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Case 1:15-cv-07433-LAP Document 1328-5 Filed 01/05/24 Page 13 of 45 This document is CONFIDENTIAL under the Court’s Protective Order (DE 62) 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; g. whether health insurance or some other person or organization or entity has paid for the medical expenses; and h. For each such Health Care Provider, please execute the medical and mental health records release attached hereto as Exhibit A. Response to Interrogatory No. 13: Ms. Giuffre objects to this interrogatory because it violates this Court’s Order. The Court has excluded the production of medical records from prior to 1999, stating, “the damage issue relates, in my view, solely to the defamation.” (April 21, 2016, Hearing Transcript at 20:23-24). This holding applies to pre-1999 medical records. As this interrogatory is not limited to the time period ordered by this Court, Ms. Giuffre objects. 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. Ms. Giuffre objects because Rule 26 does not allow discovery that is so burdensome as to require a Herculean effort by an adult to track down every possible prescription ever written for Ms. Giuffre, or every physician who ever treated Ms. Giuffre, even as a small child. Such a request is not only impractical 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. 12