55 H3VOGIU1 ih records may or may not be admissible depending on what she says 2 on the stand, but they are her statements and they are, 3 therefore, potentially admissible as admissions of a party 4 opponent under 801(d) (2). 5 Moreover, her doctor is the one who wants to testify 6 about her need for medications going forward, and he has been 7 the one who's talked about her previous use of medications. 8 Her Colorado doctor testified that she had misled him and not 9 fully disclosed her need for prescription medications, and 10 there's also the question about whether or not, if she opens 1a the door and says she's properly used medications for 12 post-traumatic stress disorder, then we should be able to 13 examine her, not only with respect to that, but her other use 14 of prescription and illegal drugs. 15 And your Honor, I think it is inappropriately limiting 16 to say we can only talk about her use of drugs during the de period of '99 to 2002 because any drug use that she has used in 18 the meantime can go to establish whether or not she truly had 19 post-traumatic stress disorder or any other mental health 20 disorder. 21 She has filed a lawsuit asking for $30 million in 22 emotional distress, pain and suffering, and her doctor is going 23 to testify that she needs medications as a part of managing 24 that pain and stress and emotional distress. If she's been 25 using drugs in the interim that may affect her memory, if she's SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011358