63 H3VOGIU1 ih she needs additional marital and sexual counseling based on her 2 disinterest in sex, which she claims is caused by the 3 defamatory statement. 4 Our expert, your Honor, likewise found that the far 5 more likely cause of any dysfunction in her marriage which 6 arose at the time of the domestic violence incident and was 7 more likely the cause of any PTSD pain, suffering, or emotional 8 distress that she was experiencing. 9 That domestic violence incident happened in early 10 March, 2015, a couple of months after the allegedly defamatory 1a statement, and seven months before plaintiff brought this 1 lawsuit. 13 The criminal proceedings against her husband also are 14 relevant to her damages, apart from Dr. Kliman's testimony. 15 Her husband was ordered to live away from their home, leaving 16 her to care for her three children alone. He then stopped de participating in the court-ordered domestic violence 18 counseling, and he fled the country with an active arrest 19 warrant that remains outstanding to this date from Colorado. 20 All of these alternative sources of emotional distress 21 for plaintiff should be admitted, as her expert, Dr. Kliman, 22 has testified, in as far as they impact supposed pain, 23 suffering, loss of enjoyment of life. 24 Motion in limine number 15, any testimony that sex 25 with a 17-year-old girl is, quote/unquote, lawful. Plaintiff SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011366