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10 fd. 12 [3 14 15 16 i) 18 wife) 20 21 22 23 24 25 115 H3vlgiu2 and the case says, it's undisputed the defendant had actual prior knowledge of the issues, of the at-issue statements that were offered by the defendant. Again, the statements were mad t6 Crescenz. And then the last case is a 1983 case, Tierney v. Davidson. That involved civil rights violations and objective reasonableness by the officers who conducted a search of a building. I think the Court knows from doing this kind of work that pretty much anything in an officer's head is allowed in a qualified immunity case, because whether the officer did something that was objectively reasonable or not depends on what's in the officer's head, and so there is (A) an exception in these kinds of cases, but (B), in fact, the evidence that was being discussed in the qualified immunity situation related to statements that the officers had heard, which formed the basis of why they went into a building. So in each and every one of these cases and all cases that deal with state of mind, the person who it is being introduced either for or against, not for the truth of the matter asserted but for their state of mind, has to know about Lt You have attached to our reply an affidavit from Ms. Maxwell who says she's never read any of these police reports prior to January 2015. And there is good reason for that, your Honor. It's not easy to get these police reports. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011418