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id.

ne)

life)

38 H3VOGIU1

might be admitted at trial. Both are orders resolving

discovery disputes under Rule 26.

Apart from her medical records, while defendant was

abusing her, such as when defendant took her to a hospital here in New York when she was only 17, and the psychological records related to Ms. Giuffre, which have been produced, which

incidentally are from 2011 and name defendant as her abuser, no

other medical records are relevant and should b xcluded under

Rule 401.

Ms. Giuffre is seeking damages for emotional distress from defamation. It does not open up the flood gates to every single medical issue she's ever had in her life. Ms. Giuffre

has produced records, everything from treatment for a ferret

bite to details of her giving birth. These are not relevant,

and we can have a ruling in advance of trial that these things should be excluded.

Defendant only seeks to use these records to confuse

the issues before the jury. Defendant offers no reason for

addressing the relevance of such documents one by one at trial,

and I think these can be safely excluded at this juncture.

MS. McCAWLEY: Your Honor, next is number 17, which we addressed in our papers, as well, about the prior settlement

agreement. You've heard about it in this case, and we have

said that that should not come into evidence.

I think they'd like to use it to propose that that

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

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