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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 15 of 30 App.-0818 14 GALMGIUC her claimed prior sexual abuse. She has, again, put in the press a number of statements regarding that, and I can't imagine that it is to the extent she claims privacy now, those might be relevant in our case both on credibility and also damage issues. Your Honor, we have asked for a lot of other interrogatories and documents that go to her damage claims, her education records, her work history. She has refused to answer any questions before where she has worked. She has refused to answer any questions about where she went to school. All of these are appropriate under the local rule for interrogatories. Finally, your Honor, we have asked for her contracts with media. She has refused to disclose those. She has refused to disclose her tax returns that show all of the payments that she has received from various media sources. = THE COURT: I take it your view of any funds from the media would operate to reduce her damages. MS. MENNINGER: Your Honor, it also shows her motive and bias in bringing this case. To the extent she has been paid for her stories to the media, which she has, she has admitted that she has been paid hundreds of thousands of dollars for giving these stories to the media. But to the extent that she is now bringing this defamation claim, if she is still either planning to receive more money from the media, she has a motive and bias to make SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0500 DOJ-OGR-00003817