**ADVICE ON RESPONDING TO CORRESPONDENCE & SUBPOENA NOTICE**\n\n---\n\n### **1. Analysis of the Situation**\n\nYou have received two key communications from the other side (Jodhi Coady of Infocus Legal):\n1. **A Notice of Subpoena:** They have issued, filed, and served a subpoena on Bankstown Hospital for your client's (Nada Alewe's) medical records. They state they will not inspect the documents yet, to allow you time to object on your client's behalf. They also mention the records are voluminous (7000 pages) and they may involve the ICL (Independent Children's Lawyer) for further action.\n2. **A Follow-up Demand for Medical Information:** They are reiterating a prior request for specific details about your client's medical treatment (GP/psychologist/psychiatrist details, hospital attendance dates, and medication list).\n\nThe subpoena is a formal court process. The follow-up email is an informal request for disclosure.\n\n---\n\n### **2. Immediate Priority: The Subpoena**\n\nThis is the most time-sensitive and procedurally important item.\n\n**Your Advice to Client & Action:**\n* **Explain the Subpoena to Your Client:** Inform Nada Alewe that the other side has compelled Bankstown Hospital to produce her medical records to the court. Explain that this is a common tactic in parenting cases where a party's mental or physical health is in issue.\n* **Discuss Objection Grounds:** You must advise her of her right to object to the subpoena or to access to the documents. Common grounds for objection include:\n * **Oppression:** The volume (7000 pages) is excessive and fishing.\n * **Lack of Relevance:** The records may contain wholly irrelevant private health information.\n * **Privilege:** Parts may be subject to legal professional privilege or other confidentiality protections.\n* **Client Instructions:** Seek her instructions on whether to:\n * **Consent to Access:** (Unlikely, given the allegations).\n * **Object to Access:** File a \"Notice of Objection\" with the court, outlining your grounds. The deadline to object is typically before the date for production (1 April 2026). You must serve this on the issuing party (Infocus Legal) and the subpoenaed party (Bankstown Hospital).\n * **Seek to Set Aside the Subpoena:** A more aggressive approach, arguing the subpoena itself should not have been issued. This is less common at this stage.\n* **Your Action - Respond to the Lawyer:** Send a brief, professional email acknowledging receipt of the subpoena notice and stating you are taking instructions and will advise in due course.\n\n**Draft Response (Subpoena):**\n> **Subject: Your Correspondence & Subpoena S1 - Alewe & Francis [PAC991/2026]**\n>\n> Dear Ms Coady,\n>\n> We acknowledge receipt of your email dated [Date] notifying us of the filing and service of Subpoena S1 issued to the South Western Area Health District (Bankstown Hospital).\n>\n> We are taking our client's instructions in relation to the subpoena and any potential objection to access. We will advise you of our position in accordance with the court's timetable.\n>\n> Yours faithfully,\n>\n> [Your Name]\n> SDC Lawyers\n\n---\n\n### **3. Responding to the Demand for Medical Information**\n\nThis is a strategic decision. You are not obliged to provide this information informally simply because they demand it. Your client has already put her health in issue by filing an affidavit referencing her SMA syndrome and hospitalisation.\n\n**Strategic Options & Advice:**\n* **Option 1: Provide Limited, Relevant Information (Recommended):** To avoid an accusation of non-disclosure and to potentially narrow the issues, you could provide basic, relevant information that is already in evidence.\n * **What to Provide:** The name and address of her treating GP (Dr Alaa Al-Zabin), who has already provided a letter (Annexure A). The approximate date of her late 2025 hospitalisation at Bankstown Hospital (which is the subject of the subpoena anyway). A list of current medications *relevant to her parenting capacity*.\n * **What to Withhold:** Details of psychologists/psychiatrists unless specifically relevant. Extensive historical details. You can state that other details are not relevant to the parenting issues or are subject to confidentiality/objection.\n* **Option 2: Decline and Force a Formal Process:** Politely refuse the informal request. State that if the Respondent seeks specific documents, they should issue a Notice to Produce or an appropriate court application. This is more adversarial but may be justified if the request is seen as overly broad or fishing.