records may or may not be admissible depending on what she says

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