10
id.
12
13
14
L5
16
ne)
18
life)
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