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e that's at issue in this case, our client said, "Now her 6 story has grown and evolved, and she's included allegations 7 about world leaders and Alan Dershowitz, which he denies." We 8 can't just take that part out of her statement, that's what 9 Ms. Maxwell put in her statement. 10 And your Honor, what
at statement, 6 so there's no substantive evidence on that point that would be 7 coming in. 8 And the third category is with respect to 9 Mr. Dershowitz, who is on the defendant's witness list for 10 trial, and we have a few points there to raise. I mean, one is 11 obviously that if that were allo
included allegations 7 about world leaders and Alan Dershowitz, which he denies." We 8 can't just t
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
he one that's at issue in this case, our client said, "Now her story has grown and evolved, and she's included allegations about world leaders and Alan Dershowitz, which he denies." We can't just take that part out of her statement, that's what Ms. Maxwell put in her statement. And your Honor, what we will u
at statement, 6 so there's no substantive evidence on that point that would be 7 coming in. 8 And the third category is with respect to 9 Mr. Dershowitz, who is on the defendant's witness list for 10 trial, and we have a few points there to raise. I mean, one is 11 obviously that if that were allo
arate lawsuit that's spun out of this situation where Cassell and Edwards filed a defamation action in Florida State Court against Alan Dershowitz. Alan. Dershowitz then counterclaimed. That was litigated in Florida State Court for about a year. Ultimately, the parties settled their differences in
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
arate lawsuit that's spun out of this situation where Cassell and Edwards filed a defamation action in Florida State Court against Alan Dershowitz. Alan Dershowitz then counterclaimed. That was litigated in Florida State Court for about a year. Ultimately, the parties settled their differences in an undisclose
ere to make that statement, so there's no substantive evidence on that point that would be coming in. And the third category is with respect to Mr. Dershowitz, who is on the defendant's witness list for trial, and we have a few points there to raise. I mean, one is obviously that if that were allowed to c
e's included allegations about world leaders and Alan Dershowitz, which he denies." We can't just take
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
ll affect undersea exploration." The Times adds, "Alan E. Kohler, FBI assistant director for counterint
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
l affect undersea exploration." The Times adds, "Alan E. Kohler, FBI assistant director for counterint
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
ll affect undersea exploration." The limes adds, "Alan E. Kohler, FBI assistant director for counterint
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
ll affect undersea exploration." The Times adds, "Alan E. Kohler, FBI assistant director for counterint
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
ens armies 4 BE, Responses is Pnumersied Wiens 24 Bii06 crccsssceces zamsammmsnccmsemernsemmmeacesnnsacenem 6 1. Stories and allegations concerning Dershowitz, foreign presidents, and world leaders are highly relevant and admissible (Motion in Limine 1) .0...... ce ceeeeseeeseeeseeeseeeseeeneeesees 6 2. Me
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
esponses to Enumerated Motions 11 Limine ......ccccccccccccccceceteces cece cessecnseceseseenssssseensensees 6 1. Stories and allegations concerning Dershowitz, foreign presidents, and world leaders are highly relevant and admissible (Motion in Limine 1) ..00...0.. eee eceeeeeeeeeeeeeeteeneene 6 2. Meeting
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 Alan Dershowitz and Minemyer

Jeffrey Epstein
PERSONLeon Black
PERSON
Marc Rich
PERSON
Bradley Edwards
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
George W. Bush
PERSON
Paul Cassell
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Donald Trump
PERSON
Bill Clinton
PERSONMaria Farmer
PERSON
Joe Biden
PERSON
Virginia Giuffre
PERSON
Scarlett Johansson
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATION
George Mitchell
PERSON