123 H3vlgiu2 ih the business records exception. But even if it weren't to come 2 in under the business records exception, it can come in not for 3 the truth of the matter asserted but to show for knowledge. 4 And you say in your June 20th order, "Notwithstanding the 5 questions are directed to reveal relevant answers regarding 6 defendant's knowledge of plaintiff's allegations, that 7 knowledge goes directly to the truth or falsity of the 8 defamation, a key element of plaintiff's claims." In other 9 words, what Maxwell knew at the time she's making the statement 10 goes to the truth of the falsity of those statements, and that 1a includes this police report, your Honor, so we believe that 12 it's critical evidence to show that. And you'll see that, 13 again, she was working for the defendant at the time that this 14 investigation happened. She has testified to that. She was on 15 the flights with him at the time this was going on over 300 16 times during that period. de THE COURT: You know, spare me the flights, okay? 18 MS. McCAWLEY: Sure. Okay. 19 THE COURT: I've heard that before. 20 MS. McCAWLEY: Sure. I'm sorry, your Honor. I'11 try 21 to cut to the chase here. 22 So certainly, you know, it's interesting, because you 23 heard defense counsel here not too long ago saying that they 24 wanted to get in police reports of an under-aged minor, 25 Virginia Giuffre, from when she was 14, being raped by two SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011426