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Case 1:15-cv-07433-LAP Document 1320-33 Filed 01/03/24 Page 13 of 24 Plaintiff's intentional refusal to obey this Court’s Order, including failure to disclose her treating psychologist she is still seeing to this day for the very injuries she claims in this lawsuit, is ground for precluding her damage claims for physical and emotional distress. 2. Lesser sanctions will be insufficient and Ms. Maxwell has been prejudiced Plaintiff's pattern of discovery abuses and failure to disclose necessary and required information makes clear that no lesser sanction will deter Plaintiffs continuing discovery abuses. “[T]he purposes of Rule 37 sanctions, [is] “to ‘ensure that a party will not benefit from its own failure to comply,’ to ‘obtain compliance with a particular order issued,’ and to ‘serve a general deterrent effect on the case at hand and on other litigation, provided that the party against whom they are imposed was in some sense at fault.’” Szafrankowska v. AHRC Home Care Servs., Inc., 2008 WL 186206, *1 (S.D.N.Y. Jan. 22, 2008) (quoting Update Art, Inc. v. Modiin Pub., Ltd., 843 F.2d 67, 71 (2d Cir.1988)); see also S. New England, 624 F.3d at 149. Ms. Maxwell has been severely prejudiced by Plaintiff's failure to provide the required identifying information and documents from her health care providers. One health care provider identified by Plaintiff in her deposition is a psychiatrist, Judith Lightfoot, who is located in Australia. Plaintiff's specifically chim ii [7 7 ____ PO Obviously, Dr. Lightfoot has relevant information concerning Plaintiffs emotional state both before and after the alleged defamatory statement. Indeed, her testimony could conclusively prove that Plaintiff's mental state has been unaffected by the alleged defamation. Despite this, Plaintiff purposefully omitted Dr. Lightfoot from her 10