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Case 1:15-cv-07433-LAP Document 1325-19 Filed 01/04/24 Page 5 of 20 the Interrogatories to information in the possession, custody or control of individuals other than Ms. Maxwell or her counsel. OBJECTIONS TO INSTRUCTIONS 1. Ms. Maxwell objects to Instruction No. 1, in particular the definition of the “Relevant Period” to include July 1999 to the present, on the grounds that it is overly broad and unduly burdensome and calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. The Complaint at paragraph 9 purports to describe events pertaining to Plaintiff and Defendant occurring in the years 1999 — 2002. The Complaint also references statements attributed to Ms. Maxwell occurring in January 2015. Defining the “Relevant Period” as “July 1999 to the present” is vastly overbroad, irrelevant and not reasonably calculated to lead to the discovery of admissible evidence, and as to certain of the Interrogatories, is intended for the improper purpose of annoying or harassing Ms. Maxwell and it implicates her privacy rights. Thus, Ms. Maxwell interprets the Relevant Period to be limited to 1999-2002 and December 30, 2014 - January 31, 2015 and objects to the Interrogatories, except as specifically noted. Without waiver of this Objection, Ms. Maxwell notes the Court Order in this case which permits discovery regarding events between 2002 and the present which relate to the topics of the sexual trafficking of females and will respond to the Interrogatories for the period 2002 to the present on that topic. 2. Ms. Maxwell objects to Instruction Nos. 2-21 to the extent they impose obligations beyond those imposed by Fed. R. Civ. P. 33(b) and Local Rule 33.3. In particular, the majority of the Instructions pertain to Requests for Production of Documents and are therefore inapplicable to Interrogatories. 3. Ms. Maxwell objects to these Interrogatories to the extent they exceed those types of interrogatories permitted by Local Rule 33.3. In particular, the majority of these Interrogatories do not seek the names of witnesses with knowledge of information relevant to the subject matter of this action nor the existence, custodian and location or general description of relevant documents. Moreover, these Interrogatories are not a more practical method of obtaining the information sought than a deposition or a request for production of documents. 4. Finally, the contention interrogatories are premature, as other discovery in this case has not concluded. Local Rule 33.3(c). 5. Ms. Maxwell objects to the Definition of “Identify” to the extent it expands upon the meaning ascribed to that term by Local Rule 26.3(c).