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using drugs now that may affect her memory, or if she's

inappropriately used drugs in the meantime, all of that would go to whether or not she truly has the emotional distress that she claims.

Motion in limine 9, plaintiff's criminal history. If

I understand plaintiff's argument, they do not want her to be

cross examined either under 608(b) or 405(b) with regard to a specific instance of dishonesty; that is, her theft from her employer.

There are legions of cases, your Honor, that find

theft to be a crime of dishonesty and admissible for proof of

character of dishonesty. Not only, your Honor, did she get charged by the

authorities in Florida with this crime of theft from her

employer, an arrest warrant was issued for her, that arrest

warrant was outstanding at the time she, quote/unquote, fled to

Thailand. That arrest warrant remained outstanding until the

year, I think 2009 or 2010, when it was quashed. Plaintiff

failed to come back to this country during that entire time. It got quashed because it had been such a long passage of time.

THE COURT: Who was the employer?

MS. MENNINGER: It was the Roadhouse Grill, your

Honor. It was a burger joint. And she was working at that Roadhouse Grill in March of 2002 during the period of time she

claims that she was a sex slave. She claimed that she was a

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

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