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Case 1:15-cv-07433-LAP Document 1325-14 Filed 01/04/24 Page 14 of 30 Dr. Hayek on April 28, 2016, to request the records. Upon information and belief, Dr. Hayek does not keep patient’s medical records for longer than seven years, and, therefore, no longer has any records pertaining to Ms. Giuffre. Ms. Giuffre and her counsel have made inquiries to Dr. Hayek’s office via telephone and email, but, to date, have not received any response. Again, Ms. Giuffre has no input on Dr. Hayek’s document retention policies, and therefore, the lack of production of records from Dr. Hayek cannot be attributed to Ms. Giuffre. C. Dr. Kutikoff, Wellington Imaging Associates (“Wellington Imaging”) , and Growing Together Plaintiff provided Defendant’s counsel executed medical release forms for Dr. Kutikoff, Wellington Imaging, and Growing Together on April 29, 2016. See McCawley Decl. at Composite Exhibit 7. Accordingly, Ms. Giuffre has no direct knowledge as to what, if anything, these three providers produced to Defendant’s counsel. Ms. Giuffre has done everything in her power to make them available to Defendant, a fact that Defendant cannot dispute. Again, there has been no “failure” by Ms. Giuffre here, as Ms. Giuffre has signed and sent the necessary release forms for the records to be sent directly to Defendant.'' D. Ms. Lightfoot Defendant admits that Ms. Giuffre produced Ms. Lightfoot’s records in footnote 4 of her brief on page 11, yet on page 16, Defendant wrongfully states Plaintiff has not produced Dr. Lightfoot’s records. Despite the self-contradictory briefing, Ms. Lightfoot has produced records. See chart above, Giuffre005431-005438, Medical Release Form with documents. As with the other providers, Ms. Giuffre has executed and sent medical records release forms to Ms. Lightfoot, and has thus met her discovery obligations. To follow up on Defendant’s wrongful a Upon information and belief, Ms. Lightfoot is not a medical doctor, but an Australian “Consulting Psychologist.” 10