DOJ-OGR-00003824.pdf

--- Page 1 --- **Case 1:20-cr-00330-PAE** **Document 212-2** **Filed 04/16/21** **Page 22 of 30** **App.-0825** **G4LMGIUC** **21** **The criminal investigation. Any materials that the plaintiff has with respect to any criminal investigations will be turned over except for any statements made by the plaintiff to law enforcement authority and those statements, if there are such, will be submitted in camera, and I will review them.** **5** **I hope that clears up our problems. Tell me if I have failed in my effort to do so. Yes, ma'am.** **7** **MS. MENNINGER: Your Honor, two quick things, I think.** **8** **With respect to medical records, we also certainly believe that the period from the time the statement was made in January 2015 until the present, because she has claimed emotional distress from that defamation --** **11** **from that defamation --** **12** **THE COURT: Sure, yes.** **13** **MS. MENNINGER: The problem is, we have asked through interrogatory what were the names of the medical providers because they have not disclosed who her medical providers were.** **14** **So there is no way for us to tell whether the records in fact have been sought from and produced with respect to each of those medical providers. I will say that other records in the possession of plaintiff lists other doctors who they have not asked for records from or releases.** **17** **THE COURT: Let's see if we can clear that up.** **22** **MS. McCAWLEY: We have disclosed the names. She has those names. We have also disclosed records, the more recent records. We have not contested that.** **24** **SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300** **DOJ-OGR-00003824**