10
id.
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L5
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ne)
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life)
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52 H3VOGIU1
claiming she has damages of post-traumatic stress disorder, and
she is the one who is going to call to the stand her
psychiatrist to talk about that patient, and she is the one
that gave him evidence about these other acts to him and on
which he has relied in reaching his conclusions. It is
impossible for us to not be able to cross examine her expert about preexisting PTSD caused by incidents and events unrelated to Ms. Maxwell.
Motion in limine number 7, whether or not Ms. Giuffre
can be called a prostitute. Your Honor, no one in this case,
no counsel, nobody that I'm aware of involved with the litigation has referred to Virginia Giuffre as a slut. That is something that plaintiff's counsel has brought up, and you will
notice there is absolutely no cite in any record, in any
document referring to her as such.
What has come up, your Honor, are internet sites in
which Ms. Giuffre has been called all kinds of things that are
unrelated to Ms. Maxwell, that do not cite Ms. Maxwell. For
xample, her friends gave interviews to the press in which they
described -- and this is attached as my Exhibit L -- described
Virginia Giuffre as "a money hungry sex kitten who enjoyed her
23
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lavish lifestyle". We cannot talk about plaintiff's reputation
on the internet without talking about what is out there on the internet. We cannot cross examine her or cross examine her
experts about what her reputation is if we can't ask about
SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
HOUSE_OVERSIGHT_011355