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Case 1:15-cv-07433-LAP Document 1320-33 Filed 01/03/24 Page 5 of 24 These discovery abuses cannot be condoned. All of this information is directly relevant to, and necessary to defend against, Plaintiff's damages claims for “psychological and psychiatric injuries and resulting medical expenses” and “past, present and future pain and suffering, mental anguish, humiliation, embarrassment, loss of self-esteem.” Plaintiffs claims for these categories of damages must be stricken or evidence as to these damages precluded from trial under Fed. R. Civ. P. 37(b)(2)(A)(ii)& (iii) and Fed. R. Civ. P. 37(c)(1)(C). BACKGROUND FACTS On February 12, 2016, Ms. Maxwell served Interrogatories on Plaintiff for the identities and locations of any Health Care Provider from whom she has “received any treatment for any physical, mental or emotional condition, including addiction to alcohol, prescription or illegal drugs, that You suffered from subsequent to the Alleged Defamation by Ghislaine Maxwell” (Interrogatory No. 12) and “prior to the Alleged Defamation.” Interrogatory No. 13 (emphasis added). As to both, Ms. Maxwell provided releases for Plaintiffs signature. On March 16, 2016, Plaintiff refused to provide the names of any of Plaintiff's treating physicians, nor the requested releases, claiming “privilege.” Menninger Decl., Ex. A. On March 22, 2016, Plaintiff served Supplemental Responses & Objections and then Amended Supplemental Responses & Objections. Menninger Decl., Ex. B. Neither contained responses as to Plaintiff's health care providers. On March 22, 2016, Plaintiff also provided an Addendum to Plaintiffs Rule 26 Initial Disclosures in which she listed as potential witnesses, Dr. Steven Olson and Dr. Carol Hayek. Menninger Decl., Ex. C. In her Initial Disclosures, Plaintiff included medical records as documents that she intends to use to establish her damages claims. Menninger Decl., Ex. D. On March 22, 2016,