HOUSE_OVERSIGHT_011335

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what years and what birthdays were in play and exactly what Ms. Giuffre said about whether she was 15, 16, or 17. Fair enough. They can cross examine her about, 'Did you say 16 when you were, in fact, 17,' or whatever it is. We're not trying to exclude that.

The limited point that we're trying to address here is that they shouldn't say, 'Ah-hah, she was 17, therefore, she's fair game.'

Under Florida law that we've cited in our pleadings,

there is no possibility of a child under the age of 18

consenting to sexual activities of the nature that are at issue

here, and therefore, the defendant should be precluded from

making that kind of suggestion. And so that's item 15.

MS. SCHULTZ: Turning to item 16 in the omnibus

motion. Ms. Giuffre has moved the Court to exclude medical records. Here, I would actually like to direct the Court's attention to defendant's response. Defendant here does not

cite a single case where a court allowed admission of unrelated and irrelevant medical records into evidence at trial. Defendant's brief also doesn't show how any medical records are relevant here, and there are privacy issues at stake. In fact, defendant does not cite to a single case in

which a court allows any medical records into evidence.

In defendant's entire response she cites two cases

only. Neither of them have anything to do with what documents

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

HOUSE_OVERSIGHT_011335