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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 24 of 30 App.-0827 A GALMGIUC years and years ago. The recent doctors we have disclosed they have noticed for deposition. THE COURT: What else? MS. MENNINGER: Your Honor, with respect to the employment and education records, as you heard plaintiff say, she has disclosed, quote/unquote, what she has. Under local rule 33.3, we are allowed to ask for the names of witnesses with knowledge at the outset of the case, and they might be custodians of records. We asked her who have been your employers. She won't tell us who her employers have been. She has just gone through her computer and say if I have an employment record I'll give it to you, but I am not going to tell you who her employers were. THE COURT: She will. cd MS. MENNINGER: Same thing with the education records. We asked her to list where she had gone to school and tell us where it is. She won't do it. Those are the things where my skepticism arises from. Largely, to the extent your Honor has ordered the production of whatever materials, criminal investigation materials that were not to be submitted in camera, those were the ones that involved plaintiff's statements, we would like the other materials that they have brought with them today to give to your Honor that do not encompass their client's statements to law enforcement. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0500 DOJ-OGR-00003826