Allen

This petition for writ of mandate seeks to protect a defense medical expert from producing documents showing the extent of his practice for the defense and for insurance companies over the past five years. The doctor has not yet been deposed, but his records were subpoenaed for production at his deposition. We conclude that the trial court erred in requiring document production without a showing that plaintiff’s object could not be accomplished through less intrusive means.

Real party in interest Assunta Sierra has sued petitioner for injuries sustained in an automobile accident (a second plaintiff had also sued, but her action has settled and will not be mentioned hereinafter). By stipulation of the parties, at petitioner’s request, real party Sierra was examined by Dr. Robert L. Samilson. Afterwards, real party noticed the deposition of Dr. Samilson and served him with a subpoena duces tecum requiring him to bring (1) records pertaining to his examination of real party and billing for the examination; (2) records indicating the sources of his income where examinations were made at the request of insurance companies or defense lawyers over the last five years; (3)…