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Her reputation for truthfulness does not go to any bad acts she may have committed 20 years ago. And your Honor, even

criminal convictions are generally not admissible 10 years

after the fact. So presentation of this type of evidence is

simply nothing more than a smear campaign, which is prescribed

by multiple Federal Rules of Evidence.

And finally, any marginal probative value of these bad

acts as a child is vastly outweighed by the undue prejudice it would cause Ms. Giuffre before a jury.

Your Honor, now I'm turning to point number 12. We've

asked the Court to exclud vidence relating to the tax

compliance of Ms. Giuffre's not-for-profit Victims Refuse

Silence. Rule 401 is the first rule under which this should be

excluded. The alleged tax compliance of her not-for-profit

does not go to whether or not defendant defamed Ms. Giuffre and

does not go to whether or not defendant abused Ms. Giuffre.

It should also b xcluded under 403. It is highly

prejudicial. It would give the wrong impression to the jury that Ms. Giuffre's organization is not tax compliant, which, in fact, it is a fact that defendant does not acknowledge in her briefing.

Proving whether or not Ms. Giuffre's not-for-profit is

tax compliant would also be a mini trial and, frankly, a

sideshow to this case.

Furthermore, all of defendant's conclusions about

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

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