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10 fd. 12 [3 14 15 16 i) 18 wife) 20 21 22 23 24 25 83 H3VOGIU1 from defense counsel about a blame the victim mindset that the jury would very well adopt once they heard that Ms. Giuffre's staying with her husband is a victim of domestic violence. So your Honor has in front of it, I think, essentially uncontested evidence, or at least uncontested argument of substantial prejudicial effect that will exist that tips decisively in favor of excluding this, particularly when they get to subjects like criminal proceedings. We're going to then get into what is the scope of the protective order if they live in Australia and things like that. That's far afield from any effect on emotional distress damages. Item 15 has to do the 17-year-old, 16-year-old, 15-year-old. I think we have agreement from both sides that sex with a 17-year-old is unlawful under the age of consent statute that exists in Florida, and we'll be asking either to cover that through an expert witness or through a jury instruction. But they say, oh, what if she's flown to New Mexico? The age of consent there might be different. And this is where I believe your Honor can take a close look at the expert witness on sex trafficking, the 702 motion is currently pending in front of you, Professor Terry Conan, who is at the Florida State Trafficking Institute, and we've offered him as an expert witness. If you take a 17-year-old from Florida, fly her to New Mexico for sexual purposes, it makes no difference what the age SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011386