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Case 1:15-cv-07433-LAP Document 1320-33 Filed 01/03/24 Page 8 of 24 Further, during the deposition of Dr. Olson on May 26, 2016, Ms. Maxwell learned that he had additional records in his laptop that had not been produced prior to his deposition.” Menninger Decl., Ex. K, p. 36. As of today’s date, more than four months after Ms. Maxwell first sought the identities of Plaintiff's health care providers and the records concerning the same, more than a month and a half since the Court ordered Plaintiff to produce such identities and records, and 10 days before the end of fact discovery in this case, Ms. Maxwell has learned of at least five additional doctors who have treated Plaintiff since the time of the alleged defamatory statement: Dr. Lightfoot, Dr. Geiger, Dr. Heaney, Donna Oliver P.A and Dr. Streeter. In each case, documents relating to these doctors were not provided until after their identities became known through deposition or other independent investigation by Ms. Maxwell. Plaintiff still has failed to produce any records from: (a) Dr. Donahue, (b) Dr. Hayek, (c) Dr. Kutikoff, (d) Wellington Imaging Assocs., (e) Growing Together, (f) post 2011 records from Dr. Lightfoot, and (g) the remaining documents for treatment by Dr. Olson. With respect to Dr. Donahue, Dr. Hayek, Dr. Kutikoff, Wellington Imaging Assocs., Growing Together and Dr. Olson, Plaintiff has failed to provide complete responses to the Interrogatories including the dates and nature or treatment. Menninger Decl., Ex. F. Plaintiff has alleged the following categories of damages: (A) “Physical, psychological and psychiatric injuries and resulting medical expenses—in the approximate amount of $102,200 present value”; (B) “Past, present and future pain and suffering, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of standing in the community, loss of dignity, and invasion of privacy in her public and private life not less than $30,000,000.00”; and (C) Estimated lost income of $180,000 annually. Present value $3,461,000 to $5,407,000” > At the deposition, copies were produced that were difficult to read. Despite requests, legible copies have not been provided.