information, then the lawyers present arguments to your Honor

10 id. 12 13 14 L5 16 ne) 18 life) 20 21 22 23 24 25 74 H3VOGIU1 information, then the lawyers present arguments to your Honor and say, 'Wait a minute. Some of the things that are in the report aren't relevant to the case and, in fact, are going to be highly prejudicial for the jury." That's why we're here this morning asking for some of those things to be excluded. For example, there are some references I won't belabor the point -- but the references that we're making to some of the illegal drug usage and so forth, that's not something we're trying to deploy affirmatively. The good doctor simply listed all of the information that had been recited as part of his report so that the lawyers and the judge can now make a determination. And the fact that Ms. Giuffre told Dr. Kliman ina confidential psychiatric examination certain things about drug use can't possibly go to her reputation because no one was there who was assessing what kinds of things might be going on. A similar point can be made about tax fraud. We're told, "Well, your Honor, tax fraud goes to her reputation." I suppose that goes to her reputation with some IRS agent who is looking at a return, but it can't possibly go to a general reputation that is at issue in this case. And once again, the cases that we cite in our briefs I think make this point clear, there is a vast risk of prejudicial effect to Ms. Giuffre because the jury is going to think, oh, she's a tax cheat, and they're going to hold that SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011377