HOUSE_OVERSIGHT_011363

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intersect with the entire story that plaintiff has told about being a sex slave in the years 1999 to 2002.

Also, your Honor, they go to damages because plaintiff

has claimed that she should be entitled to a certain amount of

damages, and her own experts have talked about her being a

troubled child. Again, this is something that they told their

psychiatric expert, and he relied on finding that she was a

troubled child, and then he's made inferences from there about

why she should be entitled to certain damages, and I think the school records are a fair game for cross examination of him. Motion in limine number 11, her bad childhood

behavior. Again, your Honor, this is exactly -- plaintiff went

in to see the psychiatrist, went in to see hers and our

independent medical examiner, and in both cases she described all of her, quote/unquote, bad childhood behavior. So it goes

to her damages, your Honor. They want to elicit what they want

to elicit and keep us from eliciting anything that would

contradict its

But putting your reputation and your character in

issue, as she has in this case, about the time when she was a

child is necessarily a part of our cross examination to explain

to a jury what her reputation at the time of the acts in question were. She was a truant, reported to the schools as a truant,

reported by her mother to the police, circulated with people in

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

HOUSE_OVERSIGHT_011363