Q: Is Plaintiff's Motion to Quash applicable as response to Defendant's request for authorization of medical information?

A: Based on California law, a Motion to Quash is typically used to challenge a subpoena, not to respond to a request for authorization of medical information. In this case, a Motion for Protective Order would be more appropriate.

Under California Code of Civil Procedure (CCP) § 2031.060, a party may move for a protective order to limit the scope of discovery or to protect confidential information. This motion can be used to prevent the disclosure of privileged or protected medical information.

When drafting the Motion for Protective Order, it is advisable to include the relevant statutes and codes that support your argument for protecting the medical information. The statutes you mentioned, such as Evidence Code §§ 990 & 1014 (which relate to the physician-patient and psychotherapist-patient privileges), California Welfare and Institutions Code §§ 5328 et seq. (concerning the confidentiality of mental health records), and the California Constitution, Article 1 § 1 (the right to privacy), are all pertinent and should be included in your motion.

The CCP sections you listed (2025.420(b)(1), (7), (9), (10), (11) and 2025.420(f)(1), (2), (3), (4)) are related to depositions and may not be directly applicable to a request for authorization of medical information. However, you can use them to draw analogies or support your arguments if they are relevant to your case.

In summary, a Motion for Protective Order, rather than a Motion to Quash, is the appropriate response to the defendant's request for authorization of medical information. Be sure to include the relevant statutes and codes that support your position in the motion.