“We respectfully submit this letter, on behalf of Defendant Donald J. Trump, to request that the Court grant a mistrial based upon pervasive unfair and prejudicial rulings by the Court; or in the alternative, (1) correct the record for each and every instance in which the Court has mischaracterized the facts of this case to the Jury and (2) allow[ed] Defendant’s counsel to have greater latitude to cross-examine Plaintiff and her witnesses.”

“A mistrial should be granted because the Court has: (1) mischaracterized the evidence in favor of Plaintiff; (2) bolstered the testimony of Plaintiff; (3) allowed Plaintiff to testify that Defendant has two tables of lawyers at trial while prohibiting Defendant from fairly clarifying the record by showing that Plaintiff has a comparable amount of lawyers; (4) continuously sustained improper ‘argumentative’ objections of Plaintiff’s counsel as to questions using a well-established and accepted looping method of cross-examination; (5) permitted the testimony of the Natasha Stoynoff, without any voir dire of the witness, when it is clear that her testimony does not fit within the requirements of Fed. R. Evid. 413(d)(2&5) and should be excluded under Fed. R. Evid. 403; (6) alluded to the potential use of relevant United States statutes as a form of remedy beyond that which might be available from the Court based on Defendant’s son, Eric Trump, making completely truthful and non-prejudicial statements about Reid Hoffman’s financing of Plaintiff’s litigation; and (7) expressed distress with Defendant’s counsel for bringing to its attention that someone from plaintiff’s side violated the court’s protective order, which led to the world-wide publication of plaintiff’s mock jury results,” writes Trump lawyer Joe Tacopina in a letter to Judge Lewis Kaplan.