Q: irrelevant, protected information, not calculated for admissible evidence; calculated to embarrass, annoy, harass.

A: You don't need a protective order. From the information in your post, all the defendant did was ask for an authorization. Just say no if the subpoena requests records unrelated to the injuries at issue.

If the defendant issues a subpoena for records unrelated to your injuries, then you can ask them to withdraw or limit the subpoena. If they refuse, then you can file a motion for protective order.

A: The California Code of Civil Procedure (CCP) Section 2031.060 governs motions for protective orders in response to requests for production of documents, including medical records. This statute allows a party to seek a protective order from the court to limit the scope of discovery or assert objections to the requested documents.

Under CCP § 2031.060(b), the court shall limit the scope of discovery if it determines that:

1. The discovery sought is unreasonably cumulative or duplicative, or can be obtained from another source that is more convenient, less burdensome, or less expensive.

2. The selected method of discovery is unduly burdensome or expensive, taking into account the needs of the case, the amount in controversy, and the importance of the issues at stake in the litigation.

3. The discovery sought is unreasonably cumulative or duplicative, or can be obtained from another source that is more convenient, less burdensome, or less expensive.

Additionally, CCP § 2017.010 states that any party may obtain discovery regarding any matter, not privileged, that is relevant to the subject matter involved in the pending action or to the determination of any motion made in that action if the matter either is itself admissible in evidence or appears reasonably calculated to lead to the discovery of admissible evidence.

While the specific language "calculated to embarrass, annoy, harass" is not explicitly used in the statute, the court has the discretion to limit discovery based on the factors mentioned above, which could include requests that are deemed irrelevant, protected by privilege, not reasonably calculated to lead to admissible evidence, or unduly burdensome.

It's important to note that the motion for a protective order should be tailored to the specific circumstances of the case and the objections to the requested documents, citing the appropriate legal authorities and factual basis for the objections.