is the one who claims she had sex with various people at

10 id. 12 13 14 L5 16 ne) 18 life) 20 21 22 23 24 25 64 H3VOGIU1 is the one who claims she had sex with various people at various places at various times, some when she was 17, some when she was 18, some when she was 19, some in Florida, some in England, some in New York, some in New Mexico. In all of those cases, except Florida, the age of consent is 17. I don't know what evidence plaintiff is going to introduce about what sex she had, where, with whom, and her age at that time because those sands have shifted dramatically during the course of this litigation. All I can say, your Honor, is, if she tries to introduce evidence that she had sex at a certain place and time and claimed that it was unlawful, your Honor will be duty bound to instruct a jury on what is or isn't lawful in a particular jurisdiction at a particular time in a particular place. Your Honor, I would submit that motion in limine 16 regarding the medical records, again, is something that depends dramatically on what plaintiff introduces during her case in chief, but there are many statements, as I mentioned earlier, to her doctors which would be admitted as nonhearsay if offered against her as party admission. There are many statements over the last 15 years that relate to her mental condition, that relate to her medications. Do I anticipate asking about her ferret bite? I do not. Do I anticipate asking about the other things that are listed in her motion in limine? I do not. But I do believe that there are a SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011367