According to the medical examiner, the MANNER OF DEATH IS: "UNDERDETEMINED". The case remains "open".
Ah, yes, you're right, I remember that now. I think what he means is that the medical investigation is permanently open. It could consider any new evidence, which would include all of the missing medical documents. Possibly financial records, too.
It surprises people that M.E.s look at medical histories as well as the body of the deceased. Thogmartin did a lot of research and came up with a bunch of missing medical records -- mostly courtesy of attorney Gary Fox. (He's the snake who dreamed up the phony malpractice suit, but let's forgive him, at least for now :-) ) Other documents are known to be missing. Who knows what Michael was able to get sealed by Greer? Anything new that shows up can go into the ongoing legal investigation. (They would be legally protected.)
Safe bet there are several people who worry deeply about documents surfacing or about blackmail or about some blabbermouth in the ranks. They are right to worry.