10
id.
12
13
14
L5
16
ne)
18
life)
20
21
22
23
24
25
64 H3VOGIU1
is the one who claims she had sex with various people at various places at various times, some when she was 17, some
when she was 18, some when she was 19, some in Florida, some in
England, some in New York, some in New Mexico. In all of those cases, except Florida, the age of consent is 17. I don't know what evidence plaintiff is going to
introduce about what sex she had, where, with whom, and her age
at that time because those sands have shifted dramatically during the course of this litigation. All I can say, your
Honor, is, if she tries to introduce evidence that she had sex
at a certain place and time and claimed that it was unlawful,
your Honor will be duty bound to instruct a jury on what is or
isn't lawful in a particular jurisdiction at a particular time in a particular place.
Your Honor, I would submit that motion in limine 16 regarding the medical records, again, is something that depends
dramatically on what plaintiff introduces during her case in
chief, but there are many statements, as I mentioned earlier, to her doctors which would be admitted as nonhearsay if offered against her as party admission.
There are many statements over the last 15 years that
relate to her mental condition, that relate to her medications.
Do I anticipate asking about her ferret bite? I do not. Do I
anticipate asking about the other things that are listed in her
motion in limine? I do not. But I do believe that there are a
SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
HOUSE_OVERSIGHT_011367