Medical Records Objection Guide

When drafting an objection to a discovery demand for medical records, you can use the following template:
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[Your Name]
[Your Address]
[City, State, ZIP Code]
[Date]
[Recipient's Name]
[Recipient's Address]
[City, State, ZIP Code]
Re: [Case Name/Number]
Dear [Recipient's Name],
Please take notice that I hereby object to the request for medical records on the following grounds:
*. Overly Broad and Vague: The demand lacks specificity and encompasses records not relevant to the current case.

*. Unduly Burdensome: Complying with this request would require unreasonable effort and expense, as it seeks extensive records beyond the scope of the allegations.
*. Irrelevant Information: The request includes medical records not pertinent to the injuries claimed in the present matter.
I respectfully request that this demand be withdrawn or narrowed to address only relevant and necessary information.
Sincerely,
[Your Signature]
[Your Printed Name]
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Ensure to consult with your attorney to tailor the objection specific to your case and jurisdiction.

When drafting an objection to a discovery demand, it's helpful to support your position with relevant case law. Here are some examples from New York:
- Cynthia B. v. New Rochelle Hosp. Med. Ctr., * N.Y.2d * (*): Addresses overly broad discovery demands.
- Kavanagh v. Ogden Allied Maintenance Corp., * N.Y.2d * (*): Discusses the relevance of medical records.
- Allen v. Crowell-Collier Publ. Co., * N.Y.2d * (*): Sets limits on overly burdensome requests.
Ensure you consult with an attorney to integrate these into your objection effectively.

Case Rating: *
For more recent case law in New York regarding objections to discovery demands, consider the following:
- Forman v. Henkin, * N.Y.3d * (*): Discusses the balance between discovery demands and privacy.
- Giordano v. New Rochelle Municipal Housing Authority, * A.D.3d * (*): Examines limitations on discovery demands.
Consulting an attorney for tailored advice is recommended.