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Case 1:15-cv-07433-LAP Document 1325-15 Filed 01/04/24 Page 5 of 14 Furthermore, there remain numerous doctors from the relevant time frame for whom no records have been provided. In addition to all of the treatment providers from 1999-2002, no records have been provided by Plaintiff for: | Menninger Decl., Ex. O. Plaintiff, while not opposing the reopening of the deposition for documents produced after that date, writes to refute supposed “baseless suggestions of impropriety.” Yet, her Response contains additional impropriety. Plaintiff repeatedly asserts that she has produced and disclosed documents but her chart and her arguments neglect to mention that those documents were only sought and produced after the deposition, indeed up to and including the very same day she filed her Response on June 28. Her claim that she could not “remember” Dr. Donohue or Judith Lightfoot until her deposition is hard to believe given she had consulted with them in the days and weeks just before her Interrogatory Responses. /d.; Ex. D at 334-35. Further, all of the 2015-2016 medical records from Colorado were only produced because the defense, not > Defendant’s Interrogatories sought the identities and locations of Plaintiff’s health care providers, the dates of treatment, the nature of the treatment, medical expenses to date, and releases for each. Inexplicably, despite this Court’s Order to answer the interrogatory, Plaintiff still has not provided the dates of treatment, the nature of treatment or any information concerning expenses for any of her providers. 3