Local Rule CV-34: Production of Documents and Things

LOCAL RULE CV-34 Production of Documents and Things Authorizations. At any time after the parties have conferred as required by Fed. R. Civ. P. 26(f), a party may request medical records, wage and earning records, or Social Security Administration records of another party as follows:

(a) Where a party's physical or mental condition is at issue, that party shall provide to the opposing counsel either the party's medical records or a signed authorization so that records of health care providers which are relevant to injuries and damages claimed may be obtained. If additional records are desired, the requesting party must show the need for them.

(b) Where lost earnings, lost earning capacity, or back pay is at issue, the party making such claims shall furnish signed authorizations to the opposing party's counsel so that wage and earning records of past and present employers and the Social Security Administration records may be obtained.

(c) Copies of any records obtained with authorizations provided pursuant to Sections (1) or (2) above shall be promptly furnished to that party's counsel. Records obtained shall remain confidential. The attorney obtaining such records shall limit their disclosure to the attorney's client (or, in the case of an entity, those employees or officers of the entity necessary to prepare the defense), the attorney's own staff, and consulting and testifying experts who may review the records in connection with formulating their opinions in the case.