\n* **Link it to the Subpoena:** Your response can note that their broad subpoena for all hospital records appears to cover the very information they are requesting, making the separate request redundant.\n\n**Draft Response (Medical Information Request):**\n> **Subject: Re: Request for Medical Information - Alewe & Francis [PAC991/2026]**\n>\n> Dear Ms Coady,\n>\n> We refer to your email of [Date].\n>\n> Our client's health is not a major issue in dispute, save for her diagnosed Superior Mesenteric Artery (SMA) syndrome, the details of which are already before the Court in her Affidavit affirmed 25 February 2026 (including the letter from her General Practitioner, Dr Alaa Al-Zabin, at Annexure A).\n>\n> Without conceding the relevance or proportionality of your request, and noting your client's subpoena to Bankstown Hospital seeks broad medical records, we provide the following limited information:\n> 1. **Treating General Practitioner:** Dr Alaa Al-Zabin. Contact details are available via the medical practice.\n> 2. **Recent Hospital Attendance:** Our client was admitted to Bankstown Hospital in late 2025 for treatment related to her SMA syndrome.\n> 3. **Current Pharmaceuticals:** Our client's current prescribed medications are for the management of her SMA syndrome and related conditions. A list will be provided on a confidential basis to the Court if and when it is deemed relevant by a Judicial Officer.\n>\n> Should your client seek further specific documents, the appropriate course is to issue a Notice to Produce.\n>\n> Yours faithfully,\n>\n> [Your Name]\n> SDC Lawyers\n\n---\n\n### **4. Overall Strategy & Next Steps**\n\n1. **Client Conference:** Urgently discuss the subpoena with Nada Alewe. Explain the process, her rights, and the costs/benefits of objecting.\n2. **File Notice of Objection (if instructed):** If objecting, draft and file the notice promptly, citing grounds like relevance and oppression. Serve it on all required parties.\n3. **Monitor the Subpoena:** Diarise the production date (1 April 2026). If you object, the registry will not allow inspection until the objection is determined by the court, often on the next return date.\n4. **Control the Narrative:** Your response to the medical request should be measured. Providing the minimal, already-disclosed information can portray cooperation while protecting your client's privacy. It also highlights that the subpoena may be excessive.\n5. **Prepare for the ICL:** The other side has flagged involving the ICL. Ensure your client's evidence (particularly regarding the father's alleged drug use, firearms, and the incident on 7 February 2026) is well-organised and credible, as the ICL will focus sharply on risk factors.\n\n**Key Principle:** Do not feel pressured by the other side's \"urgency\". Your duty is to your client. Respond procedurally correctly to the subpoena and strategically to the informal requests. Always take instructions.

**COMPREHENSIVE ADVICE ON OBJECTING TO THE SUBPOENA & STRATEGIC RESPONSE**\n\nBased on the file materials, the central issue is the subpoena for **Nada Alewe's medical records from Bankstown Hospital**. The Respondent's strategy is to shift focus from the serious allegations against him (drugs, firearms, risk to child) to Nada's health. Your defence must be robust, legally sound, and keep the court's focus on the child's safety.\n\n---\n\n### **PART 1: LEGAL BASIS FOR OBJECTION & RELEVANT AUTHORITIES**\n\nYour objection should be filed on **Form 6 - Notice of Objection**. The primary grounds are **Lack of Relevance** and **Oppression/Fishing Expedition**. Confidentiality/Privacy is a secondary but important consideration.\n\n#### **A. PRIMARY GROUND: LACK OF RELEVANCE (The most powerful argument)**\n* **Legal Principle:** A subpoena must have a \"legitimate forensic purpose.\" The documents sought must be *relevant* to an issue in the proceedings. The court will not allow a \"fishing expedition.\"\n* **Supporting Case Law & Act:**\n 1. **Commissioner for Railways v Small (1938) 38 SR (NSW) 564:** The classic authority establishing that a subpoena must not be used for a \"fishing expedition\" – an attempt to discover a case rather than to support an existing, properly articulated case.\n 2. ***Family Law Act 1975 (Cth) - Section 60CC:*** The paramount consideration is the **best interests of the child**. The court must consider:\n * **s60CC(2)(b):** \"The need to protect the child from physical or psychological harm from being subjected to, or exposed to, abuse, neglect or family violence.\" **This is the core of Nada's case** (drugs, firearms, aggression).