26 H3VOGIU1 ih Turning next to plaintiff's motion in limine number 2 11. This is a related issue. We ask that the Court exclude 3 characterizations of Ms. Giuffre's bad behavior during her 4 childhood, including characterizations of her as a bad child or 5 a runaway. Defendant's response to this tries to conflate two 6 separate things; prior bad acts, an assault on her character on 7 one hand, with a reputation for truthfulness of another. 8 Prior bad acts she may have committed as a child, like 9 running away, is inadmissible and a defamation action where the 10 damages relate to her reputation. That she ran away from home 1a or was an ill-behaved child does not go to truthfulness. 12 These events also do not go to her reputation. Her 13 reputation for truthfulness as an adult prior to the defamation 14 is the only reputation that's at issue in this case. 15 Defendant's defamatory statements damaged Ms. Giuffre's 16 reputation when she was in her 30s. This does not open the de door into evidence of Ms. Giuffre's generalized character, 18 particularly one from a troubled childhood. Occurrences, such 19 as running away from her home when she was a child, are simply 20 prior bad acts under Rule 404 that should be excluded. They 21 should also be excluded under Rule 405 because this is 22 introduction of evidence to try to show her character. And 23 Rule 608(a) also limits evidence and testimony about a witness' 24 reputation for having a character for truthfulness or 25 untruthfulness, it doesn't come in under that rule. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011329