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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 14 of 30 App.-0817 LS GALMGIUC moment. To the extent she is now alleging she suffers from emotional distress from any preexisting -- THE COURT: That's from the defamation. = MS. MENNINGER: She claims it's from the defamation. However, your Honor, if she has preexisting conditions that were truly the cause of whatever emotional injury she claims that she now possesses -- 7 THE COURT: Correct me if I'm wrong, and perhaps plaintiff will make it clear, my understanding is that the injuries alleged result from the claim of the alleged defamation, period. MS. MENNINGER: Your Honor, she has claimed emotional distress from the defamation, yes. We are requesting evidence that would show that she has preexisting emotional conditions. = THE COURT: Not from the defamation. MS. MENNINGER: Not from the defamation. From the many, many other things that have occurred in her life predating even her meeting Mr. Epstein and Ms. Maxwell, as she has told the press, not because we told the press that. Your Honor, it is difficult, if not impossible, to address her claimed $30 million emotional distress from a defamation statement that was a denial of her allegations versus any emotional distress or emotional conditions she already had before any such statement was made. Similarly, your Honor, we have asked for discovery of SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0500 DOJ-OGR-00003816