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Prince Andrew, and it's actually not his denial, as I 24 understand it, Buckingham Palace's denial of the allegation of 25 my client. But again, Prince Andrew is not on the witness SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00794570 16 H3V0GIU1 1 list, we're not able to cross examine him,
U1 1 list, we're not able to cross examine him, so what they want to 2 do is introduce triple hearsay of Buckingham Palace saying what 3 Prince Andrews said in a news article without the reporter 4 against my client without our ability to cross examine him on 5 that. 6 So your Honor, they've tr
who has put her reputation 14 at issue. Having the Duke of York and Buckingham Palace issue 15 denials is not h
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
ld not be an issue relevant to this trial. Next, your Honor, they also seek to include statements, hearsay statements and newspaper articles about Prince Andrew, and it's actually not his denial, as I understand it, Buckingham Palace's denial of the allegation of my client. But again, Prince Andrew is not o
3VOGIU1 16 list, we're not able to cross examine him, so what they want to do is introduce triple hearsay of Buckingham Palace saying what Prince Andrews said in a news article without the reporter against my client without our ability to cross examine him on that. So your Honor, they've tried to ar
rse, who has put her reputation at issue. Having the Duke of York and Buckingham Palace issue denials is not hears
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
s about Prince Andrew, and it's actually not his denial, as I understand it, Buckingham Palace's denial of the allegation of my client. But again, Prince Andrew is not on the witness SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011318 10 id. 12 13 14 L5 16 ne) 18 life) 20 21
16 H3VOGIU1 list, we're not able to cross examine him, so what they want to do is introduce triple hearsay of Buckingham Palace saying what Prince Andrews said in a news article without the reporter against my client without our ability to cross examine him on that. So your Honor, they've tried to argu
rse, who has put her reputation at issue. Having the Duke of York and Buckingham Palace issue denials is not hearsa
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
close Unverified Russian Claims About Clinton. • Andrew Weissmann Says He Hasn't Been Subpoenaed In Durha
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
close Unverified Russian Claims About Clinton. • Andrew Weissmann Says He Hasn't Been Subpoenaed In Durha
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
close Unverified Russian Claims About Clinton. • Andrew Weissmann Says He Hasn't Been Subpoenaed In Durha
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
d Russian Claims About Clinton. EFTA01658495 • Andrew Weissmann Says He Hasn't Been Subpoenaed In Durha
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
admissible (Motion in Limine 3).................+ 8 4. Louis Freeh’s testimony and report are admissible evidence (Motion in Limine 4) ....... 9 5. Prince Andrew and Buckingham Palace’s denials of Plaintiff's claims are not offered for the truth of the matter asserted (Motion in Limine 5)... i.e seeeesseeseere
Page: HOUSE_OVERSIGHT_011464 →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
Page: HOUSE_OVERSIGHT_011467 →Microsoft Word - 2017.03.16 Deft Resp IO to Ptfs Omnibus Motn in Limine (MASTER).docx
sible evidence (Motion in Limine 4) ....... 9 5. Prince Andrew and Buckingham Palace’s denials of Plaintiff's cl
Page: HOUSE_OVERSIGHT_014789 →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
Page: HOUSE_OVERSIGHT_014792 →Entities connected to both Prince Andrew and Minemyer

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Marc Rich
PERSONLeon Black
PERSON
Department of Justice
ORGANIZATION
Donald Trump
PERSON
Bill Clinton
PERSON
Alan Dershowitz
PERSON
United States
LOCATION
George W. Bush
PERSON
Michael Cohen
PERSONthe Southern District
LOCATION
Virginia Giuffre
PERSON
Bradley Edwards
PERSON
Joe Biden
PERSON
Stephen Hawking
PERSON
George Mitchell
PERSON
Julie K. Brown
PERSONMaria Farmer
PERSON
Geoffrey S. Berman
PERSON