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Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 20 of 50 Dr. Mona Devanesn, Dr. Ranjit Thind, Medicare Australia is) = = tJ > = tJ > DN PJ 5 > ° In addition, counsel for Ms. Giuffre made multiple phone calls to potential medical records custodians in and attempt to locate Dr. Kutikoff’s records. These efforts were unsuccessful. 7 On information and belief, this occurred after 1999 and prior to the January 3, 2015 defamation. Based on the uncertainty of the exact date, Ms. Giuffre reserves the right to revise, amend, and supplement her responses to Interrogatories 12 and 13. ® Records from Medicare Australia are generally limited to 3 years. Ms. Giuffre is continuing to pursue additional records from prior to July 19, 2013 through their offices in Australia. ” Ms. Giuffre has now identified Dr. Wah Wah San and Dr. Wah San to be the same provider to the best of her knowledge. She had previously listed both names. 14