131 H3vlgiu2 1 THE COURT: What's next? 2 MR. CASSELL: The motion on Kellen and Marcinkova, our 3 motion to get in adverse inference. 4 THE COURT: Yes. 5 MR. CASSELL: If I can be heard on that, your Honor. 6 THE COURT: Excuse me. Let me go back to where we id were. 8 Those statements, the statements of the "victims," are 9 being offered for the truth, are they not? 10 MS. McCAWLEY: Your Honor, I do not believe they're 1a being offered for the truth because what we're saying -- we're 12 not saying whether or not what those victims said was 13 necessarily true. We're saying was she aware that there were a 14 number -- and they take issue with the number. I don't see a 15 difference between 17 and 30. But was she aware that there 16 were a number of other individuals making reports at the time de she said my client must have been lying about being abused as a 18 minor. So whether or not those are true or not, the reports, 19 was she aware that there were a number of reports out there 20 from other little girls saying that they were also brought to 21 the massage room. And that goes to her state of mind at the 22 time she made that statement where she defames my client 23 internationally. 24 THE COURT: Yes. But aware of the reports. How could 25 she be aware of the reports? Aware of the girls and the SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011434