10
id.
12
13
14
L5
16
ne)
18
life)
20
21
22
23
24
25
19 H3VOGIU1
she wasn't truthful about something, about being sexually
assaulted, but the documents themselves describe something that's unequivocally sexual assault under Florida law, something that is unequivocally nonconsensual. So that would honestly be another mini trial and would take us far afield of what facts are relevant to this case.
And again, any minor probative value that's past sexual assault that Ms. Giuffre experienced as a child is
completely swallowed by the prejudicial effect on the jury.
r
MR. CASSELL: Your Honor, I think I'm the next one up.
For purposes of clarity, we're up to point number 7 in our omnibus motion.
This one I think is just a very simple and
straightforward one. We move to exclude derogatory sexual characterizations. This is a case that your Honor has been framing this morning. It doesn't require use of a term from
defense counsel, for example, describing our client as a prostitute or as a slut. We thought we would get agreement
when we saw the responsive papers from the defense, but as you
know, they objected in it's entirety to this motion, so we're here asking that defense counsel not refer to our client as a prostitute, not refer to her as a slut, and they also advise
their witnesses that such language would be inappropriate ina
federal trial dealing with a defamation issue.
On this particular point about prostitute, it's
SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
HOUSE_OVERSIGHT_011322