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10 et, i 138 14 15 16 ey 18 a 20 21 aD. 23 24 25 Case 1:20-cr-00330-PAE Document 212-2 Filed 04/16/21 Page 12 of 30 App.-0815 11 GALMGIUC Vietin'’s: -- THE COURT: Is what you want the retainer agreements, if there are any, whatever the arrangements are, with anybody on the privilege log that is listed as rendering advice? MS. MENNINGER: Yes, your Honor. That, I think, would be appropriate because some of our biggest issues concern the privilege log. THE, GOURT : IT understand. 7 What else? MS. MENNINGER: Your Honor, we have asked for, but been denied by plaintiff, her own deposition testimony in the Florida action. In that case the Court entered a confidential order -- THI! cd COURT: I'm prepared to deal with it. MS. MENNINGER: Your Honor, the next topic are plaintiff's medical records. THE COURT: I think I understand that. There is one thing, though. Are there any pre-'99 medical records? MS. MENNINGER: Your Honor, the case law is quite clear that injuries that were preexisting -- THE COURT: I'm sorry. Excuse me. Go ahead. MS. MENNINGER: Plaintiff has alleged that the defamation of this action triggered or caused her to reflect back upon her alleged sexual abuse. She has also alleged, for example, that many, several, three, I think, at last count, or SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0500 DOJ-OGR-00003814