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Case 1:15-cv-07433-LAP Document 1198-12 Filed 01/27/21 Page 1 of 30 United States District Court Southern District of New York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAINTIFF'S CORRECTED' RESPONSE IN OPPOSITION TO DEFENDANT'S MOTION FOR DUE \ 1) kyr's RULE 37(b) &(c) SANCTIONS FOR FAILURE TO COMPLY WITH COI RI ORDER AND FAILURE TO COMPLY WITH RULE 26(a) Due to inadvertence, one of the medical providers disclosed to Defendant, and from whom she diligently sou t medical records as far back as March of this year, Dr. Mona Devanesan, was left off of medical provider chart. It has been added in this version of the brief for increased accuracy. There are no other changes. EFTA02784586
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