Although expensive, it is often advantageous to actually obtain three copies of a chart. The first copy should be obtained by the plaintiff or plaintiff’s family without attorney intervention, while the second would be the attorney pre-suit and the third by the attorney during litigation. The inherent advantage is that the charts are obtained during periods of widely varying levels of concern from the putative defendants. Comparing each of these copies will very frequently reveal alterations to the chart itself.
You can read more practice tips in my chapter Screening the Nursing Malpractice Case, in a text edited by Patricia Iyer, RN MSN LNCC. More information about Nursing Malpractice, Third Edition, 2007 may be found at here.