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10 fd. 12 [3 14 15 16 i) 18 wife) 20 21 22 23 24 25 H3VOGIU1 there. Although no allegations of trafficking or anything of that nature, just that she was there. And they are seeking to introduce evidence through Louie Freeh, who we'll discuss ina moment, they've proposed, and he's clearly an expert that was undisclosed, and through a FOIA record, and through the articles to allege that he wasn't on the island. And so in your Honor's order in 264-1, which is one of the sealed orders, you did not allow us to depose him because you said it was irrelevant. So we're now in a position where at trial they want to put forth that information against my client, and I don't have an under-oath statement from that individual saying whether or not he actually was. Now, what we know is he flew with Jeffrey Epstein at the same time 19 different times internationally and nationally, but we don't have him with respect to this particular allegation under oath. So we would say it would be highly prejudicial for them to be able introduce evidence saying that he wasn't there or that they have some proof or some expert saying he wasn't there when, in fact, we weren't able to ask him directly, the person who is at issue, under oath, whether or not he did, in fact, go there. So one of the streamlining of this case is that allegation has nothing to do with sexual abuse, it doesn't have to do with the statements SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011311