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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 17 of 30 App.-0820 16 G4LMGIUC case. Your Honor, we have complied with our production. We have produced the materials that she is saying we have not produced. It's incorrect. We have produced her school records that we have. We have produced her tax records that we have. We have produced all of those items that we have. With respect to her medical records I am going to direct you to the case that is cited in our brief as the Evanko case and it was a similar circumstance to here. It was a Title VII case where there were emotional distress damages being alleged and the Court found that the other side could not have carte blanche ruling over all of her medical records from the time she was born to the present. We met and conferred on two hours on their discovery requests, your Honor. We agreed to produce all of her medical records that we had from 1999 to 2002 and anything else we had that was related to the sexual abuse she endured at the hands of the defendant and Mr. Epstein. We have agreed to produce those. We have already started producing those records from the various doctors, from the treating physicians. Those are in their production. Should they be entitled to things that happened prior to that? Absolutely not, your Honor. They are not entitled to a full-scale production of everything that's happened in this young lady's life. She was abused by these individuals. She shouldn't be reabused by having to disclose SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0500 DOJ-OGR-00003819