\n * **s60CC(3)(f):** \"The capacity of each of the child’s parents... to provide for the needs of the child, including emotional and intellectual needs.\"\n * **s60CC(3)(m):** \"Any other fact or circumstance that the court thinks is relevant.\"\n * **Your Argument:** Nada's SMA syndrome and related hospitalisation in late 2025 are **not relevant** to her *current* capacity to parent. She has provided a GP letter (Annexure A) confirming the diagnosis and that it is managed. Her health condition does not relate to the **specific, serious risk factors** she alleges against the Father (drug use in child's presence, firearms, violent behaviour on 7 Feb 2026). The subpoena is an attempt to divert attention from these serious allegations. The Father has not filed any material suggesting Nada's health *currently* impairs her parenting capacity.\n\n#### **B. PRIMARY GROUND: OPPRESSION**\n* **Legal Principle:** A subpoena is oppressive if it is too broad, vague, or imposes an unreasonable burden. The other side has *admitted* the records are **7,000 pages**. This is the definition of oppressive.\n* **Supporting Case Law:**\n 1. ***Trade Practices Commission v Arnotts Ltd (1989) 21 FCR 306:*** The court held that a subpoena can be set aside if it is \"oppressive\" in the sense of being \"seriously and unfairly burdensome or prejudicial.\"\n 2. ***Hearne v Street (2008) 235 CLR 125:*** While about implied undertakings, it reinforces the principle that court processes must not be used in an oppressive manner.\n* **Your Argument:** A demand for **7,000 pages** of medical records is manifestly oppressive. It is a \"blunderbuss\" approach designed to overwhelm and intimidate. It imposes a huge burden on the hospital and the court. If the Father had a *specific, relevant* concern (e.g., a claim Nada was hospitalised for a drug-induced psychosis), he could have sought specific records via a **Notice to Produce**. This broad subpoena is an abuse of process.\n\n#### **C. SUPPORTING GROUND: CONFIDENTIALITY & PRIVACY**\n* **Legal Principle:** While not an absolute bar, the court recognises a public interest in the confidentiality of medical records. Access will only be granted where the relevance and necessity outweigh the privacy interest.\n* **Supporting Act & Case Law:**\n 1. ***Privacy Act 1988 (Cth) - Australian Privacy Principles (APPs):*** Reinforces the general right to privacy of personal information, including health information.\n 2. *****Alliance Craton Explorer Pty Ltd v Quasar Resources Ltd [2013] FCA 216:*** The court emphasised that \"the confidentiality of medical records is a significant matter\" and access should only be ordered where \"the documents are sufficiently relevant to justify overriding that confidentiality.\"\n* **Your Argument:** Nada has a reasonable expectation of privacy regarding her extensive medical history. She has voluntarily disclosed the *relevant* information: her diagnosis, that it required hospitalisation, and that it is managed (per GP letter). The 7,000-page request seeks to invade this privacy for no legitimate forensic purpose.\n\n---\n\n### **PART 2: COMPLETED NOTICE OF OBJECTION (FORM 6)**\n\n*(Based on the standard Form 6 - Notice of Objection to Subpoena)*\n\n**TO: The Respondent (Edward Francis) and his lawyers (Infocus Legal)**\n**AND TO: The Subpoenaed Party (South Western Area Health District - Bankstown Hospital)**\n\n**TAKE NOTICE** that Nada Alewe (the Applicant Mother) objects to the issuing party (the Respondent Father) having access to the documents produced in response to Subpoena S1 issued to the South Western Area Health District (Bankstown Hospital) on 18 March 2026.\n\n**GROUNDS OF OBJECTION:**\n\n1. **LACK OF RELEVANCE / NO LEGITIMATE FORENSIC PURPOSE:** The subpoena constitutes a \"fishing expedition\" (*Commissioner for Railways v Small*). The documents sought (the Applicant's complete medical records) are not relevant to any fact in issue in these parenting proceedings. The Applicant's health has been disclosed (Superior Mesenteric Artery syndrome, late 2025 hospitalisation, managed condition per GP letter Annexure A). The Respondent has adduced no evidence to suggest the Applicant's *current* health impacts her parenting capacity. The real issues are the serious risks posed by the Respondent, as particularised in the Applicant's Affidavit (drug use, firearms, aggression). The subpoena is a transparent attempt to divert the Court's attention from these primary child welfare concerns under **s60CC of the *Family Law Act 1975***.