about the work, they lied about the money. They lied about the girls’ safety. And that is fraud.”); see also Defs.’ Ltr. at 3. In other words, the government’s theory was that the victims accepted employment with defendants and then “engage[d] in [the] commercial sex act[s]” that formed the basis for defendants’ prosecution only because of defendants “fraud.” 18 U.S.C. § 1591(a). But the precluded line of inquiry — the victims’ prior places of employment and exposure to sexualized environments (as well as pri- or work as prostitutes) — bears directly on whether they were defrauded within the meaning of 18 U.S.C. § 1591(a); that is, whether they understood the terms and circumstances of their employment. Cf. United States v. Valenzuela, 2008 WL 2824958, at *3 (C.D.Cal. July 21, 2008) (<HOLDING>). The government argues that notwithstanding
holding that the impact upon the victims is relevant to circumstances of the crime holding that the offense of sexual battery requires the state prove the victims lack of consent regardless of the victims age and charge the jury on the same recognizing that if the government introduced evidence tending to show that the victims  did not expect to engage in prostitution  it will have put those victims sexual histories at issue and under those circumstances it is possible that  evidence rebutting the governments allegations might be admissible under the constitutional exception holding that evidence of a later sexual encounter that triggered the delayed report was admissible only after milligan had in fact introduced evidence of late reporting  to impeach the victims testimony holding that evidence of prior uncharged sexual conduct with the victim is admissible to corroborate the victims testimony