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from defense counsel about a blame the victim mindset that the jury would very well adopt once they heard that Ms. Giuffre's

staying with her husband is a victim of domestic violence. So

your Honor has in front of it, I think, essentially uncontested evidence, or at least uncontested argument of substantial

prejudicial effect that will exist that tips decisively in

favor of excluding this, particularly when they get to subjects

like criminal proceedings. We're going to then get into what

is the scope of the protective order if they live in Australia

and things like that. That's far afield from any effect on emotional distress damages.

Item 15 has to do the 17-year-old, 16-year-old,

15-year-old. I think we have agreement from both sides that

sex with a 17-year-old is unlawful under the age of consent

statute that exists in Florida, and we'll be asking either to

cover that through an expert witness or through a jury

instruction. But they say, oh, what if she's flown to New

Mexico? The age of consent there might be different. And this

is where I believe your Honor can take a close look at the expert witness on sex trafficking, the 702 motion is currently pending in front of you, Professor Terry Conan, who is at the Florida State Trafficking Institute, and we've offered him as an expert witness.

If you take a 17-year-old from Florida, fly her to New

Mexico for sexual purposes, it makes no difference what the age

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

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