The following e-filed documents, listed by NYSCEF document number (Motion 005) 121, 122, 123, 124, 125, 126, 127, 128, 129, 130, 131, 136, 139, 140, 141, 142, 143, 144, 155, 156, 157 were read on this motion to QUASH SUBPOENA. The following e-filed documents, listed by NYSCEF document number (Motion 006) 132, 133, 134, 135, 137, 158, 159, 160, 161, 162, 163, 164, 165, 182, 185, 186, 187 were read on this motion to QUASH SUBPOENA. The following e-filed documents, listed by NYSCEF document number (Motion 007) 145, 146, 147, 148, 149, 150, 151, 152, 153, 154, 166, 167, 168, 169, 170, 171, 179 were read on this motion to QUASH SUBPOENA. The following e-filed documents, listed by NYSCEF document number (Motion 008) 172, 173, 174, 175, 176, 177, 178, 189, 190 were read on this motion to QUASH SUBPOENA. BACKGROUND Plaintiff, Shelley Rubin, is the co-founder and chair of the Rubin Museum of Art, which focuses on art of the Himalayan regions. Plaintiff alleges that she and defendant Ms. Nisha Sabharwal engaged in approximately eighty transactions over a five-year period in which the plaintiff purchased hundreds of pieces of jewelry from Ms. Sabharwal for a total amount of approximately $18 million. Plaintiff alleges that she purchased these jewelries from Ms. Sabharwal and co-defendant Vastra Inc. based upon the belief that these jewelries were “generational,” “museum-quality,” and of “considerable value,” which she later discovered her belief was mistaken. Plaintiff alleges that the defendants fraudulently induced her to purchase such jewelries at inflated prices. Plaintiff filed this action against the defendants asserting claims of fraud, breach of contract, and unjust enrichment. On February 20, 2018, this court dismissed plaintiff’s fraud-based claims, and the Appellate Division, First Department, affirmed. (Rubin v. Sabharwal, 2018 NY Slip Op 30293[U] [Sup Ct, NY County Feb. 20, 2018], affd 171 AD3d 580 [1st Dept 2019].) Various discovery disputes have arisen between the parties in litigating plaintiff’s remaining claims, which have led in turn to the four motions at issue in this decision. Motion sequence 005 is a motion by defendants to quash a subpoena served by plaintiff on nonparty Capital One, N.A., seeking bank records for defendants’ bank accounts with Capital One; and seeking to suppress any information already obtained from Capital One pursuant to the subpoena. Motion Sequence 006 is a motion by plaintiff to quash documentary and testimonial subpoenas served by defendants on plaintiff’s personal lawyer, Eileen Caulfield Schwab, Esq., and her law office. On motion sequence 007, defendants seek to quash further bank-records subpoenas served by plaintiffs on Capital One and nonparty Bank of America, NA, and to suppress any information produced to plaintiffs by the banks. Motion sequence 008 is defendants’ motion to quash a nonparty subpoena served by plaintiff on Parker Pohl LLP, which served as counsel in a related action. Additionally, in connection with the subpoenas that are the subject of motion sequence 007, defendants pointed out that those subpoenas listed Ms. Sabharwal’s unredacted Social Security number and did not instruct the recipient banks to keep that number confidential. As initially filed, therefore, motion sequence 007 also sought an order imposing several confidentiality requirements on plaintiff with respect to defendants’ Social Security numbers. The parties later entered into a confidentiality agreement relating to the Social Security numbers (and documents containing those numbers). Defendants have also asked this court to order plaintiff to disclose the name of the private investigative firm that procured Ms. Sabharwal’s Social Security number, the methods by which the investigative firm procured the number, and any other information obtained by the investigative firm as it relates to the defendants or this action. (See NYSCEF No. 183.) The court has considered that request along with the other issues presented on motion sequence 007. Further, during depositions of Mr. Mohit Sabharwal and of Nisha Sabharwal, defendants’ counsel instructed the witnesses not to answer several questions. Plaintiff contends that counsel was not entitled under the rules governing depositions to instruct the witnesses not to answer. The parties have requested