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Case 1:15-cv-07433-LAP Document 1325-14 Filed 01/04/24 Page 15 of 30 claims that Ms. Giuffre has somehow “withheld” more current records (despite executing a release for all records); Ms. Giuffre followed up with Ms. Lightfoot, who provided to Ms. Giuffre’s counsel correspondence stating that she has produced all of Ms. Giuffre’s records (see chart above, Giuffre006636), thereby indicating that she does not keep more current records. BS Dr. Olson Defendant claims that Ms. Giuffre failed to produce “the remaining documents for treatment by Dr. Olson,” but this is a wild inaccuracy. (And, Ms. Giuffre would refer the Court to a short excerpt from Dr. Olson’s deposition in which Dr. Olson explains in his own words his production. See McCawley Decl. at Exhibit 10, Dr. Olson Deposition Excerpt.) First, Ms. Giuffre signed a release for all records that Dr. Olson had. See McCawley Decl. at Composite Exhibit 6, March 8, 2016, Release for Dr. Olson records. Dr. Olson produced records Bates labeled GIUFFRE005342-005346 and GIUFFRE005492-005496. Dr. Olson then testified in his deposition that he kept a record on his laptop that was not a part of the medical records produced by his hospital. Jd. During the deposition, he printed that record and gave it to Defendant’s counsel. Jd. Now, Defendant’s counsel is claiming that this set of facts constitutes a discovery violation that warrants sanctions. There is no failure to produce here. Ms. Giuffre executed a medical release that provided for all of Ms. Giuffre’s medical records with regard to Dr. Olson, and records were produced. It was Dr. Olson who failed to include his “laptop records” among the records that were produced. Ms. Giuffre knew nothing of the “laptop records” until Dr. Olson’s deposition, and Dr. Olson provided them at that time, a fact Defendant admits in a footnote in her Motion to Reopen Ms. Giuffre’s Deposition. In that brief, Defendant complains that they were not “produced” until after Ms. Giuffre was deposed. That is a distortion. Defendant already had such documents from 11