13. Emergency medical services records.

Emergency medical services records may be exempt as medical records.  Ohio Rev. Code § 149.43(A)(3); see §  149.43(A)(1)(a).  However, to be exempt, the record must be maintained or generated in the process of medical treatment. Therefore, a patient care report generated by an emergency medical service squad did not qualify where the squad found the victim dead when it arrived, and thus provided no medical treatment. State ex rel. Ware v. City of Cleveland, 55 Ohio App. 3d 75, 562 N.E.2d 946 (1989).