HOUSE_OVERSIGHT_011345

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IT am about done at this point.

With regard to the remaining issues, you'll be happy

to hear that I think things can be sped up. We believe that

these issues should simply be, as your Honors I think was suggesting a moment ago, deferred to trial. Items 21, 22, 23, 24, 25, 26, 27, 28, and 29, those

were sort of just kind of protective measures. The one

footnote or caveat we would add to that, your Honor. We think

this gets punted to the trial, but we would simply ask your

Honor to direct defense counsel before they let the cat out of

the bag on any of these that there be a sidebar or hearing

outside of the jury just so that, you know, our motion in

limine doesn't become moot because they've already effectively put it in front of the jury.

The one that's of particular concern is alleged bad

acts by the defense team. At various points, I think your Honor, unfortunately, has seen some, you know, frankly aggressive language directed to the plaintiff's team here by

the defense team. We're prepared to respond to each and every

one of those allegations. We've tried not to get into the back

and forth because we think it's irrelevant.

But if there was to be some kind of an attack launched

on any of the members of the Boies Schiller Firm, of Brad

Edwards, myself, we would ask that we be given leave to address

that at sidebar, in-camera, or outside the presence of the jury

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

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