28 H3VOGIU1 ih Ms. Giuffre's not-for-profit tax compliance are based on an 2 errant report by her purported expert, an expert who should be 3 excluded from testifying because his report lacked methodology 4 and he opined on topics far afield from his expertise. 5 Second, any allegations that her not-for-profit is not 6 tax compliant is prejudicial, misleading, confusing to the jury 7 because it has nothing to do with the claim at issue in this 8 case. 9 Your Honor, we asked for defendant's tax returns in 10 this case. If they go to truthfulness, as defendant argues, 1a they also go to defendant's truthfulness. At this point, we're 12 not going to get them until the first day of trial, so we will 13 not be able to effectively cross examine defendant on those tax 14 returns, and we won't be able to see until then if she's paid 15 taxes on all the money and gifts and in-kind payments from 16 Epstein that she's received or has kept that away from the de government. Unlike Ms. Giuffre's tax information, defendant's 18 tax information goes to our case in chief and is relevant 19 evidence. 20 On point number 13, we move to exclude evidence 21 relating to Ms. Giuffre's alleged tax compliance. Your Honor, 22 this is a defamation action where reputation is at issue. Tax 23 compliance does not go to a reputation, it is a private matter. 24 Second, there is no evidence in this case that any 25 government, either United States or Australia, believes that SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011331