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Case 1:15-cv-07433-LAP Document 1325-19 Filed 01/04/24 Page 13 of 20 15. 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 constituted “fair comment.” 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: Ms. Maxwell retains her First Amendment privilege to express her opinion, to criticize others including Plaintiff, and to comment on matters of public interest, including Plaintiffs allegations of being a sex slave or being sexually trafficked. Mr. Gow’s communication to members of the British media constituted expressions of opinion regarding Plaintiff and her public claims. 16. Identify the basis, including all underlying facts, for your contention that Ms. Maxwell or her agent did not cause or contribute to any damages suffered by Plaintiff? 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: Mr. Gow’s communication to the British media in January 2015 did not cause or contribute to any damages Plaintiff suffered because, inter alia, Plaintiff was widely reputed prior to any such communication to be a liar, a person who falsifies claims of sexual assault, and a sexually permissive woman, because Plaintiff already had substantial mental and medical conditions that pre-existed any statement issued, and because Plaintiff's damages, if any, were occasioned by her own wide-spread dissemination of her own false and defamatory statements. Without the steps that Plaintiff took to publish her fabricated and falsified history, she would not have suffered any reputational harm. 11