\n\n2. **OPPRESSIVE AND TOO WIDE:** The subpoena is oppressive (*Trade Practices Commission v Arnotts Ltd*). The issuing party has conceded the records span approximately **7,000 pages**. Such a vast, indiscriminate demand is seriously and unfairly burdensome. It is not confined in time or scope to any allegedly relevant period or condition. If the Respondent had a genuine, specific concern, the proper course was to issue a focused Notice to Produce.\n\n3. **CONFIDENTIALITY AND PRIVACY:** The subpoena seeks to override the Applicant's significant privacy interest in her confidential medical records without justification (*Alliance Craton Explorer v Quasar Resources*). The public interest in preserving medical confidentiality is strong. The Applicant has provided sufficient, relevant medical evidence to the Court. The wholesale production sought is disproportionate and unnecessary.\n\n**ORDERS SOUGHT:**\nThat the Court set aside the subpoena, or in the alternative, order that the issuing party have no access to the documents produced.\n\n**Signature:** _________________________\n**Dickson Chidiebere Simeon, Solicitor for the Applicant**\n**Date:** 19 March 2026\n\n---\n\n### **PART 3: STRATEGIC LETTER TO RESPONDENT'S LAWYER (Jodhi Coady)**\n\n**VIA EMAIL**\n\n**Jodhi Coady | Senior Associate**\nInfocus Legal Pty Limited\n**Email:** jodhi@infocuslegal.com.au\n\n**19 March 2026**\n\n**Dear Ms Coady,**\n\n**RE: ALEWE & FRANCIS | PAC991/2026 | SUBPOENA S1 & REQUEST FOR MEDICAL INFORMATION**\n\nWe refer to your correspondence of 18 March 2026 regarding the above matter.\n\n**1. Subpoena S1 to Bankstown Hospital**\nWe are in receipt of your notice regarding Subpoena S1. We are taking our client's instructions, however, we provide the following preliminary notice of our position to avoid unnecessary cost and court time.\n\nOur client will be **filing a Notice of Objection** to your client having access to the documents produced, on the following substantive grounds:\n* **Lack of Relevance / Fishing Expedition:** The subpoena seeks our client's complete medical records without any evidentiary basis to suggest they are relevant to her *current* parenting capacity. Our client has disclosed her relevant medical history (SMA syndrome, managed condition). The core issues in this case, as particularised in our client's Affidavit, are the serious risks posed by **your client** (exposure to illicit drugs, firearms, and aggressive behaviour). This subpoena appears to be a tactical attempt to shift focus from these paramount child safety concerns.\n* **Oppression:** Your own correspondence concedes the records are approximately 7,000 pages. A demand of this scale is manifestly oppressive and an abuse of the subpoena process.\n\nWe suggest the appropriate course, if your client maintains a concern about a *specific* aspect of our client's health relevant to parenting, is to discontinue this oppressive subpoena and consider a properly particularised **Notice to Produce**.\n\n**2. Request for Medical Information**\nIn light of the above, and noting the oppressive breadth of the subpoena which ostensibly covers the information you seek, our client's position is as follows:\n\nOur client's health is not a major issue in the proceedings. She has a diagnosed medical condition (SMA syndrome) which is managed. This was disclosed with her GP's letter (Annexure A). She was hospitalised for this condition at **Bankstown Hospital in late 2025**. She takes prescribed medication to manage this condition.\n\nWe do not concede the relevance of further details. The **name and practice details of her treating GP, Dr Alaa Al-Zabin, are contained within the annexed letter already in evidence.** We will not provide a list of daily pharmaceuticals on an informal basis. If the Court deems such information relevant, it can be provided in a controlled, confidential manner.\n\nYour client's efforts are better directed at responding to the very serious allegations concerning his drug use, possession of firearms, and conduct on 7 February 2026, which directly engage the Court's paramount consideration under **s60CC(2)(b) of the *Family Law Act 1975***.\n\nWe will serve our formal Notice of Objection in due course.\n\n**Yours faithfully,**\n\n**Dickson Chidiebere Simeon**\n**SDC Lawyers**\n**Solicitor for the Applicant**\n\n---\n\n### **PART 4: KEY STRATEGIC POINTS FOR YOUR CLIENT & CONDUCT OF THE CASE**\n\n1. **Client Advice:** Explain to Nada that the other side is trying to \"muddy the waters.