18 H3VOGIU1 ih But prior sexual assault, all of which occurred while 2 Ms. Giuffre was a child, it's irrelevant to this action. It 3 doesn't come in under 401. It doesn't involve defendant. It 4 predates even meeting defendant. And these assaults do not 5 make it more or less probable that defendant defamed 6 Ms. Giuffre, and neither does it tend to prove or disprove that id defendant abused her. 8 These are also classic examples of evidence that 9 should be excluded under Rule 412. The Rape Shield Law forbids 10 evidence concerning these unrelated events involving 1a Ms. Giuffre. This rule should be strictly enforced, 12 particularly because these events happened when she was 14 and 13 15 years old. Rule 412(a) bars this evidence if it's offered 14 to prove that she engaged in any type of sexual behavior to 15 prove any type of disposition. 16 It should also be excluded under Rule 403. This is de extremely prejudicial, and because it is irrelevant, it would 18 only encourage the jury to view Ms. Giuffre, a married mother 19 in her 30s, as an immoral person for having sexual contact with 20 individuals as a child. 21 This should also be excluded under 608(a), which 22 limits interaction of evidence for specific instances of 23 conduct in order to attack the witness' character for 24 truthfulness. Now, I spoke about this at length yesterday. 25 Defendant tries to offer two particular things to say that, oh, SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011321