42 H3VOGIU1 ih T am about done at this point. 2 With regard to the remaining issues, you'll be happy 3 to hear that I think things can be sped up. We believe that 4 these issues should simply be, as your Honors I think was 5 suggesting a moment ago, deferred to trial. 6 Items 21, 22, 23, 24, 25, 26, 27, 28, and 29, those 7 were sort of just kind of protective measures. The one 8 footnote or caveat we would add to that, your Honor. We think 9 this gets punted to the trial, but we would simply ask your 10 Honor to direct defense counsel before they let the cat out of 1a the bag on any of these that there be a sidebar or hearing 12 outside of the jury just so that, you know, our motion in 13 limine doesn't become moot because they've already effectively 14 put it in front of the jury. 15 The one that's of particular concern is alleged bad 16 acts by the defense team. At various points, I think your if, Honor, unfortunately, has seen some, you know, frankly 18 aggressive language directed to the plaintiff's team here by 19 the defense team. We're prepared to respond to each and every 20 one of those allegations. We've tried not to get into the back 21 and forth because we think it's irrelevant. 22 But if there was to be some kind of an attack launched 23 on any of the members of the Boies Schiller Firm, of Brad 24 Edwards, myself, we would ask that we be given leave to address 25 that at sidebar, in-camera, or outside the presence of the jury SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011345