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id.

ne)

life)

30) H3VOGIU1

of a settlement amount between Ms. Giuffre and Jeffrey Epstein.

Accordingly, this should be completely excluded because any

marginal probative value this has on the claims is greatly

outweighed by the prejudice to Ms. Giuffre. IT am not up for the next one, so I'm going to take a

break. Thank you.

MR. CASSELL: Again, your Honor, I'm up to number 14 now, the issue of Ms. Giuffre's being a victim of domestic violence. This is not relevant or minimally relevant. It's Ms. Giuffre's burden, of course, to show the emotional distress

damages that she suffered as a result of Ms. Maxwell's

defamatory statement, and the jury can agree or disagree with whether she's carried her burden of proof.

If we understand the defendant's argument correctly,

they say, well, this would have been a distressing event in your life and, therefore, we should be free to introduce it in front of the jury. Of course, that argument would allow, if accepted, essentially any bad thing that's happened in any plaintiff's life to be introduced if they seek emotional distress damages because, my goodness, this event here or there

had some emotionally distressing effect on you. So it has

minimal to low probative value, and the prejudice is very substantial. Your Honor, obviously, has a great deal of experience

and are well aware of the domestic violence, blame the victim

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

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