I'm looking for a sample form Motion and Order Sealing Medical Records and Affidavit from Public View. Anyone have one they'd be willing to share?

Sent you an email with sample order. Let me know if you don't get it.

I was hoping you would respond! I had seen your willingness to help on this topic on posts from years ago, but didn't know if you were still around. Thanks!

Why file the records at all? You don't have to anymore with the changes to the Rules of Evidence effective 9/1/14.

@JohnR - could you explain further? Obviously I have missed something as far as changes go...

TDCAA article

If you go to the Current Rules of evidence on the Texas Supreme Courts Web page you will find the proposal was adopted

If the new rules delegate that I must serve the business records on the defendant, but the business records that I was attempting to file were medical records, how do I get around that problem? We don't give copies of medical records to the defense, only allow them to review in our office. How are others handling this?

Where do you find "medical records" being distinct from "business records?" Outside of the exceptions under CCP 39.15, what authority do you have to only allow inspection of "documents, papers, written or recorded statements of the defendant or a witness" as opposed to copying by defense counsel?

I guess our office was under the (false) assumption that medical records of our victim's were privileged documents. The defense attorney, in this particular case, has not requested copies of anything, so I assumed that notifying him of the existence of the medical records and that they are available for inspection sufficed under 39.14, but I should probably steer clear of assumptions. Our office is still adjusting to the discovery law changes, so maybe we are antiquated as to medical records. That's the reason I asked for assistance from the knowledgeable members of TDCAA.