29 H3VOGIU1 ih she is noncompliant with her taxes. Defendant's purported 2 expert's evaluation of this is wholly flawed, as explained in 3 Ms. Giuffre's motion in limine on the same. 4 Similarly, Ms. Giuffre's taxes are wholly irrelevant 5 to this case. Even actions brought by the government, your 6 Honor, where the cause of action is centered on nontax 7 compliance exclude evidence of prior tax noncompliance when it 8 takes the case too far afield of the issue being tried. 9 Courts also exclude this evidence under 403 if there's 10 no substantial nexus between the alleged tax noncompliance and 1a the matter at hand. Here, defendant fails to show any type of 1 substantial nexus to this defamation claim. None whatsoever. 13 Additionally, resolving Ms. Giuffre's tax compliance, 14 this is a point that's in dispute among the parties, and 15 resolving such an issue would also involve another mini trial 16 where Ms. Giuffre would put on evidence of her tax compliance de and, at the end of that mini trial, the jury would have no more 18 information whether or not defendant defamed Ms. Giuffre when 19 she called her a liar about being sexually abused. Trying to 20 make this an issue, this is simply a device for putting the 21 settlement agreement and the amount between Ms. Giuffre and 22 Jeffrey Epstein into evidence. 23 As has been briefed extensively, such a settlement 24 payment is tax exempt under the United States law, but that's 25 all this is, it's a device to try to get an improper admission SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011332