82 H3VOGIU1 ih concluded that was an inappropriate word. 2 The only -- let me be clear. If there's some document 3 that has the word "prostitute" in it, we're not suggesting that 4 then it would be -- if that document is in evidence and the use 5 of that word is appropriate and admissible and relevant, we're 6 not saying that that has to be redacted. But the only example 7 they gave is there's some comments in some internet chat room 8 somewhere, we're not sure exactly how they're going to 9 authenticate those, there's no evidence Ms. Giuffre has heard 10 of those, so as you say, we can take that up at the time. But apa: we would ask that defense counsel be instructed, and their 12 witnesses be instructed, not to use that term unless it appears 13 in a particular document. 14 With regard to item 14, this is the domestic violence 15 issue. And they say, look, it has relevance because it shows 16 an alternative cause of emotional distress damages. de Our position is primarily based on Rule 403. We 18 conceded, I think, that there's some arguable chain of 19 relevance that perhaps could be teased out here, but let's 20 understand, this domestic violence incident took place in 21 March, 2015, and the statement at issue that caused the 22 worldwide reputational damages was launched in January of 2015. 23 So the relevance here is marginal, and ultimately the 24 question your Honor has to, of course, sort out is the 25 prejudicial effect. There wasn't any response that I heard SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011385