DOJ-OGR-00003818.jpg

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 16 of 30 App.-0819 1.5 G4LMGIUC her story consistent with her previous stories. She has claimed $5 million in lost wages, your Honor. This is a person who has worked primarily as a waitress in the last 15 years, until her media sensational story was purchased from her by some British press. THI! Gel COURT: Anything else? MS. MENNINGER: Your Honor, the other issues are addressed in our papers. We have highlighted her incomplete production on several fronts and her refusal to answer any interrogatories. So I would rest on my papers with respect to the other arguments. Thank you. MS. McCAWLEY: Thank you, your Honor. I'd like to be very clear here, your Honor. Discovery production, I've tried to do that in our papers. But listening to opposing counsel I'm concerned maybe she hasn't reviewed the documents we have produced. We have clearly produced all of the media communications she has, including records -—- THE COURT: All the media. MS. McCAWLEY: All of the media communications. She has issued wildly broad requests in this case which we have complied with. We ran over 200 search terms. Her request No. 5 alone seeks communications with over 100 individuals. And we have complied, your Honor. This is coming from the defendant who until Monday night, when you directed her to produce privileged information, has only produced two e-mails in this SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0500 DOJ-OGR-00003818