13 H3VOGIU1 ih prejudicial effect« 2 Obviously, this is going to be considered by the jury 3 to think she's a bad kid. They're not going to like 4 Ms. Giuffre, and they're going to hold it against her, not 5 because it has some technical reputational aspect to it, but 6 because it is something that shows she's a bad person. Under 7 403, the evidence should be excluded. 8 Let me give you a second illustration of reputational 9 points. They say, "Ah-ha, look. Ms. Giuffre went to 10 Dr. Kliman," and I believe your Honor referred to that as well. 1a And your Honor asked, I think, a very good question, and let me 12 see if I can answer that question. 13 You said, "Well, why did she disclose all this stuff 14 to Dr. Kliman?" Well, the answer is obvious, she was under 15 instructions from the doctor to tell everything that happened, 16 and of course she told, to the best of her ability, everything de that happened. Some of the stuff is going to turn out ina 18 court of law to be relevant, some of this stuff in a court of 19 law is going to turn out to be irrelevant. But that's not the 20 psychiatrist's job to say, 'No, no, no, don't talk about 21 illegal drug use because the prejudicial effect outweighs the 22 probative value,' he just gets a full medical history. And 23 having collected all that information, you know, through 24 Dr. Kliman, or they also have Dr. Miller who did a similar sort 25 of thing. Now once you have all of this vast array of SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011376