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Case 1:15-cv-07433-LAP Document 1320-33 Filed 01/03/24 Page 20 of 24 One can only assume Dr. Carol Hayek has relevant information — she was actually included in Plaintiff's Second Supplemental Responses & Objections. Plaintiff nevertheless fails to identify the nature of Dr. Hayek’s treatment of her and no records have been produced. Plaintiff cannot be permitted to identify people with relevant information that she plans on relying on and yet refuse to inform the defense the content of the information. The information that was withheld and only produced after Ms. Maxwell’s counsel discovered its existence is of paramount importance to the damages claims. It is likely that the still undisclosed evidence is equally compelling. 2. Ms. Maxwell would require an extension of the discovery period Ms. Maxwell does not wish to extend the discovery deadlines in this matter and has diligently worked to meet all deadlines so that this case can proceed on the schedule set out in the Scheduling Order. Ms. Maxwell obtained the deposition testimony of the one treatment provider Plaintiff did initially identify® — Dr. Olsen — who has provided valuable information that disproves any physical or emotional distress damages caused by the alleged defamation. Now, on the eve of discovery closing, Ms. Maxwell has learned of at least five other medical treatment providers in the most relevant timeframe — people providing medical and mental health services post the alleged defamatory statement in January 2015. Plaintiffs discovery failures in hiding relevant treating physician information have prevented Ms. Maxwell from obtaining what now appears to be critical information. Two of these providers — Drs. Lightfoot and Donahue -- are located in Australia, requiring significant travel to obtain their deposition, and potentially requiring service of process through other means. Four other treatment providers — Dr. Geiger, ° Plaintiff also originally disclosed a Dr. Carol Hayek as a treatment provider. However, no information has been provided on what Dr. Hayek treated Plaintiff for or when she was treated, and no medical records have been produced. 17