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

H3V0GIU1 1 these other things that are circulating about her that have 2 nothing to do with Ms. Maxwell. 3 Mr. Cassell referred to our expert Phillip Esplin, 4 Dr. Esplin, and saying that he agreed not to refer to 5 as a prostitute. Your Honor, that came up in the 6 context of a cross examination in

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

24 25 53 H3VOGIU1 these other things that are circulating about her that have nothing to do with Ms. Maxwell. Mr. Cassell referred to our expert Phillip Esplin, Dr. Esplin, and saying that he agreed not to refer to Virginia Roberts as a prostitute. Your Honor, that came up in the context of a cross examina

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

VOGIU1 53 1 these other things that are circulating about her that have 2 nothing to do with Ms. Maxwell. 3 Mr. Cassell referred to our expert Phillip Esplin, 4 Dr. Esplin, and saying that he agreed not to refer to 5 s a prostitute. Your Honor, that came up in the 6 context of a cross examination in

Plaintiff for use at trial and states as follows: I. PLAINTIFF CANNOT SATSIFY THE LEGAL REQUIREMENTS FOR USE OF CERTAIN DEPOSITIONS AT TRIAL A. Jeffrey Epstein and Ronald Rizzo Are Not Unavailable Plaintiff cannot claim that Jeffery Epstein and Ronald Rizzo are "unavailable witnesses" whose testimony can b

testimony, even attempted to serve these witnesses or obtain their attendance at trial. She has now obtained an agreement to accept service by Mr. Epstein's counsel, mooting any claim that he is unavailable.' With respect to Mr. Rizzo, she concedes he resides within 100 miles of the courthouse, and pro

Y PLAINTIFF FOR USE AT TRIAL Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN,

s now obtained an agreement to accept service by Mr. Epstein's counsel, mooting any claim that he is unavailab

essions, the Motion in Limine to exclude the use of the designated portions of these depositions in toto must be granted. B. As a Retained Expert, Phillip Esplin Cannot Be Deemed Unavailable Plaintiff's argument concerning Phillip Esplin fails to acknowledge or even address the cases cited that require that

Ex. 1) June 24, 2016 Designated Testimony of Volume 2 September 8, 2016 Designated Testimony of VRS September 9, 2016 Designated Testimony of Jeffrey Epstein (Exs. 1-6, 8) November 18, 2016 Designated Testimony of Ross Gow (Exs. 1-26) December 1, 2016 Desi ated Testimon of Philli Es lin (Exs. 5-6, 9, 1

VRS, September 9, 2016 Exhibits 1-11 to Jeffrey Epstein Deposition November 14, 2016 Exhibits 1-20 to D

tion of VRS, September 9, 2016 Exhibits 1-11 to Jeffrey Epstein Deposition November 14, 2016 Exhibits 1

ember 22, 2016 Deposition of with Errata Sheet November 29, 2016 Deposition of November 30, 2016 Deposition of December 1, 2016 Deposition of Phillip Esplin December 2, 2016 Deposition of Gregory Taylor Index to BSF ShareFile Materials loaded on April 18-19 and April 23, 2019 EFTA00081371 FOIA CONFI

ed Testimony of Tony Figueroa Volume 2 September 8, 2016 Designated Testimony of Brittany Henderson (M) September 9, 2016 Designated Testimony of Jeffrey Epstein (Exs. 1-6, 8) November 18, 2016 Designated Testimony of Ross Gow (Exs. 1-26) December 1, 2016 Designated Testimony of (Exs. 5-6, 9, 14) January

rson September 9, 2016 Exhibits 1-11 to Jeffrey Epstein Deposition November 14, 2016 Exhibits 1-20 to D

ny Henderson September 9, 2016 Exhibits 1-11 to Jeffrey Epstein Deposition November 14, 2016 Exhibits 1

on with Errata Sheet November 29, 2016 Deposition of Peter Kent November 30, 2016 Deposition of Frederick Miller December 1, 2016 Deposition of Phillip Esplin December 2, 2016 Deposition of Gregory Taylor Index to BSF ShareFile Materials loaded on April 18-19 and April 23, 2019 EFTA00090987 FOIA CONFI

ny Henderson September 9, 2016 Exhibits 1-11 to Jeffrey Epstein Deposition November 14, 2016 Exhibits 1-20 to D

rson September 9, 2016 Exhibits 1-11 to Jeffrey Epstein Deposition November 14, 2016 Exhibits 1-20 to D

ny Henderson September 9, 2016 Exhibits 1-11 to Jeffrey Epstein Deposition November 14, 2016 Exhibits 1

on with Errata Sheet November 29, 2016 Deposition of Peter Kent November 30, 2016 Deposition of Frederick Miller December 1, 2016 Deposition of Phillip Esplin December 2, 2016 Deposition of Gregory Taylor Index to BSF ShareFile Materials loaded on April 18-19, 2019 EFTA00090984 FOIA CONFIDENTIAL TREAT