Rahofy v. Steadman, 2010 UT App 350

In 2005, Rahofy was involved in a Utah automobile accident near Cedar City; she had provided initial disclosures including medical treatment information related to the injuries.
Defendants sought Rahofy's past medical and employment records outside Utah by requesting she sign authorizations for direct release of those records.
Rahofy refused to sign the broad authorizations, prompting defendants to file a motion to compel.
The district court granted the motion to compel: employment records were to be released via authorizations; medical records required a court-approved list and in-camera review to determine relevance and privacy.
Defendants had not formally served a Rule 34 document request nor established possession, custody, or control of all requested records, especially those outside Utah; the court proceeded under informal discovery.
Rahofy appealed interlocutorily to challenge whether the district court abused its discretion in granting the motion to compel.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the district court abuse its discretion in granting the motion to compel absent a proper Rule 34 request?	Rahofy argues Defendants failed to formally request under Rule 34 and thus the motion was improper.	Steadman argues the authorizations served as sufficient discovery access to records not in Rahofy's possession.	Yes, the court abused its discretion; no proper Rule 34 request was shown.
May records outside Utah be obtained withoutRule 34 through informal authorizations or other procedures?	Rahofy contends informal authorizations are insufficient to compel production.	Steadman contends access to out-of-state records should be allowed as needed.	No; proper procedures (Rule 34 and/or subpoenas) must be used.
Were subpoenas or cross-state mechanisms available to obtain out-of-state records, rather than broad authorizations?	Rahofy asserts procedures must be used and records outside Utah can only be obtained via proper process.	Steadman argues records outside Utah may require additional, time-consuming steps.	Yes; subpoenas or proper cross-state procedures are required, and district court erred by not following them.

Cannon v. Salt Lake Reg'l Med. Ctr., Inc., 121 P.3d 74 (Utah Ct. App. 2005) (discovery scope and purpose; abuse of discretion standard for discovery rulings)
Brown v. Glover, 16 P.3d 540 (Utah 2000) (interpretation of procedural rules; duty to follow discovery procedures)
Toma v. Weatherford, 846 F.2d 58 (10th Cir. 1988) (Rule 37 remedies for failure to answer interrogatories or produce documents)