Epstein Secrets

15 statements about the defendant -- to be clear, because one of 16 the allegations is, of course, she was a madam and a 17 coconspirator with Epstein -- do involve Epstein. 18 THE COURT: Listen. Leave the pejorative out. Okay? 19 Please. 20 MS. McCAWLEY: Sure. 21 THE COURT: Simply because I

t, in 17 accord with the flight records, which have also been produced 18 in this case, which place Ms. on 23 flights with 19 defendant aboard Jeffrey Epstein's private plane. 20 So as these records actually show truancy, failed 21 grades, failure to complete courses, these should be excluded 22 under a

between our client and Mr. Dershowitz on page GM009, 24 it's one of the lies that our client specifically referred to. 25 She quotes statement, "Jeffrey bought me SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00794613 59 H3V0GIU1 1 jewelry, diamonds were his favorite, and wonderful furn

in 8 this statement does she say, 'I didn't participate in this 9 abuse. I didn't know this person. I wasn't around. This 10 didn't happen with JE.' Instead, she picks statements and says 11 things like -- which sound like a jealous girlfriend -- she 12 says, "I called Jeffrey and told him I

0 EFTA00794568 14 H3VOGIU1 1 regularly with Mr. Epstein to other places. 2 So again, we didn't get to d

against 10 him, and what's at issue in this case is, again, Maxwell's 11 statements against my client. 12 The case that they cite actually, the Minemyer case, 13 goes against them. It actually talks about how you would have 14 to call the reporter, that that couldn't come into evidence. 15 And s

s nowhere in this statement does she say, 'I didn't participate in this abuse. I didn't know this person. I wasn't around. This didn't happen with JE.' Instead, she picks statements and says things like -- which sound like a jealous girlfriend -- she says, "I called Jeffrey and told him I've falle

or, in that the statements about the defendant to be clear, because one of the allegations is, of course, she was a madam and a coconspirator with Epstein -- do involve Epstein. aid al ir] COURT: Listen. Leave the pejorative out. Okay? Please. MS. McCAWLEY: Sure. THI Gl COURT: Simply because I'm

in fact, in accord with the flight records, which have also been produced in this case, which place Ms. Giuffre on 23 flights with defendant aboard Jeffrey Epstein's private plane. So as these records actually show truancy, failed grades, failure to complete courses, these should be excluded under all the rules I

client and Mr. Dershowitz on page GMOO09, it's one of the lies that our client specifically referred to. She quotes Virginia Giuffre's statement, "Jeffrey bought me SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011361 10 id. 12 13 14 L5 16 ne) 18 life) 20 21 22 23 24

21 22 23 24 25 14 H3VOGIU1 regularly with Mr. Epstein to other places. So again, we didn't get to depo

by my client against him, and what's at issue in this case is, again, Maxwell's statements against my client. The case that they cite actually, the Minemyer case, goes against them. It actually talks about how you would have to call the reporter, that that couldn't come into evidence. And so, your Hono

in that the statements about the defendant -- to be clear, because one of the allegations is, of course, she was a madam and a coconspirator with Epstein -- do involve Epstein. THE COURT: Listen. Leave the pejorative out. Okay? Please. MS. McCAWLEY: Sure. THE COURT: Simply because I'm trying to com

t, in 17 accord with the flight records, which have also been produced 18 in this case, which place Ms. on 23 flights with 19 defendant aboard Jeffrey Epstein's private plane. 20 So as these records actually show truancy, failed 21 grades, failure to complete courses, these should be excluded 22 under a

t email between our client and Mr. Dershowitz on page GM009, it's one of the lies that our client specifically referred to. She quotes statement, "Jeffrey bought me SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00612307 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 2

s nowhere in this statement does she say, 'I didn't participate in this abuse. I didn't know this person. I wasn't around. This didn't happen with JE.' Instead, she picks statements and says things like -- which sound like a jealous girlfriend -- she says, "I called Jeffrey and told him I've fall

