Q: valid response to motion to compel execution of authorization to release of medical record- motion for protective order

A: Yes, under California law, a motion for a protective order is a valid response to a motion to compel the execution of an authorization to release medical records. This is pursuant to California Code of Civil Procedure (CCP) Section 2031.060, which states:

"(a) When an inspection, copying, testing, or sampling of documents, tangible things, places, or electronically stored information has been demanded, the party to whom the demand has been directed, and any other party or affected person, may promptly move for a protective order. This motion shall be accompanied by a meet and confer declaration under Section 2016.040.

(b) The court, for good cause shown, may make any order that justice requires to protect any party or other person from unwarranted annoyance, embarrassment, or oppression, or undue burden and expense."

In the context of medical records, a party may move for a protective order to limit the scope of the records to be released, to protect sensitive or privileged information, or to assert that the request is unduly burdensome or invasive of the party's privacy rights. The court will then consider the arguments and may grant the protective order, deny it, or modify the terms of the discovery request as it sees fit to balance the interests of the parties and ensure fairness in the discovery process.

It's important to note that the party seeking the protective order must demonstrate "good cause" for the order and must first attempt to resolve the issue with the opposing party through a meet and confer process before filing the motion with the court.