HOUSE_OVERSIGHT_011332

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she is noncompliant with her taxes. Defendant's purported expert's evaluation of this is wholly flawed, as explained in Ms. Giuffre's motion in limine on the same.

Similarly, Ms. Giuffre's taxes are wholly irrelevant

to this case. Even actions brought by the government, your

Honor, where the cause of action is centered on nontax

complianc xclud vidence of prior tax noncompliance when it

takes the case too far afield of the issue being tried.

Courts also exclude this evidence under 403 if there's

no substantial nexus between the alleged tax noncompliance and

the matter at hand. Here, defendant fails to show any type of

substantial nexus to this defamation claim. None whatsoever. Additionally, resolving Ms. Giuffre's tax compliance, this is a point that's in dispute among the parties, and

resolving such an issue would also involve another mini trial

where Ms. Giuffre would put on evidence of her tax compliance and, at the end of that mini trial, the jury would have no more information whether or not defendant defamed Ms. Giuffre when she called her a liar about being sexually abused. Trying to make this an issue, this is simply a device for putting the

settlement agreement and the amount between Ms. Giuffre and

Jeffrey Epstein into evidence.

As has been briefed extensively, such a settlement

payment is tax exempt under the United States law, but that's

all this is, it's a device to try to get an improper admission

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

HOUSE_OVERSIGHT_011332