HOUSE_OVERSIGHT_011385

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concluded that was an inappropriate word.

The only let me be clear. If there's some document

that has the word "prostitute" in it, we're not suggesting that

then it would be -—- if that document is in evidence and the use

of that word is appropriate and admissible and relevant, we're

not saying that that has to be redacted. But the only example

they gave is there's some comments in some internet chat room

somewhere, we're not sure exactly how they're going to

authenticate those, there's no evidence Ms. Giuffre has heard

of those, so as you say, we can take that up at the time. But

we would ask that defense counsel be instructed, and their

witnesses be instructed, not to use that term unless it appears in a particular document. With regard to item 14, this is the domestic violence

issue. And they say, look, it has relevance because it shows

an alternative cause of emotional distress damages.

Our position is primarily based on Rule 403. We conceded, I think, that there's some arguable chain of relevance that perhaps could be teased out here, but let's

understand, this domestic violence incident took place in

March, 2015, and the statement at issue that caused the

worldwide reputational damages was launched in January of 2015.

So the relevance here is marginal, and ultimately the question your Honor has to, of course, sort out is the

prejudicial effect. There wasn't any response that I heard

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

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