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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
s 13 just no reason we should be allowed to ask about all these 14 other bad acts. 15 Sack cites, your Honor, to an Eleventh Circuit case, 16 Schafer vs. Time, Inc. In that case, your Honor, Sack says the 17 Eleventh Circuit found the district court had been correct when 18 it ruled that the de
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
s 13 just no reason we should be allowed to ask about all these 14 other bad acts. 15 Sack cites, your Honor, to an Eleventh Circuit case, 16 Schafer vs. Time, Inc. In that case, your Honor, Sack says the 17 Eleventh Circuit found the district court had been correct when 18 it ruled that the de
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
now, that there is just no reason we should be allowed to ask about all these other bad acts. Sack cites, your Honor, to an Eleventh CircuLt case, Schafer vs. Time, Inc. In that case, your Honor, Sack says the Eleventh Circuit found the district court had been correct when it ruled that the defendant,
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 →eer reso sessment rere memeneistseee 13, 28 S.E.C. v. Collins & Aikman Corp., 256 F.R.D. 403, 412 (S.D.N-Y. 2009) oo. ceeeeeecesteeteeteeeeeeeees 19 Schafer v. Time, Inc., 142 F.3d 1361, 1364-75 (1 1th Cir. 1998) oo. eee ceseesseesseeeseeeseeeseeeneessaee 3 Seligson, Morris & Neuburger v Fairbanks Whitne
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 →V-00708-DN, 2015 WL 3533844, at *5 (D. Utah i eb) 13,28 S.E.C. v. Collins & Aikman Corp., 256 F.R.D. 403, 412 (S.D.N.Y. 2009) oo. cccccteeeseeeee 19 Schafer v. Time, Inc., 142 F.3d 1361, 1364-75 (11th Cir. 1998) oo ccceeeeeseteeteesetseteeteesenes 3 Seligson, Morris & Neuburger v Fairbanks Whitney Corp.,
Page: HOUSE_OVERSIGHT_014792 →Entities connected to both Alan Dershowitz and Schafer

Jeffrey Epstein
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
Bill Clinton
PERSONMaria Farmer
PERSON
Virginia Giuffre
PERSONthe Southern District
LOCATIONScott Rothstein
PERSON
Alfredo Rodriguez
PERSONJack Scarola
PERSON
David Boies
PERSONSigrid McCawley
PERSON
Al Gore
PERSON
Salt Lake City
LOCATION