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10 fd. 12 [3 14 15 16 i) 18 wife) 20 21 22 23 24 25 29 H3VOGIU1 she is noncompliant with her taxes. Defendant's purported expert's evaluation of this is wholly flawed, as explained in Ms. Giuffre's motion in limine on the same. Similarly, Ms. Giuffre's taxes are wholly irrelevant to this case. Even actions brought by the government, your Honor, where the cause of action is centered on nontax complianc xclud vidence of prior tax noncompliance when it takes the case too far afield of the issue being tried. Courts also exclude this evidence under 403 if there's no substantial nexus between the alleged tax noncompliance and the matter at hand. Here, defendant fails to show any type of substantial nexus to this defamation claim. None whatsoever. Additionally, resolving Ms. Giuffre's tax compliance, this is a point that's in dispute among the parties, and resolving such an issue would also involve another mini trial where Ms. Giuffre would put on evidence of her tax compliance and, at the end of that mini trial, the jury would have no more information whether or not defendant defamed Ms. Giuffre when she called her a liar about being sexually abused. Trying to make this an issue, this is simply a device for putting the settlement agreement and the amount between Ms. Giuffre and Jeffrey Epstein into evidence. As has been briefed extensively, such a settlement payment is tax exempt under the United States law, but that's all this is, it's a device to try to get an improper admission SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011332