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vidual witnesses with knowledge regarding the facts of this case, yet provided addresses (only of their counsel) as to just two, Jeffrey Epstein and Alan Dershowitz. Plaintiff then also listed categories of witnesses such as "all other then-minor girls, whose identities Plaintiff will attempt to determine" and "
ounsel) as to just two, Jeffrey Epstein and Alan Dershowitz. Plaintiff then also listed categories of witness
heir counsel) as to just two, Jeffrey Epstein and Alan Dershowitz. Plaintiff then also listed categorie
) 19 Grochowski v. Phoenix Const., 318 F.3d 80, 86 (2d Cir.2003). 5 lantosca v. Benistar Admin. Svcs., Inc., 765 F.Supp.2d 79 (D. Mass. 2011) 6 LiButti v. United States, 107 F.3d 110, 121 (2d Cir. 1997) 16 Murphy v. Board of Educ., 196 F.R.D. 220, 222 (W.D.N.Y.2000) 19 Perfect Pearl Co., Inc. v
18 view as sort of indicia of she should have known about what's 19 in these police reports, and they first of all say -- we get 20 back to this Dershowitz joint defense agreement issue, which I 21 touched on yesterday, but you're going to hear it again today, 22 so I think it's worth mentioning agai
nswer the question if it's not privileged." That's the 9 testimony that they say supports their assertion of this joint 10 defense agreement with Alan Dershowitz. 11 But there's more, your Honor. Mr. Edwards -- again, 12 who is a party in this deposition and not a lawyer -- chimes in 13 to the special ma
sertion of this joint 10 defense agreement with Alan Dershowitz. 11 But there's more, your Honor. Mr
ing to conceal that from the jury or are we going to present 7 it to them? Well, the Second Circuit case that your Honor is 8 well familiar with, LiButti, sets out the factors that have 9 determined that issue, and one of the things we hear from the 10 defendant is, oh, it's never been applied in a
what they view as sort of indicia of she should have known about what's in these police reports, and they first of all say -- we get back to this Dershowitz joint defense agreement issue, which I touched on yesterday, but you're going to hear it again today, so I think it's worth mentioning again. And h
nswer the question if it's not privileged." That's the 9 testimony that they say supports their assertion of this joint 10 defense agreement with Alan Dershowitz. 11 But there's more, your Honor. Mr. Edwards -- again, 12 who is a party in this deposition and not a lawyer -- chimes in 13 to the special ma
sertion of this joint 10 defense agreement with Alan Dershowitz. 11 But there's more, your Honor. Mr
we going to conceal that from the jury or are we going to present it to them? Well, the Second Circuit case that your Honor is well familiar with, LiButti, sets out the factors that have determined that issue, and one of the things we hear from the defendant is, oh, it's never been applied in a case l
what they view as sort of indicia of she should have known about what's in these police reports, and they first of all say -- we get back to this Dershowitz joint defense agreement issue, which I touched on yesterday, but you're going to hear it again today, so I think it's worth mentioning again. And her
py to answer the question if it's not privileged." That's the testimony that they say supports their assertion of this joint defense agreement with Alan Dershowitz. But there's more, your Honor. Mr. Edwards -- again, who is a party in this deposition and not a lawyer -- chimes in to the special master and Mr.
r assertion of this joint defense agreement with Alan Dershowitz. But there's more, your Honor. Mr. Ed
we going to conceal that from the jury or are we going to present it to them? Well, the Second Circuit case that your Honor is well familiar with, LiButti, sets out the factors that have determined that issue, and one of the things we hear from the defendant is, oh, it's never been applied in a case l
Entities connected to both Alan Dershowitz and LiButti

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Lesley Groff
PERSON
United States
LOCATION
Paul Cassell
PERSONMaria Farmer
PERSONSouthern District
LOCATION
Virginia Giuffre
PERSONthe Southern District
LOCATION
New York
LOCATIONScott Rothstein
PERSON
Jean-Luc Brunel
PERSON
Wilbur Ross
PERSON
Bill Richardson
PERSON
David Boies
PERSON
Sergey Brin
PERSONSigrid McCawley
PERSON