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20 H3VOGIU1

interesting. Am I conjuring up something that's not going to

happen? No, your Honor. The defendant's own expert report described our client as a prostitute. Your Honor has under advisement th xpert report from Dr. Esplin, and so I deposed

Dr. Esplin, and I said, "Are you sure that's an accurate term

in the context of this case? Because we have a child who

cannot consent to sexual activities." And he backed off

immediately and agreed that that was an inaccurate term for him

to use to describe my client, Ms. Giuffre. So even the defense's own expert says the term "prostitute" is inappropriate.

Your Honor has authority, of course, under Rule 611 to

manage the trial, to avoid undue harassment or embarrassment.

Also Rule 403 allows you to restrict things that would be

substantially prejudicial with no probative value, which is

exactly what we have here. So we would ask you simply to reign in derogatory language, both from witnesses and opposing counsel.

MS. SCHULTZ: Your Honor, I'll be addressing the next

several points in the omnibus motion, starting with number 8.

I think I can narrow this issue a little bit at the outset.

Ms. Giuffre concedes here that illegal or nonprescription use of drugs during the years that she was with defendant is admissible. However, any evidence pertaining to

any use of drugs, illegal or not, and alcohol from any periods

SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

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