HOUSE_OVERSIGHT_011326

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which has been produced in discovery and submitted to this Court, shows that it was defendant who sent her to Thailand,

sending her with handwritten instructions about what to do when

she gets there. So if this unsupported argument that defendant

left the United States because of some accusation of a tip jar

is to be believed, then that makes defendant an accessory after the fact and implicates her in the wrongdoing.

So I don't -- basically, there's just -- this argument is also undone by the fact that later, Ms. Giuffre comes back to the United States to live here. She's not fleeing accusations, she was fleeing defendant. If she were worried

about criminal liability in the United States, she wouldn't

come back to live here.

But the overall point is any marginal probative value

from these allegations, which I don't think there is any, but

it's far vastly outweighed by the prejudice it would cause

Ms. Giuffre and should b xcluded under all those rules.

Moving now to point 10. Ms. Giuffre has requested

that the Court exclude any evidence regarding special

schooling, truancy, and juvenile delinquencies. For this argument, your Honor, I request that I approach the bench and

give you a few documents upon which these arguments are based.

I have four documents that I'm handing up.

I have to get a little bit into the weeds here, so

please bear with me. In this case, Ms. Giuffre -- well, school

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

HOUSE_OVERSIGHT_011326