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Case 1:15-cv-07433-LAP Document 1325-7 Filed 01/04/24 Page 11 of 30 2011 records from Ms. Lightfoot, and (g) the remaining documents for treatment by Dr. Olson. (Mtn. at 5). This is also incorrect. There has been no “failure,” as discussed, in turn, below. Moreover, if records from any providers have not been produced, it is not Ms. Giuffre’s “failure,” but rather, the failure of the providers, particularly as Ms. Giuffre has executed releases for her records from all these providers. Ms. Giuffre and her counsel have been diligent in compiling nearly two decades of medical records from various states and countries. The chart below provides an overview the efforts undertaken by Ms. Giuffre and the production to Defendant as a result. MEDICAL HEALTHCARE ACTION PROVIDER PROVIDED TAKEN RELATED GIUFFRE PRODUCTION Giuffre 005342-005346 St. Thomas More Beals Hospital Records (Dr. Olsen) Dr. Olsen Primary Care Physician Rencngt | Giuflte 005492-005496 St. Thomas More a Hospital Records (Dr. Olsen) 5/23/16 Giuffre 005498 Centura Health Release Centura Teter Form (All Medical Records) Health Request Giuffre 005501-005569 Responsive : Records (Centura Health) 3/8/16 Ltr Dr. Carol Psychiatrist —— Giuffre and counsel contacted physician’s Hayek y al office via telephone and email to follow up. Request Dr. Chris Tr 4/5/16 Lit | Giufre 006631-006635 (Dr. Donahue) Donahue Request Dr. Joh Giuffre 005315 005322 The Entrance a 4/5/16 Ltr_ | Medical Centre Maili one Request (Dr. John Harris and Dr. Darshanee ie Mahaliyana) 4/5/16 Ltr | Giuffre 005339 005341 Central Coast | Request Family Medicine (Dr. Wah Wah) Dr. Sellathuri | peo Giuffre 005089 005091 (“Dr. M. Sella”) Request Royal Oaks Has no treatment records 4/5/16 Ltr_| Giuffre 005347 005349 Royal Oaks