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Case 18-2868, Document 278, 08/09/2019, 2628230, Page80 of 648 In addition to her previous response, Ms. Giuffre supplements the response to include: January 8, 2015 | Internet The https://www.thesun.co.uk/archives/news/6754/prince- Sun andrews-pal-ghislaine-groped-teen- girls/?CMP=spklr-128508300-Editorial-TWITTER- TheSunNewspaper-20150108-News 12. Identify any Health Care Provider from whom You received any treatment for any physical, mental or emotional condition, including addiction to alcohol, prescription or illegal drugs, that You suffered from subsequent to the Alleged Defamation by Ghislaine Maxwell, including: a. the Health Care Provider’s name, address, and telephone number; b. the type of consultation, examination, or treatment provided; c. the dates You received consultation, examination, or treatment; d. whether such treatment was on an in-patient or out-patient basis; e. the medical expenses to date; f. whether health insurance or some other person or organization or entity has paid for the medical expenses; and g. for each such Health Care Provider, please execute the medical and mental health records release attached hereto as Exhibit A. Supplemental Response to Interrogatory No. 12: Ms. Giuffre objects to this interrogatory in that it is overbroad and not limited in scope to the medical information relating to the abuse she suffered from Defendant and Jeffrey Epstein. Pursuant to the Rules, if requested documents are not yielded in a “reasonable inquiry,” Ms. Giuffre is not obligated to expend all of her time and resources on a quest to gather medical files that are unknown to her or unaccessable after reasonable inquiry. See, e.g., Manessis v. New York City Dep't of Transp., No, 02 CIV. 359SASDF, 2002 WL 31115032, at *2 (S.D.N.Y. Sept. 24, 2002)