19 H3VOGIU1 ih she wasn't truthful about something, about being sexually 2 assaulted, but the documents themselves describe something 3 that's unequivocally sexual assault under Florida law, 4 something that is unequivocally nonconsensual. So that would 5 honestly be another mini trial and would take us far afield of 6 what facts are relevant to this case. 7 And again, any minor probative value that's past 8 sexual assault that Ms. Giuffre experienced as a child is 9 completely swallowed by the prejudicial effect on the jury. 10 MR. CASSELL: Your Honor, I think I'm the next one up. 1a For purposes of clarity, we're up to point number 7 in our 1 omnibus motion. 13 This one I think is just a very simple and 14 straightforward one. We move to exclude derogatory sexual 15 characterizations. This is a case that your Honor has been 16 framing this morning. It doesn't require use of a term from de defense counsel, for example, describing our client as a 18 prostitute or as a slut. We thought we would get agreement 19 when we saw the responsive papers from the defense, but as you 20 know, they objected in it's entirety to this motion, so we're 21 here asking that defense counsel not refer to our client as a 22 prostitute, not refer to her as a slut, and they also advise 23 their witnesses that such language would be inappropriate ina 24 federal trial dealing with a defamation issue. 25 On this particular point about prostitute, it's SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011322