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10 fd. 12 [3 14 15 16 i) 18 wife) 20 21 22 23 24 25 fd. H3VOGIU1 of that nature shouldn't be able to come in. Because when we talk about a character issue, what's at issue here is reputation, and reputation to show the truthfulness of that would not be able to be proven in that circumstance because we don't have the other individuals there to make that statement, so there's no substantive evidence on that point that would be coming in. And the third category is with respect to Mr. Dershowitz, who is on the defendant's witness list for trial, and we have a few points there to raise. I mean, one is obviously that if that were allowed to come in, that causes the trial to become a mini trial about whether or not he, for example, was in the places where she says he was, his calendars, his credit card receipts, his telephone records, all of that. It gets into the issue, you know, obviously we have another witness who says that they were in a similar circumstance with respect to him. So it takes the trial away from whether or not the allegations relating to Maxwell are true or false and turns it into a trial about another individual who we have not made a claim against who comes in. There's also a problem with respect to that because he is also -- he has claimed attorney/client privilege as to his conversations and his advice with respect to Epstein which relates to the issues with Maxwell. So in other words, he would be able to testify what he says he didn't do, but then SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011314