reputation at issue, all of these specific instances going to

10 id. 12 13 14 L5 16 ne) 18 life) 20 21 22 23 24 25 62 H3VOGIU1 reputation at issue, all of these specific instances going to your honesty are fair game. In this case, we have asked plaintiff whether she filed tax returns. She said, "No." Tax fraud is not a private matter, as plaintiff contends, it is a crime. It is a crime of dishonesty. She likewise put into her complaint that her reputation was injured in her professional capacity as President of Victims Refuse Silence. We inquired whether Victims Refuse Silence was, indeed, a legitimate enterprise. We learned that they had not met their tax obligations and they had not been funded. That is, as your Honor knows, the subject of 702 motions, so I won't repeat it all here. I will say, however, that both of those issues, failure to file tax returns and tax fraud, are exactly the kinds of evidence permissible under 405(b) when you are attempting to establish the truth of your statement that plaintiff is a liar. Motion 14, evidence of being a victim of domestic violence. Your Honor, in this case, plaintiff claims $30 million in pain, suffering, and emotional distress. Plaintiff's expert, Dr. Kliman, testified that domestic violence by her husband is likely a cause of exacerbation of her PTSD. He also testified it was a very violent episode and more likely happened more than once. He also testified that SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011365