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Case 1:15-cv-07433-LAP Document 1325-19 Filed 01/04/24 Page 11 of 20 documents and is more appropriately discovered through the deposition of Ms. Maxwell, during which time she already answered questions on this topic. Finally, Ms. Maxwell objects to this Interrogatory to the extent it seeks information from a time period not relevant to this action. Without waiver of the foregoing, Ms. Maxwell responds as follows: Not to her knowledge. 12. Identify your basis for your contention that Plaintiff’s claims are barred by the United Kingdom’s Defamation Act of 2013. ANSWER: Ms. Maxwell objects to this Interrogatory on the grounds that it is overly broad and unduly burdensome and calls for information that is irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. Maxwell objects to this Interrogatory to the extent it calls for attorney-client communications and attorney work product. This Interrogatory is premature and violates Local Rule 33.3(c) because discovery is ongoing in this case, not complete, and it is more than thirty days from the conclusion of discovery. See, e.g., Shannon v. New York City Transit Auth., No. 00 CIV. 5079 (RWS), 2001 WL 286727, at *3 (S.D.N.Y. Mar. 22, 2001) (Sweet, J). Without waiver of the foregoing, Ms. Maxwell responds as follows: The January 2, 2015, communication by Ross Gow to members of the British media did not, nor was it likely to, cause serious harm to the reputation of Plaintiff. The imputation conveyed by the communication is substantially true. Substantial portions of the communication conveyed honest opinion. The communication was privileged as a matter of public interest. The communication is barred by the single publication rule because Mr. Gow previously issued a communication that was substantially the same as the January 2, 2015 communication, issued by materially the same manner of publication, and Plaintiff and her counsel did not deny or timely take action with respect to the previous communication. 13. Identify the basis, including all underlying facts, for your contention that Plaintiff's claims are barred because the statements made by Ms. Maxwell or her agent were protected by the self-defense privilege. ANSWER: Ms. Maxwell objects to this Interrogatory on the grounds that it is overly broad and unduly burdensome and calls for information that is irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. Maxwell objects to this Interrogatory to the extent it calls for attorney-client communications and attorney work product. This Interrogatory is premature and violates Local Rule 33.3(c) because discovery is ongoing in this case, not complete, and it is more than thirty days from the conclusion of discovery. See,