12 h, sep 18, 2019 y - Depp v Heard Dr Kipper Response to Subpoena Seeking Johnny Depp Medical Records

Description:

Dr. Kipper responds and objects to your demand as follows:

1.The subpoena is improper and in violation of the Privacy Act, 5 U.S.C. § 552a, and HIP AA Privacy Rule, 45 C.F.R Parts 160 and 164; California Civil Code Section 56.10, et. Seq;

2. The subpoena violates Plaintiffs constitutional rights to privacy;

3. The subpoena is vague, ambiguous, overly broad as to time and scope, burdensome, oppressive, annoying and harassing in that it seeks documents that are unrelated and beyond the scope of the litigation; and

4. The subpoena seeks information that are irrelevant to the subject matter of this action, and is not reasonably calculated to lead to the discovery of admissible evidence.

Notwithstanding these objections, Dr. Kipper further responds and objects:

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