12 h, may 29, 2020 y - Depp v Heard EMAIL Ben Rottenborn Ben Chew Camille Vasquez HIPAA Disclosure

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From: Rottenborn, Ben
Sent: Friday, May 29, 2020 1:47 PM
To: Chew, Benjamin G.; Vasquez, Camille M.
Subject: HIPAA Issue

Ben and Camille,
Good to speak to you this afternoon. One thought on the HIPAA issue for your consideration: when I asked for specific providers from whom you believe you don't have a full set of relevant documents, Camille mentioned the offices of Drs. Kipper and Cowan. As I said on the call, we've produced relevant and responsive documents that we've received from those offices and staff, but if your goal is making sure that they have produced everything that's relevant related to both of our clients, we share that goal. In short, I don't believe this is so much a HIPAA issue (because they didn't object to producing our client's documents to us, which we then properly produced) as it is an interest in making sure what they have produced is full and complete. Let us know if you'd like to discuss a way that both sides can ensure that (whether through a joint communication to the medical providers or some other way). That seems like it would address your concern.

If there are other specific providers about which you have questions, please let me know.

Thanks,
Ben

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