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13 H3VOGIU1

prejudicial effect« Obviously, this is going to be considered by the jury

to think she's a bad kid. They're not going to like

Ms. Giuffre, and they're going to hold it against her, not because it has some technical reputational aspect to it, but because it is something that shows she's a bad person. Under

403, the evidence should be excluded.

Let me give you a second illustration of reputational

points. They say, "Ah-ha, look. Ms. Giuffre went to

Dr. Kliman," and I believe your Honor referred to that as well.

And your Honor asked, I think, a very good question, and let me

see if I can answer that question.

You said, "Well, why did she disclose all this stuff

to Dr. Kliman?" Well, the answer is obvious, she was under

instructions from

and of course she

that happened. S

the doctor to tell everything

that happened,

told, to the best of her abilit

ome of the stuff is going

ty, everything

to turn out in a

court of law to be relevant, some of this stuff in a court of

law is going to turn out to be irrelevant. But that's not the

psychiatrist's job to say, 'No, no, no, don't talk about

becaus

illegal drug us the prejudicial effect outweighs the

probative value,' he just gets a full medical history. And

having collected all that information, you know, through

Dr. Kliman, or they also have Dr. Miller who did a similar sort

of thing. Now once you have all of this vast array of

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

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