HOUSE_OVERSIGHT_011327

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records have been part of discovery. They show a history of rampant truancy and failed courses. This constitutes prior bad acts which ar xcluded under Rule 404, particularly since

these bad acts do not go to truthfulness, so they're also

xcluded under Rule 608.

They should also b xcluded because their prejudic that it would cause Ms. Giuffre greatly outweighs any probative

value and should b xcluded under 403.

There's a huge remoteness issue here, your Honor.

These truancies and juvenile delinquencies took place many years ago when she was a minor. There's a lot of case law on

this that is in Mr. Giuffre's brief on page 22 to 23. But what

you should be aware of, your Honor, is that a close examination

of records, looking up what the number codes on these

transcripts actually mean, it shows the opposite of the

argument that defendant advances in her response brief; that she was in school, and therefore, not abused by her client.

To the contrary, the records show that she was not in school over half the time she was supposed to be and did not

complete her courses. These transcripts are not

self-explanatory. Indeed, looking at the face of them, it

seems like she was enrolled and attending school, but much of

the information in these records are number codes used by the

Palm Beach County School District. These school records could

not be placed into evidence for all the reasons above, but if

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

HOUSE_OVERSIGHT_011327