20 21 22 23 24 25 H3VOGIU1 regularly with Mr. Epstein to other places. So again, we didn't get to depo

y my client against him, and what's at issue in this case is, again, Maxwell's statements against my client. The case that they cite actually, the Minemyer case, goes against them. It actually talks about how you would have to call the reporter, that that couldn't come into evidence. And so, your Hono

orn/2020/09/30/us/elections/with-remarlcs- about-poll-watchers-and-the-supreme-court-trump-stepped-up-attempts-to-sow-doubt-on-the-vote.html> (9/30, Epstein, Thrush, 18.61 M) says that "in recent months, as his standing in the polls has fallen, Mr. Trump has pre- emptively argued that Democratic elections

kedown. FierceHealthcare <https://www. fiercehealthcare.com/payer/doj-charges-hundreds-connection-6b-healthcare- fraud-largest-takedown-ever> (9/30, Minemyer, 146K) reports, "The Department of Justice charged 345 people across 51 federal districts in the largest healthcare fraud takedown in the agency's h

included the involvement of top officials, including the president and Vice President Mike Pence." In a separate artide, the New York Times (9/30, Epstein, Thrush, 18.61M) says that "in recent months, as his standing in the polls has fallen, Mr. Trump has pre-emptively argued that Democratic elections

mer UAW president Gary Jones has also been convicted. US Charges Hundreds In Connection With $6B Healthcare Fraud Takedown. FierceHealthcare (9/30, Minemyer, 146K) reports, "The Department of Justice charged 345 people across 51 federal districts in the largest healthcare fraud takedown in the agency's h

included the involvement of top officials, including the president and Vice President Mike Pence." In a separate article, the New York Times (9/30, Epstein, Thrush, 18.61M) says that "in recent months, as his standing in the polls has fallen, Mr. Trump has pre-emptively argued that Democratic elections

mer UAW president Gary Jones has also been convicted. US Charges Hundreds In Connection With $6B Healthcare Fraud Takedown. FierceHealthcare (9/30, Minemyer, 146K) reports, "The Department of Justice charged 345 people across 51 federal districts in the largest healthcare fraud takedown in the agency's

included the involvement of top officials, including the president and Vice President Mike Pence." In a separate article, the New York Times (9/30, Epstein, Thrush, 18.61M) says that "in recent months, as his standing in the polls has fallen, Mr. Trump has pre-emptively argued that Democratic elections

mer UAW president Gary Jones has also been convicted. US Charges Hundreds In Connection With $6B Healthcare Fraud Takedown. FierceHealthcare (9/30, Minemyer, 146K) reports, "The Department of Justice charged 345 people across 51 federal districts in the largest healthcare fraud takedown in the agency's

and world leaders are highly relevant and admissible (Motion in Limine 1) .0...... ce ceeeeseeeseeeseeeseeeseeeneeesees 6 2. Meeting Bill Clinton at Jeffrey Epstein’s private island twice (Motion in Limine 2)..... 8 3. FOIA responses and related materials are admissible (Motion in Limine 3).................+ 8 4. L

her intervening causes of emotional distress and related damages (Motion in Limine 14) 23 15. Plaintiffs lies about her age and the year she met Mr. Epstein must be exposed to the Jury (Motion in Limine 15)... eee eeeceeseesseeseeesseessecseeesceeseecnseesaeeseeceseeaeesseeeeesseesaees 24 16. All of Plai

laintiffs lies about her age and the year she met Mr. Epstein must be exposed to the Jury (Motion in Limine 15)

7 Mich. App. 1, 12, 602 N.W.2d 233, 239 (1999)... eee 13 Longmire v. Ala. State Univ., 151 F.R.D. 414, 419 (M.D.Ala. 1992)... cece ee eee ee ee eee 3 Minemyer v. R-Boc Representatives, Inc., No. 07 C 1763, 2012 WL 379904, at *4 (N.D. IIL Feb. 6, 2012) oo eeeeseseessesscssenecrscsecseesecsesessesesseseesses

ents, and world leaders are highly relevant and admissible (Motion in Limine 1) ..00...0.. eee eceeeeeeeeeeeeeeteeneene 6 2. Meeting Bill Clinton at Jeffrey Epstein’s private island twice (Motion in Limine 2)..... 8 FOIA responses and related materials are admissible (Motion in Limine 3).................. 8 io)

er intervening causes of emotional distress and related damages (Motion in Limine 14) 23 15. Plaintiff's lies about her age and the year she met Mr. Epstein must be exposed to the Jury (Motion in Limine 15)... cccccccccccssenseecseeessecssecsecsseesseeeseecssessecsesteesteeens 24 16. All of Plaintiff’s m

aintiff's lies about her age and the year she met Mr. Epstein must be exposed to the Jury (Motion in Limine 15

ss'n, 237 Mich. App. 1, 12, 602 N.W.2d 233, 239 (1999)... 13 Longmire v. Ala. State Univ., 151 F.R.D. 414, 419 (M.D.Ala. 1992). 000.00. cece cee ed Minemyer v. R-Boc Representatives, Inc., No. 07 C 1763, 2012 WL 379904, at *4 (N.D. ILL. Feb. 6, 2012) oe ceecceececcecccecceseeecesecsecseeceeeseesecseesaec