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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
motion reads like a list 9 of everything plaintiff has lied about or anything that would 10 undercut her claim for damages. 11 Plaintiff quoted Passim in her reply brief from a 12 particular federal evidence treatise, and I would like to tell 13 the Court, she left out the most important parts,
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
The omnibus motion reads like a list of everything plaintiff has lied about or anything that would undercut her claim for damages. Plaintiff quoted Passim in her reply brief froma particular federal evidence treatise, and I would like to tell the Court, she left out the most important parts, and that i
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
he omnibus motion reads like a list of everything plaintiff has lied about or anything that would undercut her claim for damages. Plaintiff quoted Passim in her reply brief from a particular federal evidence treatise, and I would like to tell the Court, she left out the most important parts, and that
Name Mark an cif Bill 7/14/1954 Cotetyltountaes of Tax Residence US ts Conde/Re Parson a non.US Berierciarylnon-US Beneficial Owner? Last Name Epstein Convening Person TypeiRole Trustor tat Indyke CortIroang Person Typsaiolo Trustee Yes (comply* Appendix 2) I No Lae& Name Kahn Controlling Pers
rson a non-US Benallastehon-US Beneficial Omer? Yes (complete Appendix 2) 4/ No 44 Fat Name Darren Dale oil BIM v i enees CourswiCouninut ot In Passim US Is Confiding Person a non.US Benegoaryhson-US Beneficial Omer? PmNameRichard Dale °Seth 12/06/1972 cassava:Rimers at Tax Residence US Is C
Entities connected to both Jeffrey Epstein and Passim

Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
Alfredo Rodriguez
PERSON
Kenneth Marra
PERSON
Bill Clinton
PERSON
Peter Mandelson
PERSONthe Southern District
LOCATION
Paul Cassell
PERSON
Virginia Giuffre
PERSONScott Rothstein
PERSONJack Scarola
PERSON
David Boies
PERSON
Colorado
LOCATION
Bernie Sanders
PERSONJeffrey Pagliuca
PERSONSigrid McCawley
PERSON