A Manhattan federal judge on Monday allowed Michael Avenatti to subpoena the mental health records of his former client, Stormy Daniels, ahead of an anticipated January trial on charges that he had defrauded the adult film star.

U.S. District Judge Jesse M. Furman of the Southern District of New York ruled that Avenatti’s attorneys could subpoena a set of records for the “purposes of impeachment” in the case, which accuses the disgraced lawyer and one-time presidential hopeful of stealing approximately $300,000 that was owed to Daniels under a book deal.

Any documents produced pursuant to the subpoena, Furman said, would first be subject to in camera review to determine if they should eventually be turned over to the defense.

Furman noted, however, that his ruling could set up a “potentially unsettled and thorny” question about whether the materials were covered by the psychotherapist-patient privilege, an issue which he said Daniels and the prosecution team might “have the better of.”