rulings from the court resolving this disagreement, and have submitted letter briefing to this court on the issue. Motion sequences 005, 006, 007, and 008; defendant’s letter request pertaining to the Social-Security-number issue; and the parties’ requests for deposition rulings are consolidated here for disposition. Defendants’ motion for a protective order quashing the subpoena served on Capital One (mot seq 005) is granted. The branch of plaintiff’s motion (mot seq 006) for a protective order quashing the document subpoena served on attorney Schwab and her law office is granted in part and denied in part; and the branch of that motion for a protective order quashing the testimonial subpoena is denied. Defendants’ motion for a protective order quashing the further subpoenas served on Capital One and Bank of America (mot seq 007) is granted. Defendants’ request for a protective order imposing confidentiality requirements with respect to defendants’ Social Security numbers (mot seq 007), and defendants’ related request for an order directing disclosure about how plaintiff obtained those numbers, are denied as academic given the parties’ confidentiality agreement. Defendants’ motion for a protective order quashing the subpoena served on Parker Pohl (mot seq 008) is granted. Plaintiff’s request for an order directing Ms. Sabharwal and defendant Mohit Sabharwal to answer questions that were posed to them at their depositions, but that they declined to answer on the instructions of counsel, is granted in part and denied in part. DISCUSSION Motion sequences 005 and 007 address similar issues, as do motion sequences 006 and 008. This decision addresses 005 and 007 together, then 006 and 008, then the parties’ joint letter request for deposition rulings. Under New York law, a party moving to quash a subpoena “bears the initial burden to show that the information sought is utterly irrelevant or that the process will not lead to legitimate discovery.” (Liberty Petroleum Realty, LLC v. Gulf Oil, L.P., 164 AD3d 401, 404 [1st Dept 2018].) Only if that initial burden is met does the burden shift to the subpoenaing party to demonstrate that the information sought is material and necessary. The words “material and necessary” must be construed liberally to require disclosure, as long as the disclosure sought is relevant to the prosecution or defense of an action. (Matter of Kapon v. Koch, 23 NY3d 32, 38 [2014].) Moreover, there is no “requirement that the subpoenaing party demonstrate that it cannot obtain the requested disclosure from any other source.” (Id.) Social Security numbers, however, “are almost never discoverable.” (Alta Apts. LLC v. Wainwright, 2004 NY Slip Op 50797[U], *5 [Civ Ct, NY County July 19, 2004].) Suppression is not warranted even of documents that had been “improperly or irregularly obtained within the meaning of CPLR 3103 (c),” as long as such documents or information “would have to be produced in the ordinary course of discovery” such that the movant’s substantial rights were not “prejudiced by the manner in which they were obtained.” (Coast to Coast Energy, Inc. v. Gasarch, 77 AD3d 589 [1st Dept 2010].) I. The Motions to Quash on Motion Sequences 005 and 007 A. Motion Sequence 005 On this motion, plaintiff asserts that the records requested constitute “evidence of the ascribed value of the pieces sold as complained of in this action as well as provide evidence of their value and the proof of the payment for the same.” (NYSCEF No. 126.) Plaintiff argues that this court previously directed discovery of the costs of procurement of the jewelry sold to the plaintiff. (NYSCEF No. 139 at 2-4, 7.) Plaintiff also argues that it was not clear until the depositions of defendants Mr. and Ms. Sabharwal that co-defendant Vastra procured all of the jewelry sold to plaintiff from Ms. Sabharwal and paid her for such jewelries. (Id.) Per Ms. Sabharwal’s Affidavit of Diligent Search (NYSCEF No. 144 at
6-8), Ms. Sabharwal testified that a vast majority of the jewelry that was sold to the plaintiff was procured from various suppliers, most in India and the others in New York, over the years through cash and bartering. Ms. Sabharwal testified that it was typical for these transactions in India to not be accompanied by receipts or other documentations. (NYSCEF No. 144 at
