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But prior sexual assault, all of which occurred while

Ms. Giuffre was a child, it's irrelevant to this action. It doesn't come in under 401. It doesn't involve defendant. It predates even meeting defendant. And these assaults do not

make it more or less probable that defendant defamed

Ms. Giuffre, and neither does it tend to prove or disprove that defendant abused her.

These are also classic examples of evidence that

should b xcluded under Rule 412. The Rape Shield Law forbids

vidence concerning these unrelated events involving

Ms. Giuffre. This rule should be strictly enforced,

particularly because these events happened when she was 14 and

15 years old. Rule 412(a) bars this evidence if it's offered to prove that she engaged in any type of sexual behavior to

prove any type of disposition.

It should also b xcluded under Rule 403. This is

xtremely prejudicial, and because it is irrelevant, it would only encourage the jury to view Ms. Giuffre, a married mother in her 30s, as an immoral person for having sexual contact with individuals as a child.

This should also b xcluded under 608(a), which

limits interaction of evidence for specific instances of

conduct in order to attack the witness' character for

truthfulness. Now, I spoke about this at length yesterday.

Defendant tries to offer two particular things to say that, oh,

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

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