Thank you for your follow-up.
3. that this info goes to just OC but in my x's petition it states that and custody evaluators, court appointed experts or experts retained.
Those are all authorized parties as they are all direct or indirect parties to the case, as they may have the need to evaluate the medical information.
on the sample it states
5. In the sample it states Prior to disclosing Plaintiff’s protected health information to persons involved in this litigation, counsel shall inform each such person that Plaintiff’s protected health information may not be used or disclosed for any purpose other than this litigation. Counsel shall take all other reasonable steps to ensure that persons receiving Plaintiff’s protected
health information do not use or disclose such information for any purpose other than this litigation .......but in my x's petition it states PHI shall be subject to any and all other protective orders in the above captioned litigated? mentions nothing of prior to inform anything...
You can add such language, and file an answer with such modification if you like.
6. In the sample it states 45 days after the conclusion of the litigation but my x's petition is after trial, appelate and supreme proceedings are exhausted...?
8. my X's counsel give an exception which is they want more than records but also notes, memoranda, correspondence, too
You can directly petition to claim that this is beyond the scope and while you can agree to general medical records provided, you do not agree to attorney work product or outside correspondence that is not a part of the medical file.
Good luck and kindly rate my answers to you at this time. Thank you!