60 H3VOGIU1 ih intersect with the entire story that plaintiff has told about 2 being a sex slave in the years 1999 to 2002. 3 Also, your Honor, they go to damages because plaintiff 4 has claimed that she should be entitled to a certain amount of 5 damages, and her own experts have talked about her being a 6 troubled child. Again, this is something that they told their 7 psychiatric expert, and he relied on finding that she was a 8 troubled child, and then he's made inferences from there about 9 why she should be entitled to certain damages, and I think the 10 school records are a fair game for cross examination of him. apa: Motion in limine number 11, her bad childhood 12 behavior. Again, your Honor, this is exactly -- plaintiff went 13 in to see the psychiatrist, went in to see hers and our 14 independent medical examiner, and in both cases she described 15 all of her, quote/unquote, bad childhood behavior. So it goes 16 to her damages, your Honor. They want to elicit what they want de to elicit and keep us from eliciting anything that would 18 Gonbradict ats 19 But putting your reputation and your character in 20 issue, as she has in this case, about the time when she was a 21 child is necessarily a part of our cross examination to explain 22 to a jury what her reputation at the time of the acts in 23 question were. 24 She was a truant, reported to the schools as a truant, 25 reported by her mother to the police, circulated with people in SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011363