\" Reassure her that her health condition is not a legal weakness. Her proactive disclosure of the GP letter shows responsibility. The court is concerned with *current* capacity and risk. Her allegations against the Father are specific and serious – that is what the judge will be most interested in.\n2. **Focus on the Real Issues:** In all correspondence and in court, pivot back to the **risk factors**:\n * \"Our primary concern, and the Court's, must be the evidence that the child was present where illicit drugs were in plain view and the Father was allegedly under their influence.\"\n * \"The Father has not responded to the allegations concerning firearms and drug dealing.\"\n3. **Tactical Posture:** Your objection is strong. The other side's subpoena is poorly drafted and obviously oppressive. This gives you the high ground. Your letter is firm and legally grounded, putting them on notice that their tactic will be challenged vigorously.\n4. **Next Steps:**\n * File and serve the **Notice of Objection**.\n * Prepare a short, sharp written outline (1-2 pages) for the next court date citing the case law above, ready to argue why the subpoena should be set aside.\n * Consider whether to file a **Notice to Produce** against the Father for any documents relating to:\n * Police records of the June 2022 raid (weed and steroids seizure).\n * Any records relating to firearms licences or charges.\n * This is a more targeted, justifiable discovery request.\n\nBy taking this robust, legally-referenced approach, you protect your client's privacy, challenge an oppressive court process, and forcefully keep the case focused on the child's safety in the Father's care.

**COMPLETED NOTICE OF OBJECTION (FORM 6.38) & COVERING LETTER**\n\nBased on the comprehensive legal analysis provided earlier, here is the completed **Notice of Objection** form and a strategic covering letter to the other side.\n\n---\n\n### **PART 1: COMPLETED NOTICE OF OBJECTION (Form 6.38)**\n\n**TO BE COMPLETED BY THE PERSON FILING THIS NOTICE**\n* **File number:** PAC991/2026\n* **Date for production or Court attendance:** 01/04/2026\n* **Court (Registry) location:** PARRAMATTA\n\n**PART A: DETAILS OF OBJECTION**\n\n**TO** the Registrar of the Federal Circuit and Family Court of Australia (Division 2), at **PARRAMATTA**\n\n**AND TO** the issuing party (Edward Francis / Infocus Legal)\n**AND TO** all other parties in this proceeding\n\n**Name of person objecting:** NADA ALEWE (the Applicant Mother)\n\n**[X] I am the person named in the attached subpoena.**\n\n**Filed on behalf of:** The Applicant (Nada Alewe)\n**Prepared by:** Dickson Chidiebere Simeon\n**Lawyer’s code:** [Your Code]\n**Name of law firm:** SDC Lawyers\n**Address for service in Australia:** LEVEL 3, SUITE 8, BANKSTOWN NSW 2200\n**State:** NSW\n**Postcode:** 2200\n**Email:** dsimeon@sdclawyers.com.au\n**Telephone:** 0409328772\n\n---\n\n**DETAILS OF OBJECTION CONTINUED…**\n\n**[X] I give notice that I object to the inspection / copying of some or all of the documents produced for the following reasons:**\n\n**GROUNDS OF OBJECTION:**\n\n1. **LACK OF RELEVANCE / FISHING EXPEDITION:** The subpoena seeks the Applicant's complete medical records without establishing a legitimate forensic purpose. The Applicant's health is not a major issue in dispute. She has disclosed the relevant medical information: a diagnosis of Superior Mesenteric Artery (SMA) syndrome, a related hospitalisation in late 2025, and that the condition is managed (per GP letter, Annexure A to her Affidavit affirmed 25 February 2026). The Respondent has adduced no evidence to suggest the Applicant's *current* health impairs her parenting capacity. The subpoena is a classic \"fishing expedition\" (*Commissioner for Railways v Small*) designed to divert the Court's attention from the serious, particularised risks to the child posed by the Respondent, as set out in the Applicant's Affidavit (exposure to illicit drugs, firearms, aggressive conduct).\n\n2. **OPPRESSIVE AND TOO WIDE:** The subpoena is oppressive (*Trade Practices Commission v Arnotts Ltd*). The issuing party has conceded the records span approximately **7,000 pages**. Such a vast, indiscriminate demand for a person's entire medical history is manifestly oppressive and an abuse of process. It is not confined in time, scope, or relevance to any specific condition alleged to affect parenting.\n\n3. **CONFIDENTIALITY AND PRIVACY:** The subpoena seeks to override the Applicant's significant and reasonable expectation of privacy in her confidential medical records without justification. The public interest in preserving medical confidentiality is strong (*Alliance Craton Explorer v Quasar Resources*). The Applicant has provided sufficient, relevant medical evidence to the Court. The wholesale production and inspection sought is disproportionate and unnecessary.