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Case 1:15-cv-07433-LAP Document 1320-33 Filed 01/03/24 Page 6 of 24 Ms. Maxwell was forced to file a Motion to Compel Plaintiff to Disclose Pursuant to Fed. R. Civ. P. 26(a)(1). Docket Entry (“DE”) 64. On March 31, 2016, Ms. Maxwell was forced to file a Motion to Compel Plaintiff, inter alia, to properly respond to Interrogatory Nos. 12 and 13. Docket Entry (“DE”) 75. On April 21, 2016, Plaintiff's counsel represented to the Court during oral argument that “We have disclosed the names. She has those names. We have also disclosed the records, the more recent records. We have not contested that.... But we have disclosed the names of the providers.” (Tr. at 21-22) Plaintiff’s counsel stated the only missing doctors were “in the past.... years and years ago.” (Tr. at 22-23) attached to Menninger Decl., Ex. E. At the April 21, 2016 hearing, the Court ordered Plaintiff to produce the records from Ms. Giuffre’s medical doctors (apart from pre-1999) and to respond fully to the interrogatories concerning all of her treating physicians after 1999. /d. (Tr. 20-21). On April 29, 2016, Plaintiff served Second Amended Supplemental Responses & Objections. Menninger Decl., Ex. F. As to Interrogatory No. 12 (seeking the names of treatment providers subsequent to the Alleged Defamation). Plaintiff listed: Dr. Steven Olson Dr. Chris Donahue Dr. John Harris and Dr. Majaliyana Dr. Wah Wah Dr. Sellathuri Royal Oaks Medical Center Dr. Carol Hayek NY Presbyterian Hospital Campbelltown Hospital Sydney West Hospital Westmead Hospital Dr. Karen Kutikoff Wellington Imaging Associates Growing Together. 1 : : That motion remains open.