43 H3VOGIU1 ih so that we can keep the fact that we have done something bad 2 that should then be held against our client away from the jury. 3 But all these remaining things we are in agreement, I 4 think with the suggestion you were perhaps making a moment ago, 5 we can deal with these issues at trial. 6 That's our omnibus motion in limine, your Honor. 7 THE COURT: Thank you. 8 MS. MENNINGER: The omnibus motion reads like a list 9 of everything plaintiff has lied about or anything that would 10 undercut her claim for damages. 1a Plaintiff quoted Passim in her reply brief from a 12 particular federal evidence treatise, and I would like to tell 13 the Court, she left out the most important parts, and that is 14 the ones that relate to 405(b). 15 As that treatise reads, "Character is an element of a 16 defense in a defamation case if the defending party claims that de the statements in question are true and seeks to prove that the 18 plaintiff has the character ascribed to her or to reduce 19 damages by showing that her reputation is so bad the statement 20 did no harm. 21 "In such cases, pursuant to Rule 405, all forms of 22 character evidence are admissible wherever relevant, including 23 opinion, reputation, and specific instances of conduct." 24 As your Honor found in our motion to dismiss ruling of 25 February 29th of last year, "Though defendant never called SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011346