\n\n**PART B: SIGNATURE**\n\n**Signed:** _________________________\n**Date:** ___ / ___ / 2026\n\n**Signed by (print full name):** DICKSON CHIDIEBERE SIMEON\n\n**[X] Lawyer for the person/party objecting**\n\n---\n\n### **PART 2: STRATEGIC COVERING LETTER TO INFOCUS LEGAL**\n\n**VIA EMAIL (WITH NOTICE OF OBJECTION ATTACHED)**\n\n**Jodhi Coady | Senior Associate**\nInfocus Legal Pty Limited\n**Email:** jodhi@infocuslegal.com.au\n\n**19 March 2026**\n\n**Dear Ms Coady,**\n\n**RE: ALEWE & FRANCIS | PAC991/2026 | SUBPOENA S1 TO BANKSTOWN HOSPITAL & NOTICE OF OBJECTION**\n\nWe refer to your correspondence of 18 March 2026 regarding the above matter.\n\n**1. Notice of Objection to Subpoena S1**\nWe are in receipt of your notice of Subpoena S1 issued to the South Western Area Health District (Bankstown Hospital) for our client's medical records.\n\nWe enclose, by way of service, a sealed copy of our client's **Notice of Objection** filed this day.\n\nOur client objects to your client having access to inspect or copy the documents produced, on the substantive grounds set out in the Notice, namely:\n* **Lack of Relevance / Fishing Expedition:** The subpoena seeks documents with no legitimate forensic purpose to the issues in the case, being a transparent attempt to shift focus from the serious risk allegations against your client.\n* **Oppression:** The demand for approximately 7,000 pages of medical records is manifestly oppressive.\n* **Confidentiality:** The subpoena unjustifiably overrides our client's significant privacy interests.\n\nThe Court Registry has been notified of the objection. Accordingly, no inspection of the documents can occur until the objection is determined by the Court.\n\n**2. Request for Medical Information**\nIn light of the above, and noting the oppressive breadth of the subpoena which ostensibly seeks the information you requested, our client maintains her position as previously advised.\n\nOur client's health is not a major issue. She has a diagnosed and managed medical condition (SMA syndrome). This was disclosed with her GP's letter (Annexure A). She was hospitalised for this condition at Bankstown Hospital in late 2025. She takes prescribed medication to manage this condition.\n\nWe do not concede the relevance of further details. The **name and practice details of her treating GP, Dr Alaa Al-Zabin, are contained within the annexed letter already in evidence.**\n\nShould your client maintain a genuine concern about a *specific* aspect of our client's health relevant to parenting, the appropriate course is to discontinue this oppressive subpoena and consider a properly particularised application to the Court.\n\nWe will await the Court's listing for the determination of the objection.\n\n**Yours faithfully,**\n\n**Dickson Chidiebere Simeon**\n**SDC Lawyers**\n**Solicitor for the Applicant**\n\n---\n\n### **KEY POINTS & NEXT STEPS FOR YOU:**\n\n1. **File & Serve:** Ensure the **Notice of Objection** is **filed** at the Parramatta Registry and **sealed**. Then, **serve** a sealed copy on:\n * **Infocus Legal** (the issuing party).\n * **South Western Area Health District (Bankstown Hospital)** (the subpoenaed party). This is crucial to put them on notice not to release the records for inspection.\n * The Court, via the subpoena email address (`parramatta.subpoena@fcfcoa.gov.au`), if required by local practice.\n\n2. **Client Advice:** Explain to Nada that the objection has been filed. The hospital must still send the records to the court by 1 April, but **no one can look at them** until a judge decides on the objection. This protects her privacy for now.\n\n3. **Prepare for Hearing:** The objection will likely be listed for hearing shortly after the production date (1 April). Prepare a concise, one-page outline of argument citing the case law (*Small, Arnotts, Alliance Craton*) and the principles from the *Family Law Act 1975* (s60CC) to argue that the child's best interests are served by focusing on the alleged risks from the Father, not by a fishing expedition into the Mother's medical history.\n\n4. **Tone of the Letter:** The letter is firm and legally grounded. It does not engage in debate about the medical information request, as the subpoena objection is the primary battleground. It positions their subpoena as the problem.\n\nThis approach is defensible, procedurally correct, and keeps the strategic initiative.