53 H3VOGIU1 ih these other things that are circulating about her that have 2 nothing to do with Ms. Maxwell. 3 Mr. Cassell referred to our expert Phillip Esplin, 4 Dr. Esplin, and saying that he agreed not to refer to Virginia 5 Roberts as a prostitute. Your Honor, that came up in the 6 context of a cross examination in which he said he has no idea 7 whether any of her claims are credible or not. He does not 8 believe it's within the province of the psychiatrist to be 9 making credibility determinations. So he was not in any way 10 suggesting, in fact he testified for hours to the contrary, 1a that he knows whether her claims of being a prostitute are true 12 or not true, and he agreed not to talk about. 13 The only context in which I think this comes up, your 14 Honor, are witnesses or people on the internet who have made 15 disparaging remarks about the plaintiff that have to be the 16 subject of her reputation and her request for damages that she de says are related to Ms. Maxwell. 18 Plaintiff's drug abuse, motion in limine number 8. 19 They have conceded, as they must, that the period of time about 20 which Ms. Giuffre is testifying is fair game for her discussion 21 of all of her illegal drug use. And it wasn't just 22 prescription drugs, she has testified that she was on a number 23 of different drugs at the time, and that because of those 24 drugs, her memory of events from 2000 are, quote/unquote, 25 foggy. And she says that's one of the reasons she can't SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011356