There is a thing that attorneys have called "work product." It is communication amongst themselves that, by definition, cannot or should not be able to be subpoenaed.
I messages sometimes contain statements, words or phrases that you wouldn't want read by a parent or another doctor. This is why, given we don't do MU, we do it as above so as to avoid their getting into the transferred chart. Of course, this has a double-edged sword as there may be very good documentation which you may need.
