Ms. Giuffre's not-for-profit tax compliance are based on an

10 id. 12 13 14 L5 16 ne) 18 life) 20 21 22 23 24 25 28 H3VOGIU1 Ms. Giuffre's not-for-profit tax compliance are based on an errant report by her purported expert, an expert who should be excluded from testifying because his report lacked methodology and he opined on topics far afield from his expertise. Second, any allegations that her not-for-profit is not tax compliant is prejudicial, misleading, confusing to the jury because it has nothing to do with the claim at issue in this case. Your Honor, we asked for defendant's tax returns in this case. If they go to truthfulness, as defendant argues, they also go to defendant's truthfulness. At this point, we're not going to get them until the first day of trial, so we will not be able to effectively cross examine defendant on those tax returns, and we won't be able to s until then if she's paid taxes on all the money and gifts and in-kind payments from Epstein that she's received or has kept that away from the government. Unlike Ms. Giuffre's tax information, defendant's tax information goes to our case in chief and is relevant evidence. On point number 13, we move to exclud videnc relating to Ms. Giuffre's alleged tax compliance. Your Honor, this is a defamation action where reputation is at issue. Tax compliance does not go to a reputation, it is a private matter. Second, there is no evidence in this case that any government, ither United States or Australia, believes that SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011331