Gene....in your hypothetical I'm assuming that the "ex" is going to be used to testify in regards to past abuse. If so, that's character evidence and is inadmissible by the prosecutor. If a defense attorney REALLY screws up and "opens the door" he might be able to get it in later. If so, blame the hypothetical lawyer.

So, apples to apples, personnel file open during trial?

�Out of every one hundred men, ten shouldn't even be there, eighty are just targets, nine are the real fighters, and we are lucky to have them, for they make the battle. Ah, but the one, one is a warrior, and he will bring the others back.