62 H3VOGIU1 ih reputation at issue, all of these specific instances going to 2 your honesty are fair game. 3 In this case, we have asked plaintiff whether she 4 filed tax returns. She said, "No." Tax fraud is not a private 5 matter, as plaintiff contends, it is a crime. It is a crime of 6 dishonesty. 7 She likewise put into her complaint that her 8 reputation was injured in her professional capacity as 9 President of Victims Refuse Silence. We inquired whether 10 Victims Refuse Silence was, indeed, a legitimate enterprise. 1a We learned that they had not met their tax obligations and they 12 had not been funded. That is, as your Honor knows, the subject 13 of 702 motions, so I won't repeat it all here. 14 I will say, however, that both of those issues, 15 failure to file tax returns and tax fraud, are exactly the LG kinds of evidence permissible under 405(b) when you are de attempting to establish the truth of your statement that 18 plaintiff is a liar. 19 Motion 14, evidence of being a victim of domestic 20 violence. Your Honor, in this case, plaintiff claims 21 $30 million in pain, suffering, and emotional distress. 22 Plaintiff's expert, Dr. Kliman, testified that domestic 23 violence by her husband is likely a cause of exacerbation of 24 her PTSD. He also testified it was a very violent episode and 25 more likely happened more than once. He also testified that SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011365