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Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 25 of 50 Defendant’s request for pediatric records is also overly-broad because, as this Court correctly noted, Ms. Giuffre is not seeking damages based on anything prior to Defendant abusing her. Defendant has told the Court that before she was sexually trafficked her as a minor, Tellingly, Defendant does not state upon what basis she makes the claim that they are relevant, nor does she say what relevance it has on Defendant’s defamation of her in 2015. Of course, Defendant has no supporting case law. Finally, Ms. Giuffre does not allege that she was trafficked by Defendant in 1999. Through discovery, Ms. Giuffre has been able to obtain documents that established that Defendant trafficked her starting in the summer 2000. Ms. Giuffre was 16 until August 9 of 2000, and was 17 thereafter. Defendant seems to think that it is much better, or even excusable to traffic a 16 or 17 year old than a 15 year old. Maxwell Dep. Tr. 33:3-4 (April 22, 2016) (“Virginia Roberts who your [sic] are referring to was a masseuse aged 17”). See McCawley Dec. at Exhibit 4. Of course, like the other young girls they abused, Ms. Giuffre was not a massage therapist.'' Despite Defendant’s view that being a older than 15 is fine for massaging her convicted pedophile boyfriend, the law makes it illegal to traffic humans at any age; particularly when they are children under the age of 18. 5. The Physician-patient Privilege Applies to Information sought by Interrogatory No. 13 The physician patient privilege most certainly applies to an individual’s pediatric medical records. The identity of a physician’s name also gives information regarding the type of medical treatment Ms. Giuffre received, particularly if that physician is specialist. Defendant cites no case law whatsoever in her argument that no privilege applies to this information. "' See McCawley Decl. at Exhibit 5, Recarey Dep. Tr. at 125:16-23 (“Q. Did you ever ascertain whether or not FP had any formal training in massage therapy? THE WITNESS: She did not. None of the high school girls that I interviewed or anyone under the age of 18 had any formal massage training.) 19