27 H3VOGIU1 ih Her reputation for truthfulness does not go to any bad 2 acts she may have committed 20 years ago. And your Honor, even 3 criminal convictions are generally not admissible 10 years 4 after the fact. So presentation of this type of evidence is 5 simply nothing more than a smear campaign, which is prescribed 6 by multiple Federal Rules of Evidence. 7 And finally, any marginal probative value of these bad 8 acts as a child is vastly outweighed by the undue prejudice it 9 would cause Ms. Giuffre before a jury. 10 Your Honor, now I'm turning to point number 12. We've 1a asked the Court to exclude evidence relating to the tax 12 compliance of Ms. Giuffre's not-for-profit Victims Refuse 13 Silence. Rule 401 is the first rule under which this should be 14 excluded. The alleged tax compliance of her not-for-profit 15 does not go to whether or not defendant defamed Ms. Giuffre and 16 does not go to whether or not defendant abused Ms. Giuffre. de It should also be excluded under 403. It is highly 18 prejudicial. It would give the wrong impression to the jury 19 that Ms. Giuffre's organization is not tax compliant, which, in 20 fact, it is a fact that defendant does not acknowledge in her 21 brLvering. 22 Proving whether or not Ms. Giuffre's not-for-profit is 23 tax compliant would also be a mini trial and, frankly, a 24 sideshow to this case. 25 Furthermore, all of defendant's conclusions about SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011330