32 H3VOGIU1 ih what years and what birthdays were in play and exactly what 2 Ms. Giuffre said about whether she was 15, 16, or 17. Fair 3 enough. They can cross examine her about, 'Did you say 16 when 4 you were, in fact, 17,' or whatever it is. We're not trying to 5 exclude that. 6 The limited point that we're trying to address here is 7 that they shouldn't say, 'Ah-hah, she was 17, therefore, she's 8 fair game.' 9 Under Florida law that we've cited in our pleadings, 10 there is no possibility of a child under the age of 18 1a consenting to sexual activities of the nature that are at issue 12 here, and therefore, the defendant should be precluded from 13 making that kind of suggestion. And so that's item 15. 14 MS. SCHULTZ: Turning to item 16 in the omnibus 15 motion. Ms. Giuffre has moved the Court to exclude medical 16 records. Here, I would actually like to direct the Court's de attention to defendant's response. Defendant here does not 18 cite a single case where a court allowed admission of unrelated 19 and irrelevant medical records into evidence at trial. 20 Defendant's brief also doesn't show how any medical 21 records are relevant here, and there are privacy issues at 22 stake. In fact, defendant does not cite to a single case in 23 which a court allows any medical records into evidence. 24 In defendant's entire response she cites two cases 25 only. Neither of them have anything to do with what documents SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011335