Epstein Secrets

0 21 22 23 24 25 number of what I deem to be improper vouching. THE COURT: Let's get to the supplemental reports. I've read the papers on the Daubert aspect and I have some familiarity with the report, but let's get to the supplemental. MR. PAGLIUCA: I will, your Honor. And I start there because

fender registration. THE COURT: Okay. Agreed. MR. EDWARDS: So at the time -- THE COURT: So? MR. EDWARDS: So at the time she issues her statement SOUTHERN DISTRICT REPORTERS, P.C. EFTA00592418 51 H3ulgiva in 2015, which is, all of these allegations that deal with 4 5 6 7 8 9 10 11 12 13 14 15 1

ff BY: BRADLEY J. EDWARDS, ESQ. HADDON, MORGAN AND FOREMAN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. SOUTHERN DISTRICT REPORTERS, P.C. EFTA00592369 H3ulgiva (Case called) THE COURT: We have a problem, folks. By my count 4 5 6 7 8 9 10 11 12 13 14 15

5 H3ulgiva 1 number of what I deem to be improper vouching. 2 THE COURT: Let's get to the supplemental reports. 3 I've read the papers on the Daubert aspect and I have some 4 familiarity with the report, but let's get to the supplemental. 5 MR. PAGLIUCA: I will, your Honor. And I start there 6

ration. 22 THE COURT: Okay. Agreed. 23 MR. EDWARDS: So at the time 24 THE COURT: So? 25 MR. EDWARDS: So at the time she issues her statement SOUTHERN DISTRICT REPORTERS, P.C. EFTA00794465 (212) 805-0300 EFTA00794466

DWARDS, ESQ. 21 HADDON, MORGAN AND FOREMAN, P.C. Attorneys for Defendant 22 BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. 23 24 25 SOUTHERN DISTRICT REPORTERS, P.C. EFTA00794367 (212) 805-0300 EFTA00794368 2 H3ulgiva 1 2 (Case called) 3 THE COURT: We have a problem, folks. By my count

• (USANYS) dc vember 9, 202110:25 AM To USANYS) [Contractor] < :.; (USANYS) [Contractor] Cc: 44 "; Subject: 3500 production Because of the Daubert hearing tomorrow, we should get another production of 3500 out later today. Can you work on getting that organized, please? I expect we will have mo

nized, please? I expect we will have more notes from our meetings today. Thanks, Assistant United States Attorney United States Attorney's Office Southern District of New York One St. Andrew's Plaza New York, New York 10007 Tel EFTA00040145

M To: (USANYS); (USANYS) Subject: Notes - November 2, 2021 Call with Dr. Rocchio November 2, 2021 Call with Dr. Rocchio • Discussed timing of Daubert hearing/logistics • LR mentioned she has continued to review literature relating to third parties and body of relevant literature related to preda

d definition of grooming is same as LR's definition and consistent across fields Assistant United States Attorney United States Attorney's Office Southern District of New York One St. Andrew's Plaza New York, New York 10007 Tel: 3502-03 I Page 1 of I SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15,

.D.N.C. March 12, 2021) 17 Boucher v. US. Suzuki Motor Corp., 73 F.3d 18 (2d Cir. 1996) 8, 23 Bourjaior v. United States, 483 U.S. 171 (1987) 6 Daubert v. Merrell Dow Pharm., Inc., 509 U.S. 579 (1993) passim deWit v. UPS Ground Freight, Inc., No. 16 Civ. 36, 2017 WL 5905575 (N.D. Fl. Jul. 25, 2017)

RT OF ITS MOTION IN LIMINE TO PRECLUDE EXPERT TESTIMONY OF DR. PARK DIETZ AND DR. ELIZABETH LOFTUS DAMIAN WILLIAMS United States Attorney for the Southern District of New York One St. Andrew's Plaza New York, New York 10007 Assistant United States Attorneys Of Counsel EFTA00070837 TABLE OF CONTENTS PRELI

e its responsive brief by noon on November 22, 2021, and to respond only regarding Dr. Hall and not the other experts discussed in the Government's Daubert motion. EFTA00078462 Page 2 Respectfully submitted, DAMIAN WILLIAMS United States Attorney By: s/ Assistant United States Attorneys Southe

U.S. Department of Justice United States Attorney Southern District of New York The Si!lo J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 November 21, 2021 BY ECF The Honorable Alison J. Nath

2021 03:33:21 +0000 Attachments: Exhibit_B jproposed_redaetions].pdf USANYS) From: Sent: Monday, November 8, 2021 9:43 PM To: Cc Subject: RE: Daubert motion SANYS Thanks very much, I've reviewed and have no substantive edits. There were a few typos, but I gather from the email chain that mu tip

nything else you have the time or inclination to do. Thank you again for all your help with this! EFTA00086354 Assistant United States Attorney Southern District of New York 1 Saint Andrews Plaza New York, New York 10007 EFTA00086355

e Government has given notice of a qualified expert who will provide reliable and relevant opinions, as required by Federal Rule of Evidence 702 and Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993). (See Def. Mot. 3). Second, evidence relating to Minor Victim-3 is admissible both as dir

Defendant. THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S MOTIONS IN LIMINE DAMIAN WILLIAMS United States Attorney for the Southern District of New York One St. Andrew's Plaza New York, New York 10007 Assistant United States Attorneys Of Counsel EFTA00088802 Table of Contents PRELI

Assistant U.S. Attorney Southern District of New York One St. Andrew's Plaza New York. NY 10007 On Nov 11, 2021, at 5:17 PM, a alMIN> wrote: Daubert opinion on Rocchio, in case it's of interest. Thanks again! From: Nathan NYSD Chambers ‹ > Sent: Thursday, November 11, 2021 5:10 PM To: Jeff Pagl

te: Thu, 11 Nov 2021 22:54:38 +0000 Attachments: 20cr330 Daubert_Opinion_11.11.212s.pdf Great job, thank you for sending! Assistant U.S. Attorney Southern District of New York One St. Andrew's Plaza New York. NY 10007 On Nov 11, 2021, at 5:17 PM, a alMIN> wrote: Daubert opinion on Rocchio, in case it's of

is also unacceptable because the courtroom has been, and will be, in frequent use, just as it was when the parties in this case met all day for the Daubert hearing and pretrial conference on February 4. The Court's calendar is also constantly shifting, meaning that the defense team will have little to n

Release on Bail EFTA00093361 G2ase12207MOGUIvA614 1136tA4M126€ 1 ,Falitiasneaft ePa§et13219 U.S. Department of Justice United States Attorney Southern District of New York The Silvio 1 Mollo Building One Saint Andrew's Plaza New York. New York 10007 March 9, 2021 BY ECF & ELECTRONIC MAIL The Honorable