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of that nature shouldn't be able to come in. Because when we

talk about a character issue, what's at issue here is

reputation, and reputation to show the truthfulness of that

would not be able to be proven in that circumstance because we

don't have the other individuals there to make that statement,

so there's no substantive evidence on that point that would be coming in. And the third category is with respect to

Mr. Dershowitz, who is on the defendant's witness list for

trial, and we have a few points there to raise. I mean, one is

obviously that if that were allowed to come in, that causes the

trial to become a mini trial about whether or not he, for

example, was in the places where she says he was, his

calendars, his credit card receipts, his telephone records, all

of that. It gets into the issue, you know, obviously we have

another witness who says that they were in a similar

circumstance with respect to him. So it takes the trial away from whether or not the allegations relating to Maxwell are true or false and turns it into a trial about another individual who we have not made a claim against who comes in. There's also a problem with respect to that because he is also -- he has claimed attorney/client privilege as to his

conversations and his advice with respect to Epstein which

relates to the issues with Maxwell. So in other words, he

would be able to testify what he says he didn't do, but then

SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

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