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Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 17 of 50 interrogatory is quite obvious, and done in bad faith. Ms. Giuffre listed every physician known to her. The list is extensive. It looked like this: “Health Care Providers known to Ms. Giuffre who may have provided treatment subsequent to the defamation are as follows’: © Dr. Steven O17, e Dr. Chris Donohue, e ] S ~ Q oO & ] & = i) 4 > e Dn Ks = > ° 3 tJ an ° 5 o =x ° n Ss = tJ 1, e = — < Qa => = c s ge = = i) i) t, * Health care providers known to have provided treatment both prior to and subsequent to Defendant’s January 3, 2015 defamation of Ms. Giuffre are listed in the supplemental responses for both Interrogatories 12 and 13. There may be additional crossover of providers that have treated Ms. Giuffre prior to the defamation, listed in the supplemental response to Integratory 13, who also provided treatment subsequent to the defamation. Ms. Giuffre reserves the right to revise, amend, and supplement her response to Interrogatory No. 12 with providers listed in her supplemental response to Interrogatory 13 if and when she becomes aware of any additional crossover. 11