HOUSE_OVERSIGHT_011325

id.

ne)

life)

22 H3VOGIU1

probative value is outweighed by the prejudice. Again, this is only seeking damages based on defendant's defamation.

I'm going to move on to point number 9. Ms. Giuffre seeks to exclude any alleged criminal history from coming into

this case. And the Federal Rules of Evidence bar the

introduction of this evidence, full stop. As the Court is aware, the only way criminal history

could come into evidence is through Rule 609, but that rule

itself bars this evidence because, one, there's no conviction, and two, the alleged crime does not go to truthfulness. Of the two parties, your Honor, Ms. Giuffre is the

only one who has not been convicted of a crime here, this is

merely an alleged prior bad act which is excluded under Rul

404.

And this alleged act, which Ms. Giuffre denies, does

not go to truthfulness, and that's an important point here. An accusation of a crime with no conviction does not go to truthfulness, especially a crime like this, which specifically

is defendant says she stole from a tip jar when she was a

teenager. Knowing that this type of evidence is excluded,

counsel for defendant has put forth an unsupported argument

that Ms. Giuffre left the United States because of allegations

that she stole from a tip jar. That is, of course, false. She

left the United States to get away from defendant's abuse.

And moreover, the documentary evidence in this case,

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

HOUSE_OVERSIGHT_011325