Epstein Secrets

N AND FOREMAN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. SOUTHERN DISTRICT REPO

AN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. SOUTHERN DISTRIC

22 23 24 25 problem. Well, no, it isn't. No, it isn't. Okay. So let's do 675. MS. MENNINGER: Your Honor, I will say that it is my reading of Rule 412 that any hearing that is based upon in part Rule 412 is supposed to be conducted in a in camera setting. MS. SCHULTZ: Counsel for Ms. has no objec

NITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL'S REPLY IN SUPPORT OF HER MOTIONS IN LIMINE Jeffrey S. Pagliuca Laura A. Menninger HADDON MORGAN & FOREMAN P.C. Denver Phone: Christian R. Everdell COHEN & GRESSER LLP New York NY Phone: Bobbi C. Stemheim

IN SUPPORT OF HER MOTIONS IN LIMINE Jeffrey S. Pagliuca Laura A. Menninger HADDON MORGAN & FOREMAN P.C.

inor probative value the evidence has is substantially outweighed by the danger of unfair prejudice. Fed. R. Evid. 401, 403. And as explained in the Rule 412 motion today, if offers testimony and the government presents argument 22 EFTA00090748 along these lines, that will open the door to other sexu

14 MS. SCHULTZ: Your Honor, I'd like -- 15 MR. PAGLIUCA: I'd like to respond to this joint 16 defense a

same 2 problem. Well, no, it isn't. No, it isn't. 3 Okay. So let's do 675. 4 MS. MENNINGER: Your Honor, I will say that it is my 5 reading of Rule 412 that any hearing that is based upon in part 6 Rule 412 is supposed to be conducted in a in camera setting. 7 MS. SCHULTZ: Counsel for Ms. has no