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Case 1:15-cv-07433-LAP Document 1325-14 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 Evil Hospital Records (Dr. Olsen) Dis@leen Primary Care Physician Reccngt | Giuflre 005492-005496 St. Thomas More 4 Hospital Records (Dr. Olsen) 5/23/16 Giuffre 005498 Centura Health Release Centura | fetter Form (All Medical Records) Health Ps Request Giuffre 005501-005569 Responsive 4 Records (Centura Health) 3/8/16 Ltr Dr. Carol Psychiatrist — Giuffre and counsel contacted physician’s Hayek syctiaws hd office via telephone and email to follow up. Request Drihis a 4/5/16 Ltr | Giuftre 006631-006635 (Dr. Donahue) Donahue Request ee a Book a Giuffre 005315 005322 The Entrance anew 4/5/16 Lir_| Medical Centre Maili an a Request (Dr. John Harris and Dr. Darshanee hye ee Mahaliyana) PC ee 4/5/16 Ltr | Giuffre 005339 005341 Central Coast Dr. Wah Wah | Request Family Medicine (Dr. Wah Wah) rshh | —————— 4/5/16 Ltt | Giuttre 005089 005091 (“Dr. M. Sella”) _ Request Royal Oaks Has no treatment records 4/5/16 Ltr_| Giuffre 005347 005349 Royal Oaks