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

handling that. 5 This is essentially a hearsay exercise. We want information to 6 be excluded regarding Rebecca Boylan. Why? Because Rebecca 7 Boylan has not been deposed and is not going to be a witness in 8 the case. 9 As we understand what the defendant is planning to do, 10 she's planning

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

tness in the case. As we understand what the defendant is planning to do, she's planning to call Mr. Dershowitz. Mr. Dershowitz is going to say Ms. Boylan told him that Ms. Giuffre told him something, and so we have the classic hearsay within a hearsay situation. The problem, of course, is that Boylan

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

handling that. 5 This is essentially a hearsay exercise. We want information to 6 be excluded regarding Rebecca Boylan. Why? Because Rebecca 7 Boylan has not been deposed and is not going to be a witness in 8 the case. 9 As we understand what the defendant is planning to do, 10 she's planning

om> Subject: Fwd: 3/22 - Berlin to Paris Sony for all the typos .Sent from my iPhone Begin forwarded message: From: Date: March IlliMPIPRI M To: Jeffrey Epstein <[email protected]> Subject: Fwd: 3/22 - Berlin to Paris Begin forwarded message: From: Danny Preston Date: March 20, 2012 8:31:36 AM GMT+01:0

in forwarded message: From: Danny Preston Date: March 20, 2012 8:31:36 AM GMT+01:00 To: Cc: ay Boylan Subject: 3/22 - Berlin to Paris Hello Mr. Epstein, Per Ray Boylan's request, I found an aircraft for a round trip on Thursday from Berlin to Paris. Pm double checking the crew duty for your times o

ded message: From: Date: March IlliMPIPRI M To: Jeffrey Epstein <[email protected]> Subject: Fwd: 3/2

ay Boylan Subject: 3/22 - Berlin to Paris Hello Mr. Epstein, Per Ray Boylan's request, I found an aircraft f

mail.com> Subject: Fwd: 3/22 - Berlin to Paris Begin forwarded message: From: Danny Preston Date: March 20, 2012 8:31:36 AM GMT+01:00 To: Cc: ay Boylan Subject: 3/22 - Berlin to Paris Hello Mr. Epstein, Per Ray Boylan's request, I found an aircraft for a round trip on Thursday from Berlin to Pari

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)

g is relevant and admissible (Motion in Limine 19)... eee 29 20. The transcript of the tape recording of Mr. Dershowitz’s conversation with Rebecca Boylan is admissible (Motion 1n Limine 20)... ceececesessseeseeceeeeseeneeceseeseeneeeeeerseeeaees 31 C. Plaintiff's Remaining Motions In Limine Are Prematu

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

nt and admissible (Motion in Limine 19).................00. 29 20. The transcript of the tape recording of Mr. Dershowitz’s conversation with Rebecca Boylan is admissible (Motion in Limine 20)... ccccccccccceceeceeeceseeesecneesseesteeesaeenes 31 C. Plaintiff's Remaining Motions In Limine Are Premature an

ane Misbehavior. • Balko: Federal Review Of State Convictions Needed To Protect Rights Of Accused. INTERNATIONAL RELATIONS • Prince Andrew Sued By Epstein Accuser Over Alleged Sexual Abuse. OTHER WASHINGTON NEWS • Austin To Mandate Vaccines For Military Personnel By Mid-September. • US Again Tops 100

ed in US court on Monday "for having allegedly on three occasions sexually abused a woman who says she was trafficked for sex by the late financier Jeffrey Epstein." In a civil complaint, said the Duke of York, Queen Elizabeth's second son, sexually assaulted and battered her about two decades ago, when she w

she was trafficked for sex by the late financier Jeffrey Epstein." In a civil complaint, said the Duke of

n. Both Kaplan and Alphonso David, leader of the Human Rights Campaign, were consulted over a letter the Cuomo administration had drafted attacking Boylan's credibility." Federal Judge Suggests CDC's New Eviction Moratorium Amounts To Legal "Gamesmanship." Politico (8/9, Gerstein, O'Donnell, 6.73M) r

story. DOJ, FBI Conclude Epstein Had No "Client List," Committed Suicide Axios (07/06, Isenstadt) reported that the DOJ and FBI have concluded that Jeffrey Epstein did not have a "client list" and committed suicide in 2019. A memo detailing the findings states that investigators found no evidence of Epstein bl

ey Epstein did not have a "client list" and committed suicide in 2019. A memo detailing the findings states that investigators found no evidence of Epstein blackmailing powerful figures or being murdered. The article highlighted that Director Patel and Deputy Director Bongino have since said Epstein com

reported that the DOJ and FBI have concluded that Jeffrey Epstein did not have a "client list" and committ

rline ecosystem, including trusted vendors and contractors, could be at risk of being targeted by the Scattered Spider group. Hawaii Tribune (07/04, Boylan) and Daily Mail (07/05, Garino) also reported on the story. Connecticut 19-Year-Old Posed as Yahoo! And Google Worker in $245M Crypto Heist newsti

American public when it comes to the FBI." The article added that Director Patel and Deputy Director Bongino plainly stated that notorious financier Jeffrey Epstein died by suicide in prison. "I was asked about some of the details surrounding the Jeffrey Epstein case. I have reviewed the case. Jeffrey Epstein k

o plainly stated that notorious financier Jeffrey Epstein died by suicide in prison. "I was asked about so

r Bongino plainly stated that notorious financier Jeffrey Epstein died by suicide in prison. "I was asked

ff), Hawaii News Now (HNN/CBS-5) (05/21, Staff Writer), KNBC (NBC-4) (05/21, Lloyd), KTLA (CW-5) (05/21, Conybeare), and the Star-Advertiser (05/21, Boylan). Suspect Facing Federal Charges After Bomb Hoax Shuts FBI Tampa Field Office The Independent (05/21, Rohrlich) reported that Nicki Wayne Goodman,

American public when it comes to the FBI." The article added that Director Patel and Deputy Director Bongino plainly stated that notorious financier Jeffrey Epstein died by suicide in prison. "I was asked about some of the details surrounding the Jeffrey Epstein case. I have reviewed the case. Jeffrey Epstein k

o plainly stated that notorious financier Jeffrey Epstein died by suicide in prison. "I was asked about so

r Bongino plainly stated that notorious financier Jeffrey Epstein died by suicide in prison. "I was asked

ff), Hawaii News Now (HNN/CBS-5) (05/21, Staff Writer), KNBC (NBC-4) (05/21, Lloyd), KTLA (CW-5) (05/21, Conybeare), and the Star-Advertiser (05/21, Boylan). Suspect Facing Federal Charges After Bomb Hoax Shuts FBI Tampa Field Office The Independent (05/21, Rohrlich) reported that Nicki Wayne Goodman,