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10 fd. 12 [3 14 15 16 i) 18 wife) 20 21 22 23 24 25 54 H3VOGIU1 remember the names of the foreign presidents that she was trafficked to, and these other famous people, because she was taking so many drugs she just can't remember. Obviously, your Honor, a witness' ability to perceive and recall and relate events that happened a long time ago that were affected by drug use need to be brought to light before the jury. The second issue, your Honor, relates to the use of prescription medication. What you heard plaintiff say is they would like to introduce evidence that she's taking prescription drugs properly, but they want to exclude us from cross examining her about that to see whether or not she was taking prescription drugs improperly. That's called cross examination, your Honor. Her use of prescription drugs has been well-documented in her doctor's records, and she has made false statements to her doctors regarding her need for prescription drugs. She's gone from one doctor to the next, telling one that she hasn't taken any Valium for years, and then the next on and then we have the records showing that that's just not true. She's told doctors that she was stressed out about a big litigation in New York, she told a doctor that in the year 2014, this lawsuit wasn't filed until 2015, so she's made statements to doctors that are inaccurate. Your Honor, her statements reflected in her medical SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011357