84 H3VOGIU1 ih of consent is at that point because you have a federal sex 2 trafficking crime that has been committed. 3 The same thing is true if you fly a 17-year-old into 4 London, or if you fly her into New York. All of those are sex 5 trafficking crimes, and Professor Conan is prepared to explain 6 both that particular aspect, I would describe it as a mixed 7 question of fact and law, and also some of the psychological 8 techniques that are used to create the -- I think he refers to 9 them as the invisible chains of sex traffickers. 10 So we either have a crime in Florida, because she's apa: under the age of consent, or we have a federal or, in all 12 likelihood, state trafficking offense if she's flown to another 13 states 14 Which regard to item 18, the Cassell and Edwards 15 litigation, I think your Honor asked some excellent questions 16 on that. de We were told that there are five reasons why 18 Ms. Giuffre's connection to that case has some relevance. The 19 first argument, I guess, is their strongest argument, was that, 20 well, she was a witness in that case. But, of course, that was 21 a confidential deposition, so it couldn't have anything to do 22 with reputational damages or something else. 23 Let me be clear. Ms. Giuffre made statements when she 24 was deposed, and if they say, ah-hah, you've said X from the 25 witness stand, but last year when you were deposed you said not SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011387