Court filing argues against labeling [REDACTED - Survivor] as a prostitute and discusses PTSD expert testimony

10 id. 12 13 14 L5 16 ne) 18 life) 20 21 22 52 H3VOGIU1 claiming she has damages of post-traumatic stress disorder, and she is the one who is going to call to the stand her psychiatrist to talk about that patient, and she is the one that gave him evidence about these other acts to him and on which he has relied in reaching his conclusions. It is impossible for us to not be able to cross examine her expert about preexisting PTSD caused by incidents and events unrelated to Ms. Maxwell. Motion in limine number 7, whether or not Ms. Giuffre can be called a prostitute. Your Honor, no one in this case, no counsel, nobody that I'm aware of involved with the litigation has referred to [REDACTED] as a slut. That is something that plaintiff's counsel has brought up, and you will notice there is absolutely no cite in any record, in any document referring to her as such. What has come up, your Honor, are internet sites in which Ms. Giuffre has been called all kinds of things that are unrelated to Ms. Maxwell, that do not cite Ms. Maxwell. For xample, her friends gave interviews to the press in which they described -- and this is attached as my Exhibit L -- described [REDACTED] as "a money hungry sex kitten who enjoyed her 23 24 25 lavish lifestyle". We cannot talk about plaintiff's reputation on the internet without talking about what is out there on the internet. We cannot cross examine her or cross examine her experts about what her reputation is if we can't ask about SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011355