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10 et, i 138 14 15 16 ey 18 a 20 21 aD. 23 24 25 Case 1:20-cr-00330-PAE Document 212-2 Filed 04/16/21 Page 18 of 30 App.-0821 ig GA4LMGIUC things that happened prior to her time with them. Your Honor, we do object to the production of that material. THE COURT: The flashback allegation. = MS. McCAWLEY: I think what she may be referring to, I have not heard that term used, I think what she may be referring to was the fact that this is a defamation claim and the person who defamed my client was also an abuser, we allege. So when she is defamed by the person who abused her and that abuser is calling her a liar, that caused her significant emotional distress. It's different than if some other individual that she had not had contact with called her a liar. When she is talking about a flashback, maybe that's what she is referring to, but we don't have the word flashback anywhere in our complaint. = THE COURT: No. I made that up. There will be no claim by the plaintiff that the defamation caused her distress by making her aware or as a result of the prior sexual abuse. MS. McCAWLEY: The sexual abuse by the defendants? THI! ll COURT: No. MS. McCAWLEY: Sexual abuse by others. THI Cl COURT: Yes. MS. McCAWLEY: No. Sexual abuse that relates to the Epstein period, yes. THE COURT: That I understand. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0500 DOJ-OGR-00003820