intersect with the entire story that plaintiff has told about
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intersect with the entire story that plaintiff has told about
being a sex slave in the years 1999 to 2002.
Also, your Honor, they go to damages because plaintiff
has claimed that she should be entitled to a certain amount of
damages, and her own experts have talked about her being a
troubled child. Again, this is something that they told their
psychiatric expert, and he relied on finding that she was a
troubled child, and then he's made inferences from there about
why she should be entitled to certain damages, and I think the
school records are a fair game for cross examination of him.
Motion in limine number 11, her bad childhood
behavior. Again, your Honor, this is exactly -- plaintiff went
in to see the psychiatrist, went in to see hers and our
independent medical examiner, and in both cases she described
all of her, quote/unquote, bad childhood behavior. So it goes
to her damages, your Honor. They want to elicit what they want
to elicit and keep us from eliciting anything that would
contradict its
But putting your reputation and your character in
issue, as she has in this case, about the time when she was a
child is necessarily a part of our cross examination to explain
to a jury what her reputation at the time of the acts in
question were.
She was a truant, reported to the schools as a truant,
reported by her mother to the police, circulated with people in
SOUTHERN DISTRICT REPORTERS, P.C.
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HOUSE_OVERSIGHT_011363
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