what years and what birthdays were in play and exactly what
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what years and what birthdays were in play and exactly what
Ms. Giuffre said about whether she was 15, 16, or 17. Fair
enough. They can cross examine her about, 'Did you say 16 when
you were, in fact, 17,' or whatever it is. We're not trying to
exclude that.
The limited point that we're trying to address here is
that they shouldn't say, 'Ah-hah, she was 17, therefore, she's
fair game.'
Under Florida law that we've cited in our pleadings,
there is no possibility of a child under the age of 18
consenting to sexual activities of the nature that are at issue
here, and therefore, the defendant should be precluded from
making that kind of suggestion. And so that's item 15.
MS. SCHULTZ: Turning to item 16 in the omnibus
motion. Ms. Giuffre has moved the Court to exclude medical
records. Here, I would actually like to direct the Court's
attention to defendant's response. Defendant here does not
cite a single case where a court allowed admission of unrelated
and irrelevant medical records into evidence at trial.
Defendant's brief also doesn't show how any medical
records are relevant here, and there are privacy issues at
stake. In fact, defendant does not cite to a single case in
which a court allows any medical records into evidence.
In defendant's entire response she cites two cases
only. Neither of them have anything to do with what documents
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
HOUSE_OVERSIGHT_011335
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