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Case 1:15-cv-07433-LAP Document 1328-4 Filed 01/05/24 Page 18 of 40 before the court in April concerned discovery of Plaintiff's medical records because those records bore on her claim she had suffered “sex trafficking” damages. Interrogatory No. 13 does not seek medical information for that purpose. Plaintiff has alleged she has suffered more than $30 million in noneconomic damages from the allege defamation; she intends to request an additional $50 million in punitive damages related at least in part on the alleged conduct that caused the noneconomic damages. The defense intends to show that Plaintiff for financial and other improper reasons manufactured her allegations of “sex trafficking” and created from whole cloth her alleged $30 million in noneconomic damages from “defamation.” Some of the most relevant and material evidence concerns pre-1999 medical records and information, which contradict some of Plaintiff's sworn testimony about the alleged “sex trafficking.” For example, Plaintiff has testified Mr. Epstein and Ms. Maxwell subjected her to sex trafficking in 1998. Yet, in 1998 Plaintiff was an inpatient resident at a drug rehabilitation facility. As another example, Plaintiff has alleged that Ms. Maxwell’s denial in 2015 of Plaintiff's allegations of sex trafficking caused her to ingest ever greater quantities of anti-anxiety and other prescription medications, for which Plaintiff is seeking noneconomic damages. Yet, Plaintiff's pre-1999 medical records will establish that Plaintiff was a longtime drug addict—addicted to prescription and other drugs. Additionally, based on Plaintiffs claims of having suffered $30 million in mental pain and anguish, among other noneconomic damages, Ms. Maxwell is entitled to pre-1999 medical records to establish the mental and emotional baseline for Plaintiff and to determine her preexisting mental and emotional condition, since under no circumstances is Ms. Maxwell liable for Plaintiff's preexisting mental and emotional condition. See, e.g., Bauman v. 2810026 Canada Ltd., No. 15-CV-374A(F), 2016 WL 402645, at *1 (W.D.N.Y. Feb. 3, 2016); Pokigo v. Target 15