Section 3122. Objection to disclosure, inspection or examination; compliance

(a) Within twenty days of service of a  notice  or  subpoena
  duces tecum under rule 3120 or section 3121, the party or person to whom
  the  notice or subpoena duces tecum is directed, if that party or person
  objects to the disclosure, inspection  or  examination,  shall  serve  a
  response which shall state with reasonable particularity the reasons for
  each objection. If objection is made to part of an item or category, the
  part shall be specified. A medical provider served with a subpoena duces
  tecum  requesting the production of a patient's medical records pursuant
  to this rule need not respond or object to the subpoena if the  subpoena
  is  not  accompanied  by  a  written  authorization  by the patient. Any
  subpoena served upon a medical provider requesting the  medical  records
  of a patient shall state in conspicuous bold-faced type that the records
  shall  not  be  provided unless the subpoena is accompanied by a written
  authorization by the patient. The party seeking  disclosure  under  rule
  3120  or  section  3121 may move for an order under rule 3124 or section
  2308 with respect to any objection to, or other failure to respond to or
  permit inspection as requested by, the notice or subpoena  duces  tecum,
  respectively, or any part thereof.
    (b)  Whenever a person is required pursuant to such a notice, subpoena
  duces tecum or order to produce documents for inspection, and where such
  person withholds one or more documents that  appear  to  be  within  the
  category  of  the documents required by the notice, subpoena duces tecum
  or order to be produced, such person shall  give  notice  to  the  party
  seeking  the production and inspection of the documents that one or more
  such documents are being withheld. This notice shall indicate the  legal
  ground  for  withholding  each  such  document,  and  shall  provide the
  following information  as  to  each  such  document,  unless  the  party
  withholding  the  document  states  that  divulgence of such information
  would cause disclosure of the allegedly privileged information: (1)  the
  type  of  document;  (2) the general subject matter of the document; (3)
  the date  of  the  document;  and  (4)  such  other  information  as  is
  sufficient to identify the document for a subpoena duces tecum.
    (c)  Whenever a person is required pursuant to such notice or order to
  produce documents for inspection, that person shall produce them as they
  are kept in the regular course of business or shall organize  and  label
  them to correspond to the categories in the request.
    (d) Unless the subpoena duces tecum directs the production of original
  documents  for  inspection and copying at the place where such items are
  usually maintained, it shall be sufficient for the  custodian  or  other
  qualified person to deliver complete and accurate copies of the items to
  be  produced.  The reasonable production expenses of a non-party witness
  shall be defrayed by the party seeking discovery.