gov.uscourts.nysd.447706.1198.17.pdf

Case 1:15-cv-07433-LAP Document 1198-17 Filed 01/27/21 Page 1 of 3 EXHIBIT R  Summary of Plaintiff’s Statements Concerning Disclosure of HealthCare Information Date Plaintiff’s Statement Truth Sources March 16 Refusal to identify any health Privilege waived by Plaintiff when Plaintiff’s Responses & care providers or records because suing for $30 million of medical and Objections to First “privileged” mental injury Discovery Requests April 4 Plaintiff “has sent written Plaintiff had sent only one release to Plaintiff’s Response to requests to her providers, paid the Dr. Olsen. Defendant’s Motion to fees associated with copying her Compel (DE #78) at 18; files, and is awaiting her On April 5, Plaintiff sent out releases providers responses.” to five new providers. Response at 7 (chart); McCawley Decl. in Reply to this Motion, Ex. 6 (releases dated April 5) April 21 “We have disclosed the names. Plaintiff had disclosed two providers, Transcript of April 21 Hrg. She has those names. We have Dr. Olsen and Hayek in her at 21-22 also disclosed records, the more Addendum to Rule 26 Disclosures on recent records. We have not March 22. Menninger Decl. Exs. B & F contested that. … We have disclosed the names of the Plaintiff’s other 15 doctors were not providers.” disclosed in response until April 29 April 21 Only doctors not yet disclosed Doctors from 2015-2016 not then Transcript of April 21 Hrg. were “in the past. We are talking disclosed: Del Mar, Lightfoot, at 22-23 Case 1:15-cv-07433-LAP Document 1198-17 Filed 01/27/21 Page 2 of 3 about years and years ago.” Donohue, Oliver, Streeter, Geiger, Heaney. Menninger Decl. Ex. B Case 1:15-cv-07433-LAP Document 1198-17 Filed 01/27/21 Page 3 of 3