HOUSE_OVERSIGHT_011365

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reputation at issue, all of these specific instances going to your honesty are fair game.

In this case, we have asked plaintiff whether she

filed tax returns. She said, "No." Tax fraud is not a private matter, as plaintiff contends, it is a crime. It is a crime of dishonesty.

She likewise put into her complaint that her

reputation was injured in her professional capacity as

President of Victims Refuse Silence. We inquired whether

Victims Refuse Silence was, indeed, a legitimate enterprise.

We learned that they had not met their tax obligations and they

had not been funded. That is, as your Honor knows, the subject

of 702 motions, so I won't repeat it all here.

I will say, however, that both of those issues,

failure to file tax returns and tax fraud, are exactly the

kinds of evidence permissible under 405(b) when you are

attempting to establish the truth of your statement that

plaintiff is a liar.

Motion 14, evidence of being a victim of domestic violence. Your Honor, in this case, plaintiff claims $30 million in pain, suffering, and emotional distress. Plaintiff's expert, Dr. Kliman, testified that domestic violence by her husband is likely a cause of exacerbation of her PTSD. He also testified it was a very violent episode and

more likely happened more than once. He also testified that

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

HOUSE_OVERSIGHT_011365