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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 21 of 30 App.-0824 20 GALMGIUC The plaintiff has told me that they have now supplied all the education and employment records that they have. I think if there is any question about that, if the defense is skeptical, I would ask the counsel for the plaintiffs to make that statement on the record, not necessarily here, but by way of a statement to the Court and principally to the defendant. On the question of residences, that's, in my view, not a contention interrogatory because of the nature of this case. I think it's more like listing witnesses. So I would say that the plaintiff should supply all residences. The Dershowitz deposition will be produced under the confidentiality provision. As I read what I've been given, it's to be held in confidence and it will remain in confidence, but it will be produced. Yes, the tax returns should be produced. 15 years seems like -- I see. Ok. 15 years. The medical records of the period '99 to 2002 will be produced and the plaintiff will indicate whether that production is complete or, if it isn't complete, when it will be complete. As for the pre-'99 medical records, based on where we are at the moment, I do not believe that those are relevant. Because the damage issue relates, in my view, solely to the defamation. If that changes in any way, I will revisit that issue. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0500 DOJ-OGR-00003823