Every indexed document

there is no evidence in this case that any

and we won't be able to see until then if she's paid

any allegations that her not-for-profit is not

it is a fact that defendant does not acknowledge in her

now I'm turning to point number 12. We've

any marginal probative value of these bad

is inadmissible and a defamation action where the

with a reputation for truthfulness of another.

including characterizations of her as a bad child or

which place Ms. Giuffre on 23 flights with

as you can see in the document I handed up

looking up what the number codes on these

she was fleeing defendant. If she were worried

then that makes defendant an accessory after

shows that it was defendant who sent her to Thailand

the alleged crime does not go to truthfulness.

to avoid undue harassment or embarrassment.

your Honor. The defendant's own expert report

they objected in it's entirety to this motion

but the documents themselves describe something