In most states in the US, a corporation must have permission from the state Health Department to close a hospital. As part of that, the custodian of all the medical records is named--in this case, who is named as custodian of those records? Also, do you expect the patients at this new facility to be the same patients who were there under the old corporation? Maybe if you call them on every patient, they will eventially get tired of looking up each record and give you copies.