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Case 1:15-cv-07433-LAP Document 1325-19 Filed 01/04/24 Page 12 of 20 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 self-defense privilege as it applies to Mr. Gow’s January 2, 2015 communication to members of the British press are spelled out in detail in the Memorandum of Law In Support of Defendant’s Motion to Dismiss at page 8-13. 14. Identify the basis, including all underlying facts, for your contention that Plaintiff is a public figure and unable to prove Ms. Maxwell exhibited actual malice. 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: Plaintiff sought public attention to her fabricated story concerning Ms. Maxwell and others. To wit, Plaintiff was paid more than $100,000 for her false story to the Daily Mail as well as the sale of a photograph purporting to be of herself and Prince Andrew. Plaintiff then further sought public attention to her story through (a) an interview with Bradley Edwards and Jack Scarola, (b) through contact with various literary agents, ghost-writers and news outlets, and (c) through a carefully orchestrated scheme to publish her false claims in a public pleading in the U.S. District Court for the Southern District of Florida, as well as media interviews and other contacts including ABC News, Sharon Churcher, and her purported work on behalf of Victims Refuse Silence. With regard to Maxwell’s absence of actual malice, any statements attributed to her regarding Ms. Roberts were limited in scope, directly targeted to Plaintiff's mis-statements of fact without any further comment regarding the many character and truthfulness shortcomings of Plaintiff, and were directed to the media outlets who continued to publish Plaintiff's lies. Ms. Maxwell decided against making any further statements regarding Plaintiff and her many lies in order to minimize public attention to Plaintiff's false claims, despite the many opportunities to provide additional truthful comment and color, as demonstrated by her email communications provided in discovery. 10