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10 fd. 12 [3 14 15 16 i) 18 wife) 20 21 22 23 24 25 53 H3VOGIU1 these other things that are circulating about her that have nothing to do with Ms. Maxwell. Mr. Cassell referred to our expert Phillip Esplin, Dr. Esplin, and saying that he agreed not to refer to Virginia Roberts as a prostitute. Your Honor, that came up in the context of a cross examination in which he said he has no idea whether any of her claims are credible or not. He does not believe it's within the province of the psychiatrist to be making credibility determinations. So he was not in any way suggesting, in fact he testified for hours to the contrary, that he knows whether her claims of being a prostitute are true or not true, and he agreed not to talk about. The only context in which I think this comes up, your Honor, are witnesses or people on the internet who have made disparaging remarks about the plaintiff that have to be the subject of her reputation and her request for damages that she says are related to Ms. Maxwell. Plaintiff's drug abuse, motion in limine number 8. They have conceded, as they must, that the period of time about which Ms. Giuffre is testifying is fair game for her discussion of all of her illegal drug use. And it wasn't just prescription drugs, she has testified that she was on a number of different drugs at the time, and that because of those drugs, her memory of events from 2000 are, quote/unquote, foggy. And she says that's one of the reasons she can't SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011356