on general issues of bias and motive for fabrication, as is her right under the Confrontation Clause of the United States Constitution. Letter from L. Menninger to Hon. Lorna G. Schofield at 2-3, ECF No. 114; see also Letter from L. Menninger to Hon. Debra C. Freeman at 3 ECF No. 108 ("Certainly, the amoun

subpoenas, serve; email protective order to all counsel; email correspondence with counsel re. conferral 0.60 315.00 11/16/2018 TG Confer with L. Menninger re discovery matters; review Zinoviev deposition documents 0.50 262.50 LAM Draft letter to court with proposed protective order; serve notices of