Epstein Secrets

annot be met with respect to Mr. Rodriguez's deposition testimony. Indeed, the Plaintiff's Motions to Exclude Designation of Depositions Excerpts of Alan Dershowitz and Plaintiff argued this precise point. Ms. Maxwell was not a party to any of the litigations in which Mr. Rodriguez was deposed; Ms. Maxwell was

clude Designation of Depositions Excerpts of Alan Dershowitz and Plaintiff argued this precise point. Ms. Max

to Exclude Designation of Depositions Excerpts of Alan Dershowitz and Plaintiff argued this precise poi

essions, the Motion in Limine to exclude the use of the designated portions of these depositions in toto must be granted. B. As a Retained Expert, Phillip Esplin Cannot Be Deemed Unavailable Plaintiff's argument concerning Phillip Esplin fails to acknowledge or even address the cases cited that require that

n Testimony and Exhibits) August 7, 2009 Designated Testimony of July 29, 2009 Designated Testimony of October 15, 2015 Designated Testimony of Alan Dershowitz October 16, 2015 Designated Testimony of Alan Dershowitz January 12, 2016 Designated Testimony of Alan Dershowitz January 16, 2016 Designated T

f October 15, 2015 Designated Testimony of Alan Dershowitz October 16, 2015 Designated Testimony of Alan D

ony of October 15, 2015 Designated Testimony of Alan Dershowitz October 16, 2015 Designated Testimon

ember 22, 2016 Deposition of with Errata Sheet November 29, 2016 Deposition of November 30, 2016 Deposition of December 1, 2016 Deposition of Phillip Esplin December 2, 2016 Deposition of Gregory Taylor Index to BSF ShareFile Materials loaded on April 18-19 and April 23, 2019 EFTA00081371 FOIA CONFI

n Testimony and Exhibits) August 7, 2009 Designated Testimony of July 29, 2009 Designated Testimony of October 15, 2015 Designated Testimony of Alan Dershowitz October 16, 2015 Designated Testimony of Alan Dershowitz January 12, 2016 Designated Testimony of Alan Dershowitz January 16, 2016 Designated T

f October 15, 2015 Designated Testimony of Alan Dershowitz October 16, 2015 Designated Testimony of Alan D

ony of October 15, 2015 Designated Testimony of Alan Dershowitz October 16, 2015 Designated Testimon

on with Errata Sheet November 29, 2016 Deposition of Peter Kent November 30, 2016 Deposition of Frederick Miller December 1, 2016 Deposition of Phillip Esplin December 2, 2016 Deposition of Gregory Taylor Index to BSF ShareFile Materials loaded on April 18-19 and April 23, 2019 EFTA00090987 FOIA CONFI

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

H3V0GIU1 1 these other things that are circulating about her that have 2 nothing to do with Ms. Maxwell. 3 Mr. Cassell referred to our expert Phillip Esplin, 4 Dr. Esplin, and saying that he agreed not to refer to 5 as a prostitute. Your Honor, that came up in the 6 context of a cross examination in

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

VOGIU1 53 1 these other things that are circulating about her that have 2 nothing to do with Ms. Maxwell. 3 Mr. Cassell referred to our expert Phillip Esplin, 4 Dr. Esplin, and saying that he agreed not to refer to 5 s a prostitute. Your Honor, that came up in the 6 context of a cross examination in

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

24 25 53 H3VOGIU1 these other things that are circulating about her that have nothing to do with Ms. Maxwell. Mr. Cassell referred to our expert Phillip Esplin, Dr. Esplin, and saying that he agreed not to refer to Virginia Roberts as a prostitute. Your Honor, that came up in the context of a cross examina