52 H3VOGIU1 ih claiming she has damages of post-traumatic stress disorder, and 2 she is the one who is going to call to the stand her 3 psychiatrist to talk about that patient, and she is the one 4 that gave him evidence about these other acts to him and on 5 which he has relied in reaching his conclusions. It is 6 impossible for us to not be able to cross examine her expert 7 about preexisting PTSD caused by incidents and events unrelated 8 to Ms. Maxwell. 9 Motion in limine number 7, whether or not Ms. Giuffre 10 can be called a prostitute. Your Honor, no one in this case, 1a no counsel, nobody that I'm aware of involved with the 12 litigation has referred to Virginia Giuffre as a slut. That is 13 something that plaintiff's counsel has brought up, and you will 14 notice there is absolutely no cite in any record, in any 15 document referring to her as such. 16 What has come up, your Honor, are internet sites in de which Ms. Giuffre has been called all kinds of things that are 18 unrelated to Ms. Maxwell, that do not cite Ms. Maxwell. For 19 example, her friends gave interviews to the press in which they 20 described -- and this is attached as my Exhibit L -- described 21 Virginia Giuffre as "a money hungry sex kitten who enjoyed her 22 lavish lifestyle". We cannot talk about plaintiff's reputation 23 on the internet without talking about what is out there on the 24 internet. We cannot cross examine her or cross examine her 25 experts about what her reputation is if we can't ask about SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011355