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Case 1:15-cv-07433-LAP Document 1325-19 Filed 01/04/24 Page 15 of 20 sexually assaulted as a 14 year old by two young men in the “Woodsies,” that she had suffered at a since-closed drug rehabilitation facility at the hands of “guards,” that she suffered from “anxiety,” depression and suicidal ideation from at least 1998 before meeting Ms. Maxwell, that she has experienced marital discord, that she suffered from parental and familial alienation, that she has been beaten, choked and strangled by her husband on more than one occasion, that she has suffered from pre-existing and post-existing drug addictions, alcohol abuse and prescription medication addiction and abuse, that she has suffered many of the ill-effects of an impoverished childhood, and that she suffers from certain limitations of mental faculty. 19. Identify the basis, including all underlying facts, for your contention that Plaintiff’s damages were the result of her own conduct or the conduct of others and were not proximately caused by any action of Ms. Maxwell. 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: Plaintiffs records disclose that she (allegedly) had been sexually assaulted as a child by a family friend, that she had been held as a sexual slave in captivity as a young teenager, that she had been sexually assaulted by teens when she was 14 in the back of a house, that she had been sexually assaulted as a 14 year old by two young men in the “Woodsies,” that she had suffered at a since-closed drug rehabilitation facility at the hands of “guards,” that she suffered from “anxiety,” depression and suicidal ideation from at least 1998 before meeting Ms. Maxwell, that she has experienced marital discord, that she suffered from parental and familial alienation, that she has been beaten, choked and strangled by her husband on more than one occasion, that she has suffered from pre-existing and post-existing drug addictions, alcohol abuse and prescription medication addiction and abuse, that she has suffered many of the ill-effects of an impoverished childhood, and that she suffers from certain limitations of mental faculty. Plaintiff was advised by her own physician in Australia to engage in psychotherapy but has refused to do so. Plaintiff was advised to cease taking valium but has refused to do so. Plaintiff was advised by a court to stay away from her abusive husband but has refused to do so. Further, Plaintiff had the opportunity to truthfully tell her actual history on a number of occasions, including during her interviews with ABC, with other media outlets, with book authors and journalists, but chose not to tell her true story, instead telling falsehoods and fabricated and mistaken events, dates and participants. 13