Epstein Secrets

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. : 20 Cr. 330 (MN) x GHISLAINE MAXWELL'S MOTION IN LIMINE TO EXCLUDE GOVERNMENT EXHIBIT 52, AN UNAUTHENTICATED HEARSAY DOCU

RODUCTION I. The Document Cannot be Authenticated 3 II. The Document is Not a Business Record 4 EFTA00074469 TABLES OF AUTHORITIES Cases v. Maxwell, 325 F. Supp. 3d 428 (S.D.N.Y. 2018) 1 Missimer v. Tiger Machine Co., No. 04-3443, 2005 WL 3968133, at *2 (E.D.Pa. Sept. 28, 2005) 5 Palmer v.

AINE MAXWELL, Defendant. : 20 Cr. 330 (MN) x GHISLAINE MAXWELL'S MOTION IN LIMINE TO EXCLUDE GOVERNMENT EXHIBIT 5

iii EFTA00074471 Defendant Ghislaine Maxwell ("Ms. Maxwell") files this Motion in Limine to Exclude Governm

ieve we talked about a journal that you kept, and you looked for that? A. Yes, ma'am. Q. And you couldn't find it? A. I give it to Detective Joe. Q. Recarey? A. Yes, ma'am. Q. Where did you usually keep the journal with the names of the girls, in what part of the house? A. In the staff house. Q. Sorr

11 floor of the house. 12 Q. Did you ever see Ms. Maxwell taking 13 pictures of the girls? 14 A. No, ma'

w her doing that where were 9 they, the girls? 10 A. The dining room, the library, the first 11 floor of the house. 12 Q. Did you ever see Ms. Maxwell taking 13 pictures of the girls? 14 A. No, ma'am. 15 Q. Did you ever see Mr. Epstein taking 16 pictures of the girls? 17 A. No, ma'am. 18 Q

believe, yeah, I'm not 24 sure, ma'am. 25 BY MS. EZELL: Page 319 A. Yes, ma'am. Q. And you couldn't find it? A. I give it to Detective Joe. Q. Recarey? A. Yes, ma'am. Q. You mentioned that you called Mr. Jean-Luc Bernell about a recommendation when you were looking for a job. A. Yes, ma'am. Q.

A. Yes, ma'am. Q. Did any of those appear to be Ms. Maxwell? A. Yes, ma'am. Q. You mentioned that who was

3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 322 A. Yes, ma'am. Q. Did any of those appear to be Ms. Maxwell? A. Yes, ma'am. Q. You mentioned that who was still working there when you A. Yes, ma'am. Q. — was a very religious woman -- A. Yes, ma'am. Q.

8 7115 Rue Notre Dame, Miami Beach, FL 33141 EFTA00728192 Page 319 A. yes, ma'am. Q. And you couldn't find it? A. I give it to Detective Joe. Q. Recarey? A. Yes, ma'am. Q. You mentioned that you called Mr. can-Luc Bernell about a recommendation when you looking for a job. A. Yes, ma'am. Q. And d