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id.

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84 H3VOGIU1

of consent is at that point because you have a federal sex trafficking crime that has been committed. The same thing is true if you fly a 17-year-old into

London, or if you fly her into New York. All of those are sex

trafficking crimes, and Professor Conan is prepared to explain both that particular aspect, I would describe it as a mixed question of fact and law, and also some of the psychological techniques that are used to create the -- I think he refers to

them as the invisible chains of sex traffickers.

So w ither have a crime in Florida, because she's

under the age of consent, or we have a federal or, in all

likelihood, state trafficking offense if she's flown to another

states

Which regard to item 18, the Cassell and Edwards litigation, I think your Honor asked som xcellent questions on that.

We were told that there are five reasons why Ms. Giuffre's connection to that case has some relevance. The

first argument, I guess, is their strongest argument, was that,

well, she was a witness in that case. But, of course, that was

a confidential deposition, so it couldn't have anything to do

with reputational damages or something else.

Let me be clear. Ms. Giuffre made statements when she was deposed, and if they say, ah-hah, you've said X from the

witness stand, but last year when you were deposed you said not

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

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