Q: Response to Motion to Compel execution of authorization for release of medical records.

A: Under California law, a response to a motion to compel execution of an authorization for release of medical records would typically involve the following:

1. Opposition pursuant to:

- California Code of Civil Procedure (CCP) § 2017.010 - General scope of discovery

- CCP § 2019.030 - Scope of discovery in general

- CCP § 2031.010 - Inspection, copying, testing, or sampling of documents, tangible things, land or other property

- Evidence Code § 994 - Physician-patient privilege

- Article I, Section 1 of the California Constitution - Right to privacy

2. Motion for a protective order pursuant to:

- CCP § 2017.020(a) - The court shall limit the scope of discovery if it determines that the burden, expense, or intrusiveness of that discovery clearly outweighs the likelihood that the information sought will lead to the discovery of admissible evidence.

- CCP § 2019.030(c) - The court shall restrict the frequency or extent of discovery if it determines either of the following: (1) The discovery sought is unreasonably cumulative or duplicative, or is obtainable 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.

- CCP § 2031.060 - Motion for a protective order for documents, tangible things, land or other property

These statutes provide the legal basis for opposing a motion to compel and seeking a protective order to limit the scope of discovery, particularly when the requested medical records are privileged, irrelevant, or the request is overly broad or burdensome.