This section contains the nature of the case and procedural background.

Howard (D) performed a sagittal split osteotomy on Payne (P). P alleged that it was performed in a negligent manner and without her informed consent. P took D's deposition, and D was requested to produce a number of documents related to his dental practice and private affairs. D refused on grounds of irrelevance of privilege. P then moved for a default judgment against D or in the alternative to compel him to make the requested discovery.

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