20 H3VOGIU1 ih interesting. Am I conjuring up something that's not going to 2 happen? No, your Honor. The defendant's own expert report 3 described our client as a prostitute. Your Honor has under 4 advisement the expert report from Dr. Esplin, and so I deposed 5 Dr. Esplin, and I said, "Are you sure that's an accurate term 6 in the context of this case? Because we have a child who id cannot consent to sexual activities." And he backed off 8 immediately and agreed that that was an inaccurate term for him 9 to use to describe my client, Ms. Giuffre. So even the 10 defense's own expert says the term "prostitute" is 1a inappropriate. 12 Your Honor has authority, of course, under Rule 611 to 13 manage the trial, to avoid undue harassment or embarrassment. 14 Also Rule 403 allows you to restrict things that would be 15 substantially prejudicial with no probative value, which is 16 exactly what we have here. So we would ask you simply to reign de in derogatory language, both from witnesses and opposing 18 counsel. 19 MS. SCHULTZ: Your Honor, I'll be addressing the next 20 several points in the omnibus motion, starting with number 8. 21 I think I can narrow this issue a little bit at the outset. 22 Ms. Giuffre concedes here that illegal or 23 nonprescription use of drugs during the years that she was with 24 defendant is admissible. However, any evidence pertaining to 25 any use of drugs, illegal or not, and alcohol from any periods SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011323