61 H3VOGIU1 ih the community out trying to find her, and she was known as such 2 in her community. So to say somehow that we can't talk about 3 her reputation for truth telling, her reputation for honesty at 4 the time she was a child when she claims that she was the 5 victim of sex abuse, is not supported by the law. 6 Plaintiff also cites to Sack on Defamation, and I 7 believe the cite is 10, Section 5. And your Honor, I think 8 this helps clarify a lot of what our position is in this case. 9 Sack believes, as we do, that it is entirely 10 appropriate under 405(b) to question a plaintiff who has 1a alleged defamation, whose reputation is an issue about all 12 kinds of bad acts. They have said, just now, that there is 13 just no reason we should be allowed to ask about all these 14 other bad acts. 15 Sack cites, your Honor, to an Eleventh Circuit case, 16 Schafer vs. Time, Inc. In that case, your Honor, Sack says the uy Eleventh Circuit found the district court had been correct when 18 it ruled that the defendant, which allegedly accused the 19 plaintiff of being a traitor, "would be permitted to question 20 the plaintiff about a felony conviction, a possible violation 21 of his subsequent parole, convictions for driving under the 22 influence, an arrest for writing a bad check, failure to file 23 tax returns, failure to pay alimony and child support, and 24 evidence concerning plaintiff's efforts to change his name and 25 social security number." In other words, once you put your SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011364