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10 fd. 12 [3 14 15 16 i) 18 wife) 20 21 22 23 24 25 65 H3VOGIU1 number of times that she saw doctors, made statements, sought treatment, got medications, all of which are reflected in her medical records and are something that about which she may be cross examined. She claims her medical records are private. She is the one seeking $30 million in emotional distress, pain and suffering, and I think when you do that, I'm sure her lawyers advised her that her privacy rights with respect to her medical records would no longer be the same as a private individual. Your Honor, Motion in limine 17, again, the dollar value of the Jane Doe settlement depends entirely on what happens in terms of plaintiff's case in chief and whether any other evidence regarding the Jane Doe 102 litigation comes into vidence, because if it does, then the settlement and the settlement amount may very well become relevant, but I can't say right now how anyone intends to use that at trial, why it would be relevant, and I can't say whether or not the settlement amount would likewise be relevant. Motion in limine 18, the Cassell-Edwards—Dershowitz litigation and their settlement. It's interesting to note Mr. Cassell to refer to himself in the third person when he was talking about that litigation. Your Honor, there are a number -—- I can count five reasons, at least, that that case is relevant to the facts in this case. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011368