(a) Exchange of Medical Records.
(1) By Plaintiff. Within 5 days after a defendant has filed an answer or a motion in response to the complaint, the plaintiff must serve on that defendant copies of all of the plaintiff’s available medical records relevant to the condition that is the subject matter of the action. The plaintiff also must provide a medical records authorization to allow the defendant to obtain copies of the plaintiff’s medical records from their original source.
(2) By Defendants. Within 10 days after the plaintiff serves medical records under Rule 26.3(a)(1), a defendant must serve on the plaintiff and all other parties copies of all of the plaintiff’s available medical records relevant to the condition that is the subject matter of the action.
(3) Records Obtained Under a Medical Records Authorization. If a defendant obtains records using a plaintiff’s medical records authorization, the party obtaining the records must furnish to all other parties–at its sole expense–complete copies of any non-duplicative records not previously produced by the plaintiff or another defendant.
(4) Limitations. The parties may agree to limit the records produced under this rule.
(b) Timing of Expert Disclosure. The parties must disclose the identities and opinions of standard of care and causation experts simultaneously, unless the parties agree or the court orders otherwise for good cause.