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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
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
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
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
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
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
he process endanger Democratic lawmakers seeking reelection. INTERNATIONAL NEWS Canada Opens Border To Fully Vaccinated Americans. Politico (8/9, Allan, 6.73M) reports Canada "opened to fully vaccinated Americans on Monday, increasing pressure on the Biden administration to respond in kind to its no
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
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 →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
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 →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 Alan Dershowitz and Boylan

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
Woody Allen
PERSON
Joe Biden
PERSON
Virginia Giuffre
PERSON
Scarlett Johansson
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATION