interesting. Am I conjuring up something that's not going to

10 id. 12 13 14 L5 16 ne) 18 life) 20 21 22 23 24 25 20 H3VOGIU1 interesting. Am I conjuring up something that's not going to happen? No, your Honor. The defendant's own expert report described our client as a prostitute. Your Honor has under advisement th xpert report from Dr. Esplin, and so I deposed Dr. Esplin, and I said, "Are you sure that's an accurate term in the context of this case? Because we have a child who cannot consent to sexual activities." And he backed off immediately and agreed that that was an inaccurate term for him to use to describe my client, Ms. Giuffre. So even the defense's own expert says the term "prostitute" is inappropriate. Your Honor has authority, of course, under Rule 611 to manage the trial, to avoid undue harassment or embarrassment. Also Rule 403 allows you to restrict things that would be substantially prejudicial with no probative value, which is exactly what we have here. So we would ask you simply to reign in derogatory language, both from witnesses and opposing counsel. MS. SCHULTZ: Your Honor, I'll be addressing the next several points in the omnibus motion, starting with number 8. I think I can narrow this issue a little bit at the outset. Ms. Giuffre concedes here that illegal or nonprescription use of drugs during the years that she was with defendant is admissible. However, any evidence pertaining to any use of drugs, illegal or not, and alcohol from any periods SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011323