or at least uncontested argument of substantial
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this domestic violence incident took place in
there's no evidence Ms. Giuffre has heard
we're not sure exactly how they're going to
it seems like we're in agreement that that should be a
I would also reiterate that her reputation
as much as defendant seems to think she is. They don't
none of this information comes in under the Federal
but the prejudice greatly outweighs whatever probative
something that's in the news a lot these days. So
I would also submit that the prescription
and a sentence fragment in the middle of a medical
and that's why we proposed this motion in limine to you
that's subject for cross examination of him
he's the same expert that was in the Anders case who
she knows -- while during her deposition she
I called Jeffrey and told him I've fallen madly in love
and we had to be very careful in who we picked
you've seen all the expert depositions in this
very clear from the documents they've produced