Court discussion on admissibility of 'prostitute' term and domestic violence relevance in a defamation case

10 id. 12 13 14 L5 16 ne) 18 life) 20 21 22 23 24 25 82 H3VOGIU1 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 1 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 HOUSE_OVERSIGHT_011385