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Case 1:15-cv-07433-LAP Document 1328-5 Filed 01/05/24 Page 14 of 45 This document is CONFIDENTIAL under the Court’s Protective Order (DE 62) 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. 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) (concluding that “ability to pursue discovery regarding [plaintiff's] medical records should be limited in some manner”); Evanko v. Electronic Systems Assoc., Inc., No. 91 Civ. 2851, 1993 WL 14458 at *2 (S.D.N.Y. Jan. 8, 1993) (applying the New York state physician-patient privilege, and holding that where plaintiff claimed that she suffered emotional distress, defendants did not have “a license to rummage through all aspects of the plaintiff's life in search of a possible source of stress or distress,” including plaintiffs medical records); Wachtman v. Trocaire College, 532 N.Y.S.2d 943, 944 (N.Y. App. Div. 1988) (holding that the scope of a waiver of the physician-patient privilege in personal injury cases is “limited and does not permit discovery of information involving unrelated illnesses and treatment”); Sgambellone v. Wheatley, 165 Misc.2d 954, 958, 630 N.Y.S.2d 835, 838 (N.Y. Sup.Ct. 1995) (holding that in a personal injury action, plaintiff's waiver of the physician-patient privilege “is not a wholesale waiver of all information about the plaintiffs entire physical and mental conditions but a waiver only of the physical and/or mental condition that is affirmatively placed in controversy”) (emphasis in original). 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 13