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D FOREMAN, P.C. Attorneys for Defendant 20 BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. 21 22 23 24 25 SO
P.C. Attorneys for Defendant 20 BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. 21 22 23 24
t's defamation. 3 I'm going to move on to point number 9. Ms. 4 seeks to exclude any alleged criminal history from coming into 5 this case. And the Federal Rules of Evidence bar the 6 introduction of this evidence, full stop. 7 As the Court is aware, the only way criminal history 8 could come into evidence is through Rule 609
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
defendant's defamation. I'm going to move on to point number 9. Ms. seeks to exclude any alleged criminal history from coming into this case. And the Federal Rules of Evidence bar the introduction of this evidence, full stop. As the Court is aware, the only criminal history could come into evidence is through Rule 609, but that
GAN AND FOREMAN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. SOUTHERN DISTRICT R (2
EMAN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. SOUTHERN DISTRICT
ant's defamation. I'm going to move on to point number 9. Ms. Giuffre seeks to exclude any alleged criminal history from coming into this case. And the Federal Rules of Evidence bar the introduction of this evidence, full stop. As the Court is aware, the only way criminal history could come into evidence is through Rule 609, but th
Entities connected to both Jeffrey Pagliuca and the Federal Rules of Evidence bar the

Ghislaine Maxwell
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Jeffrey Epstein
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Prince Andrew
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Colorado
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David Boies
PERSONSigrid McCawley
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Bradley Edwards
PERSONthe Southern District
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Paul Cassell
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Virginia Giuffre
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Alan Dershowitz
PERSONJane Doe
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George W. Bush
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Bill Clinton
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Alfredo Rodriguez
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Bernie Sanders
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LAURA A. MENNINGER
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Kenneth Marra
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Robert Mueller
PERSONSharon Churcher
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