Q: I filed a complaint and included personal injury for health related problems, that were caused.

A: Please get a lawyer to help you even if you just pay for an office visit. This is an area that even the most seasoned lawyers struggle with. The answer to your question depends on what court you are in and what the local practice is for dealing with these types of requests. Typically you refuse the request with a written response and state why you refuse. But you have to give a legitimate legal reasons for refusing. Then you and the other lawyer try to discuss your objection and maybe resolve it. But here you are extremely vulnerable because what you say in any such discussion is going to be used as evidence, potentially, against you. Every time you talk to the opposing party they get to use what you say. If you had an Attorney speaking on your behalf the statements of your Attorney would not be admissible. Then if the matter isn't resolved it gets put in front of a judge to decide. If the Judge finds that you shouldn't have refused to give the discovery you could be hit with Attorney's Fees. Since no one on the internet knows whether you should or shouldn't refuse, we can't tell you if refusing will be a problem.

Another way to deal with this that is less risky, is you agree to give all the requested records to a Judge to do an in camera review (a private review) and let the Judge decide what they should or shouldn't get. But that is risky if you can't give the Judge the law to follow and explain why the Judge should or shouldn't restrict the records.

Get help from an Attorney.