Is a videotape of a medical examination sufficient to constitute a written report?

The majority further note that subdivision (b) of section 2032 entitles the examined party on request to "a detailed written report of the [22 Cal.3d 706] examining physician setting out his findings and conclusions . . . ." Relying on Bailey v. Superior Court (1977) 19 Cal.3d 970, 140 Cal.Rptr. 669, 568 P.2d 394, which held that the videotape of a deposition was not a writing, the majority conclude that the videotape of a medical examination cannot qualify as the written report of the examining physician under subdivision (b).