I went into some of it here,
In short court orders are the exception to the privacy rule. Usually medical record subpoenas are not court orders and the record custodian needs “satisfactory assurances” the patient was notified and is okay with the release. Usually the patient will have signed off on the subpoena. In this kind of case the patient will probably ask the court for a protective order or something, otherwise the records custodian (defendant) will require a court order.
(This quoted post was written before I understood that the present law has people suing the providers and not the woman.)
~Max