HOUSE_OVERSIGHT_011377

id.

ne)

life)

74 H3VOGIU1

information, then the lawyers present arguments to your Honor and say, 'Wait a minute. Some of the things that are in the

report aren't relevant to the case and, in fact, are going to

be highly prejudicial for the jury." That's why we're here

this morning asking for some of those things to be excluded.

For example, there are some references I won't

belabor the point -- but the references that we're making to

some of the illegal drug usage and so forth, that's not something we're trying to deploy affirmatively. The good

doctor simply listed all of the information that had been

recited as part of his report so that the lawyers and the judge can now make a determination.

And the fact that Ms. Giuffre told Dr. Kliman ina

confidential psychiatric examination certain things about drug use can't possibly go to her reputation because no one was there who was assessing what kinds of things might be going on. A similar point can be made about tax fraud. We're told, "Well, your Honor, tax fraud goes to her reputation." I suppose that goes to her reputation with some IRS agent who is

looking at a return, but it can't possibly go to a general

reputation that is at issue in this case.

And once again, the cases that we cite in our briefs I

think make this point clear, there is a vast risk of

prejudicial effect to Ms. Giuffre because the jury is going to

think, oh, she's a tax cheat, and they're going to hold that

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

HOUSE_OVERSIGHT_011377