HOUSE_OVERSIGHT_011328

id.

ne)

life)

25 H3VOGIU1

you are inclined to do them, you could not place them into

evidence fairly without testimony regarding what all these

codes on the transcripts mean, or at a bare minimum, the

introduction of evidence and instruction that makes explicit what all the codes on the transcripts mean.

Defendant either failed to do her due diligence on

this and looked at what the codes are before advancing this

argument, but either way, it's not a good faith argument because, as you can see in the document I handed up, these

codes and their meanings were detailed at length in

Ms. Giuffre's opposition to the motion for summary judgment, and I would ask the Court to refer to the facts at page 32 of the statement of facts.

So what the records actually show is rampant truancy, years of absence from school while defendant was abusing her, which show ample opportunity for abuse, and are, in fact, in accord with the flight records, which have also been produced

in this case, which place Ms. Giuffre on 23 flights with

defendant aboard Jeffrey Epstein's private plane. So as these records actually show truancy, failed grades, failure to complete courses, these should be excluded

under all the rules I cited earlier, or at a bare minimum,

instruction to the jury about what the codes mean and detailing how many days of school Ms. Giuffre actually attended, a number

that is conspicuously absent from defendant's brief.

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

HOUSE_OVERSIGHT_011328