Giuffre_Maxwell_Batch4_p00344.png

Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 41 of 50 Regarding documents related to Interrogatory No. 11, which concerns facts about Ms. Giuffre’s lost wages, Ms. Giuffre has withdrawn her lost wage claim, and therefore, this interrogatory is no longer relevant. Regarding documents related to Interrogatory No. 12, concerns Ms. Giuffre’s health care providers subsequent to the defamation. Ms. Giuffre has already produced the documents and medical records associated with these providers, as described above. Accordingly, there is nothing to compel regarding this Interrogatory, and Defendant’s request should be denied. Regarding documents related to Interrogatory No. 13, concerns Ms. Giuffre’s health care providers prior to the defamation. Not only has Ms. Giuffre disclosed her health care providers from 1999 through the present, but she has retrieved and produced her medical records, and executed and sent releases for each and every one of them. Regarding any documents that may exist relating to any pre-1999 medical records, Ms. Giuffre incorporates her argument regarding the same, above, including the doctor-patient privilege. Regarding documents related to Interrogatory No. 14, which concerns sexual assault Ms. Giuffre experienced as a young teenager, prior to Defendant’s sexual assault of her while still a minor, Ms. Giuffre has no documents beyond the police reports that Defendant produced. This request should be denied, anyway, pursuant to the statues and case law set forth above. Despite Defendant’s efforts to hide the vast categories of documents that fall within the ambit of Interrogatory No. | (in contravention of Local Rule 37.1), as the Court can see, Interrogatory No. | is a sprawling, over-broad, request, that seeks documents that are either (1) non-discoverable pursuant to this Court’s April 21, 2016, Order; (2) protected by statutes and case law; (3) protected by the doctor-patient privilege; (4) are wholly irrelevant to this action; and (5) seek documents that are not within the possession, custody or control of Ms. Giuffre, or 35