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id.
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L5
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ne)
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life)
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66 H3VOGIU1
Plaintiff was a witness in that case. She was deposed
in that case. She testified under oath in that case, represented by the same counsel that she has here. Her testimony in that case is admissible.
She participated in that case, your Honor, from March
of 2015 or so until it settled in or around April of 2016, and
she reported to her doctors that it was causing her a
significant amount of stress. In fact, shortly before she was deposed in that case she went to a doctor and requested that she get more Valium to help her handle her upcoming deposition. Dr. Miller, our psychiatrist, found that her participation in that lawsuit as a witness caused her
significant stress and explained many of her complained of
symptoms, and he said that they wer xacerbated by her participation in that litigation.
Third, evidence regarding that lawsuit goes to her
reputational damages. Again, your Honor, I refer to the federal evidence treatise relied on by plaintiff. In defamation cases, defendants can also prove other liables and
rumors about the claimant are circulating, at least if they are
widespread, to demonstrate it is not what the defendant said
about the plaintiff that caused her reputation to suffer but
what others said. Your Honor has read the 702 pleadings. Plaintiff's
experts have pulled off the internet all kinds of stories that
SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
HOUSE_OVERSIGHT_011369