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Case 1:15-cv-07433-LAP Document 1328-4 Filed 01/05/24 Page 19 of 40 Corp., 2014 WL 6885905, at **2-3 (W.D.N.Y. Dec. 8, 2014) (plaintiffs preexisting mental and physical conditions relevant to plaintiff's damage claim); Bruno v. CSX Transp., Inc., 262 F.R.D. 131, 133-34 (W.D.N.Y. 2009) (granting discovery of plaintiffs medical records relating to plaintiffs substance abuse and mental health treatment where disclosure was likely to reveal evidence of alternative or intervening causes for the damages claimed by plaintiff). Objection 9. The interrogatory is not overbroad. The interrogatory required Plaintiff to identify healthcare providers who treated her for specified conditions, e.g., mental conditions and addiction, “prior to” any alleged defamation of her by Ms. Maxwell. Plaintiffs “overbreadth” objection argued that the interrogatory was not “limited in scope to the medical information relating to the abuse she suffered from Defendant and Jeffrey Epstein.” The premise is wrong. Plaintiff, who is suing for more than $80 million in damages and who claims to have suffered more than $30 million in noneconomic damages, including “pain and suffering,” cannot be heard to complain about an interrogatory requesting the identities of healthcare providers who treated her before the alleged defamation-related injuries. Plaintiff's pre-defamation physical and mental condition is the baseline for her claim for damages and is therefore highly relevant. See, e.g., This Mot., at 15-16 (citing cases). The interrogatory is not unduly burdensome. We incorporate here the discussion above on Objection 3, and supplement as follows. Plaintiff implicitly concedes that her physical and mental condition before the alleged defamation is relevant to this lawsuit. Her complaint about burdensomeness suggests only that her “pre-defamation” physical and mental condition was so complex or required so much medical attention that it would be unduly burdensome for her to “track down” all her medical providers. The simple answer is twofold. One, relevant and 16