100 H3vlgiu2 ih compliance, if there is questions about that, could be 2 introduced. We think that there shouldn't be tax compliance 3 issues coming in with regard to Ms. Giuffre. They've said, 4 well, that goes to her credibility. What's good for 5 Ms. Giuffre should be good for the defendant. But again, to be 6 clear, we don't want to turn this into a tax trial; we want it 7 to be a defamation trial. But they've made an argument, tax 8 issues are relevant to Ms. Giuffre. Then we would like to have 9 a parallel opportunity then with respect to Ms. Maxwell. 10 The other thing we have, for example, we're alleging 1a there's a organization that is paying girls to give sex to 12 Epstein. And who's making the payments? Well, Ms. Maxwell, 13 among others. We have her on bank records, at the Epstein 14 mansion, where she's in charge of the -- 15 THE COURT: Well, that's different. 16 MR. CASSELL: Yes, and that's exactly -- uy THE COURT: That's not her financial status. 18 MR. CASSELL: Right. So that's not her financial 19 status. For example, we want to show those kinds of payments. 20 We also want to show more broadly that Ms. Giuffre and the 21 other girls were not coming into a bungalow in the middle of 22 Hoboken or whatever. They were coming into a mansion in one of 23 the most -- 24 THE COURT: Well, that's got nothing to do with her 29 financial status. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011403