10
id.
12
13
14
L5
16
ne)
18
life)
20
21
22
23
24
25
55 H3VOGIU1
records may or may not be admissible depending on what she says
on the stand, but they are her statements and they are,
therefore, potentially admissible as admissions of a party
opponent under 801(d) (2). Moreover, her doctor is the one who wants to testify
about her need for medications going forward, and he has been
the one who's talked about her previous use of medications. Her Colorado doctor testified that she had misled him and not fully disclosed her need for prescription medications, and
there's also the question about whether or not, if she opens
the door and says she's properly used medications for
post-traumatic stress disorder, then we should be able to
examine her, not only with respect to that, but her other use
of prescription and illegal drugs.
And your Honor, I think it is inappropriately limiting to say we can only talk about her use of drugs during the
period of '99 to 2002 because any drug use that she has used in
the meantime can go to establish whether or not she truly had
post-traumatic stress disorder or any other mental health disorder. She has filed a lawsuit asking for $30 million in
emotional distress, pain and suffering, and her doctor is going
to testify that she needs medications as a part of managing
that pain and stress and emotional distress. If she's been
using drugs in the interim that may affect her memory, if she's
SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
HOUSE_OVERSIGHT_011358