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Case 1:15-cv-07433-LAP Document 1320-33 Filed 01/03/24 Page 19 of 24 Pt Yet, Plaintiff did not report this treatment or identify these health care providers in her Initial Disclosures or Interrogatory Reponses. She also purposefully left this information out of her testimony relating to doctors she has seen after January 2, 2015, i obviously trying to hide this very serious other intervening cause of her damages — and she almost got away with it. Po Dr. Lightfoot is perhaps the most relevant health care provider, yet her name appears nowhere in the Disclosures or in the Interrogatory Reponses. Plaintiff still has not produced a single record from Dr. Lightfoot for any treatment after the alleged defamatory statement. A third doctor, Dr. Donahue, may have been named, but the nature and dates of the treatment he provided were never disclosed. Po a. Menninger Decl., Ex. G, p. 336. There is a clear need to depose Dr. Donahue regarding this failure to mitigate damages. Yet, his records have not been produced, and his role in Plaintiff's treatment was not disclosed until Plaintiffs deposition. 16