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I think that this is a case where there may have been some green ink flowing (and I do not mean in reference to the second amendment of pleadings).

This is not to dispute that NHSR are at times hopeless: in a matter I am handling they requested disclosure of the claimant's medical records / notes a few weeks prior to the deadline for the response and then asked for an extension of (in loose terms) two months because they did not have the records / notes.

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