66 H3VOGIU1 ih Plaintiff was a witness in that case. She was deposed 2 in that case. She testified under oath in that case, 3 represented by the same counsel that she has here. Her 4 testimony in that case is admissible. 5 She participated in that case, your Honor, from March 6 of 2015 or so until it settled in or around April of 2016, and 7 she reported to her doctors that it was causing her a 8 significant amount of stress. In fact, shortly before she was 9 deposed in that case she went to a doctor and requested that 10 she get more Valium to help her handle her upcoming deposition. 1a Dr. Miller, our psychiatrist, found that her 12 participation in that lawsuit as a witness caused her 13 significant stress and explained many of her complained of 14 symptoms, and he said that they were exacerbated by her 15 participation in that litigation. 16 Third, evidence regarding that lawsuit goes to her de reputational damages. Again, your Honor, I refer to the 18 federal evidence treatise relied on by plaintiff. In 19 defamation cases, defendants can also prove other liables and 20 rumors about the claimant are circulating, at least if they are 21 widespread, to demonstrate it is not what the defendant said 22 about the plaintiff that caused her reputation to suffer but 23 what others said. 24 Your Honor has read the 702 pleadings. Plaintiff's 25 experts have pulled off the internet all kinds of stories that SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011369