in the way that we did
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in the way that we did.
I'm just going to let my counsel address any final
issues.
MS. SCHULTZ: Your Honor, I don't have anything
further to say on motion in limine number 6. The defendant has
not given any valid reason or justification for introducing any
evidence of prior sexual assault that should be excluded for
all the reasons in the brief and the oral argument over thes
two days.
With regard to drugs, there are voluminous medical
records presented here. Defendant's counsel has stood up and
said there are false statements to doctors and have suggested
that Ms. Giuffre is doctor shopping. I'll submit that the
records do net reflect that.
Defendant apparently seeks to introduce a jotted down
note here or there from medical records, but these are plainly
hearsay, and a sentence fragment in the middle of a medical
chart is not admissible evidence, it's hearsay. And then,
they're certainly not a party admission, they don't even
reflect the totality of what the conversation is between
patient and doctor.
Also, I would also submit that the prescription
records show that they are not doctor shopping to a mass
amounts of pills or medication. The prescription records speak
for themselves. You can count the number of pills that were
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