Defendant's Ability to Obtain Plaintiff's Complete Medical History -


What limitations exist, if any, on a defendant’s ability to obtain a plaintiff’s complete medical history, both pre and post incident?

“[Nevada’s] discovery rules provide no basis for carte blanche invasion into a litigant’s private affairs, merely because redress is sought for personal injury. Schlatter v. Eighth Judicial Dist. Court, 93 Nev. 189, 561 P.2d 1342, 1977 Nev. LEXIS 511 (Nev. 1977). However, where a litigant’s physical condition is in issue, a court may order discovery of medical records containing information relevant to the injury complained of or any preexisting injury related thereto. Id. However, a “carte blanche discovery of all information contained” in sought-after medical records without regard to relevancy or the possible discovery of admissible evidence exceeds the jurisdiction of the trial court. Id. at 192.