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P1497 Treating a trial court's order for injunctive relief as a protective discovery order, the Court of Appeal found defendant's persistent attempts to use the employment relationship and threat of discipline to obtain medical information outside the discovery process in plaintiff's action under the Federal Employer's Liability Act (FELA) justified issuance of the order and the imposition of discovery sanctions; in a state action under the FELA, California's Civil Discovery Act is not pre-empted by federal law.CitationPRATT v UNION PACIFIC RR (FELA Discovery) 168 CA4 165 [See: 45 USC 51 etseq, 151 etseq; CCP 2016.010 etseq; Parker v Wolters Kluwer 149 CA4 285, P/AT 5/07]
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