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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
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
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
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 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
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
ar: They can't." INTERNATIONAL RELATIONS Prince Andrew Sued By Epstein Accuser Over Alleged Sexual Abuse. Reuters (8/9, Stempel) reports Britain's Prince Andrew was sued 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 fin
ts Of Accused. INTERNATIONAL RELATIONS • Prince Andrew Sued By Epstein Accuser Over Alleged Sexual Abuse
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
ll Letter NBC News (07/04, Reilly) reported that Andrew Floyd, a federal prosecutor, was fired by Attorne
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
wn sake, as noted by scholar EFTA01655952 Marc-Andre Argentino. The article stated that the introducti
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,
ction for its own sake, as noted by scholar Marc-Andre Argentino. The article stated that the introducti
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,
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 →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
Page: HOUSE_OVERSIGHT_011465 →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 →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
Page: HOUSE_OVERSIGHT_014790 →Entities connected to both Prince Andrew and Boylan

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
Woody Allen
PERSON
Virginia Giuffre
PERSON
Bradley Edwards
PERSON
Prince Charles
PERSON
Joe Biden
PERSON
Stephen Hawking
PERSONMaria Farmer
PERSONFBI
ORGANIZATION