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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
that overview. 2 They reference Mueller and Kirkpatrick, a treatise 3 that we think is very instructive on this particular point. 4 Mueller and Kirkpatrick says, "It is true that in a 5 defamation case there is more latitude to introducing 6 reputational types of evidence. However, it's important to
UTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00794625 71 H3V0GIU1 1 so let meet respond to that overview. 2 They reference Mueller and Kirkpatrick, a treatise 3 that we think is very instructive on this particular point. 4 Mueller and Kirkpatrick says, "It is true that in a 5 defamation ca
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
spond to that overview. They reference Mueller and Kirkpatrick, a treatise that we think is very instructive on this particular point. Mueller and Kirkpatrick says, "It is true that in a defamation case there is more latitude to introducing reputational types of evidence. However, it's important to remem
7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 H3V0GIU1 -1 so let meet respond to that overview. They reference Mueller and Kirkpatrick, a treatise that we think is very instructive on this particular point. Mueller and Kirkpatrick says, "It is true that in a defamation case there
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
10 id. 12 13 14 L5 16 ne) 18 life) 20 21 22 23 24 25 val H3VOGIU1 so let meet respond to that overview. They reference Mueller and Kirkpatrick, a treatise that we think is very instructive on this particular point. Mueller and Kirkpatrick says, "It is true that ina defamation case there i
spond to that overview. They reference Mueller and Kirkpatrick, a treatise that we think is very instructive on this particular point. Mueller and Kirkpatrick says, "It is true that ina defamation case there is more latitude to introducing reputational types of evidence. However, it's important to rememb
IAL EFTA00225418 EXHIBITS TO WRITTEN RESPONSE OF A. MARIE VILLAFANA Exhibit 41 Date Description 33 7/6/2007 Letter from Gerald l.efcourt and Alan Dershonia toJeffrey Sloman and Andrei Londe arguing against federal prosecution. 34 7/13/2007 Letter from Roy Black to Marie Villa' la with handwritten atto
to subpoenas requested by Lilly Ann Sanchez and possible resolution of case 7/6/2007 Jeffrey Sloman and Andrew Lourie Gerald B. Lefcourt and Alan Dershowitz Follow-up letter to 6/26/07 meeting including facts, law, and policy that should inform any decision made on how and whether to proceed 33 7/13/2
07 Plea Notification Letter B-2 11/23/2007 Unscheduled meeting between Jay Lefkowitz, Alan Dershowitz and Jeff Sloman. (Drop in by Lefkowitz and Dershowitz) 11/26/2007 Jason Richards PBSO D/S Harold Elliott Research re work release: PBSO Post Orders for the Work Release Program Privileged Confidenti
n 33 7/6/2007 Letter from Gerald l.efcourt and Alan Dershonia toJeffrey Sloman and Andrei Londe argu
s advice on some of the issues — legal and non-legal — that arose during the case. Assistant U.S. Attorney Lynn Kirkpatrick (still at the USAO): Ms. Kirkpatrick and I are friends from my time in Miami. She was a supervisor in Miami although not in my chain of command. I would often speak or email with her j
school bus Donald J. Trump, Prince Andrew. Alan Dershowitz. Lady Victoria Hervey, Leslie & Abigail Weiner.
t by school bus Donald J. Trump, Prince Andrew. Alan Dershowitz. Lady Victoria Hervey, Leslie & Abig
pstein II> BREAKING • bµ+y Epstein accuser' wys she has just days left to live sifter getting hit by school bus Donald J. Trump, Prince Andrew. Alan Dershowitz. Lady Victoria Hervey, Leslie & Abigail Weiner. -----,--George B. Tonks, Eileen Guggenheim, Glenn & Eva Dubin. Richard Branson. the Maxwell's.
inwir mow oor. eft • fa., P./.70. C on duo, i C4, 1 tatea, Ca.d 1 • WG ma. 0 0 V EFTA01653062 r AciNes: UDCW PACTSS: be a liar. and Mr. Kirkpatrick have reported they are fearful of Mr. Tonks sha vale emails, recorded phone calls, and other personal information about her and other alh :tims rel
By Richard Eden for The Daily Mail 18:50 EDT 15 Sep 2023 . updated 08:43 EDT 16 Sep 2023 George B... BREAKING: Donald J. Trump. Prince Andrew. Alan Dershowitz. Lady Victoria Hervey, Leslie & Abigail Wexner, _______George B. Tot. Eileen Guggenheim, Glenn & Eva Dubin, Richard Branson. the Maxwell's. FB
ly stood up to criminals. I AM IN THE MOST AWFUL POSITION be you placed me here. You used my name for publicity and as fuel in a public feud against Dershowitz. Then you abandoned me with Dershowitz and no compensation!!! YOU KNOW I CANNOT AFFORD CANCER SURGERY and will be forced to sell my home in the wors
B... BREAKING: Donald J. Trump. Prince Andrew. Alan Dershowitz. Lady Victoria Hervey, Leslie & Abig
0 . CO co CD = cD CD CD r -t- —Pt —3 CD 5 • CD CD UZI —3 7-t: CD —3 B 0 r Acel No: I :23CRi PAC ISo be a liar. Ms. nd Mr. Kirkpatrick have reported they arc fearful of Mr. Tonks sit vate emails, recorded phone calls, and other personal information about her and other alb ;tims rel
%vir BREAKING: Virginia Giuffre killed Virginia Giuffre! THEORISTS WHO ARE NOW EXPERTS ON VIRGINIA GIUFFRE Donald J. Trump, Prince Andrew, -Alan Dershowitz, Lady Victoria Hervey, Leslie & Abigail Wexner, George B. Tonks, Eileen Guggenheim. Glenn & Eva Dubin, Richard Branson. the Maxwell's, FBI, MI
RGINIA GIUFFRE Donald J. Trump, Prince Andrew, -Alan Dershowitz, Lady Victoria Hervey, Leslie & Abigail Wexner,
RGINIA GIUFFRE Donald J. Trump, Prince Andrew, -Alan Dershowitz, Lady Victoria Hervey, Leslie & Abig
r f-•• t-4- O r * CO CD - 3 co CD = = r-P - 3 a CD C) CD CI) CD O Cam' CD C1=1 O) O PACTS*: be a liar. Ms. Farmer and Mr. Kirkpatrick have reported they are fearful of Mr. I shz vale emails, recorded phone calls, and other personal information about her and other alli tims relate
Entities connected to both Alan Dershowitz and Kirkpatrick

Jeffrey Epstein
PERSONLeon Black
PERSON
Marc Rich
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Lesley Groff
PERSON
United States
LOCATION
George W. Bush
PERSON
Paul Cassell
PERSON
Richard Kahn
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Donald Trump
PERSON
Bill Clinton
PERSONMartin Weinberg
PERSONMaria Farmer
PERSON
Woody Allen
PERSON
Joe Biden
PERSON