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Case 1:15-cv-07433-LAP Document 1328-4 Filed 01/05/24 Page 17 of 40 and unduly burdensome, but likely impossible. Accordingly, such an interrogatory is merely for the purpose of imposing a burden on Ms. Giuffre and her attorneys, not to mention the purposes of harassment. 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 from her birth to the present to find any prescriptions ever written for her for anything at all.) Ms. Giuffre is not certain as to her the sum of her medical expenses from 1999 to the present, and therefore is unable to answer that subpart. Ms. Giuffre is not aware of what health insurance carrier or other organization paid for her historical medical expenses unless it is identified on the records produced to the Defendant. Finally, Ms. Giuffre objects in that it seeks information protected by the doctor-patient privilege, and any other applicable privilege stated in the General Objections. Ms. Giuffre further objects to this interrogatory in that it violates Rule 33 as its subparts, in combination with the other interrogatories, exceed the allowable twenty-five interrogatories. Ms. Giuffre further objects to this request in that it is overbroad and seeks confidential medical information of a sex abuse victim and is not limited in scope to the issues in this case. Without waiving such objections, Ms. Giuffre has already produced her responsive documents Bates labelled GIUFFRE000001 to GIUFFRE007566, and supplements such documents as follows.. me Objection 8. Pre-1999 medical records are discoverable. Plaintiff had requested damages allegedly suffered from being the “victim of sex trafficking” dating back to 1999. On April 21, 2016, the Court ruled that Plaintiff's damages are limited to harm from the alleged defamation. Regarding Ms. Maxwell’s request for records pre-dating 1999, the Court said: “‘As for the pre-’99 medical records, based on where we are at the moment, I do not believe that those are relevant ... [b]ecause the damage issue relates ... solely to the defamation.” Tr. 20:21-24 (Apr. 21, 2016). Plaintiff objected to this interrogatory on the ground it requested pre-1999 medical information in “violat[ion]” of the Court’s ruling. The objection should be overruled. The issue “Plaintiff's voluminous arguments and argumentative citations to case law—inserted into her multi-page “objections” —are omitted in this Motion. “Immediately following this paragraph was a tabular chart listing names of healthcare providers, the healthcare provided, Plaintiffs counsel’s efforts undertaken to obtain records, and documents produced to the defense. On July 29, 2016, Plaintiff supplemented the chart. The supplementation did not cure the deficiencies. 14