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“This pattern of abuse and coercive control continued over the approximately decade-long duration of Ms Holmes and Mr Balwani’s relationship, including during the period of the charged conspiracies,” the filing states.
Citing the syndrome known as intimate partner abuse, the lawyers claim: “Mr Balwani was controlling with Ms Holmes, that Ms Holmes was isolated by Mr Balwani, that Mr Balwani was combative with Ms Holmes, and that Mr Balwani was often physically present in Ms Holmes’ office, all tactics that … are abuse tactics used by abusers.”
Holmes has claimed in
previous filings that Balwani was sexually abusive, “withdrew affection if she displeased him, controlled what she ate, how she dressed, how much money she could spend, who she could interact with”. He also threw “hard, sharp objects at her” and controlled her sleep, lawyers have said.
But this is the first declaration by Holmes’s legal team that she plans to use the alleged abuse as a defense of her actions, claiming Balwani was “dominating her and erasing her capacity to make decisions”. As a result, the attorneys claim, it affected Holmes’s ability “to deceive her victims”.
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