in 1984. He is licensed to practice law in Tennessee and Mississippi.

About QPWB

Quintairos, Prieto, Wood & Boyer, P.A. is the largest minority and women owned law firm in the nation with more than 400 lawyers serving clients from 27 offices in the United States and abroad. Our lawyers provide representation in litigation, business, real estate and governmental law.

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