74 H3VOGIU1 ih information, then the lawyers present arguments to your Honor 2 and say, 'Wait a minute. Some of the things that are in the 3 report aren't relevant to the case and, in fact, are going to 4 be highly prejudicial for the jury." That's why we're here 5 this morning asking for some of those things to be excluded. 6 For example, there are some references -- I won't 7 belabor the point -- but the references that we're making to 8 some of the illegal drug usage and so forth, that's not 9 something we're trying to deploy affirmatively. The good 10 doctor simply listed all of the information that had been 1a recited as part of his report so that the lawyers and the judge 1 can now make a determination. 13 And the fact that Ms. Giuffre told Dr. Kliman in a 14 confidential psychiatric examination certain things about drug 15 use can't possibly go to her reputation because no one was 16 there who was assessing what kinds of things might be going on. de A similar point can be made about tax fraud. We're 18 told, "Well, your Honor, tax fraud goes to her reputation." I 19 suppose that goes to her reputation with some IRS agent who is 20 looking at a return, but it can't possibly go to a general 21 reputation that is at issue in this case. 22 And once again, the cases that we cite in our briefs I 23 think make this point clear, there is a vast risk of 24 prejudicial effect to Ms. Giuffre because the jury is going to 25 think, oh, she's a tax cheat, and they're going to hold that SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011377