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r filing. 6 But there are statements that are attributed to my 7 client in other articles and things. For example, there are 8 statements about Bill Clinton being on the island, and the 9 defense wants to bring in those statements to show that -- they 10 believe they can show evidence that he wasn't o
, as well. 19 So in our view, it's highly prejudicial under 403. 20 Those groupings should not come in. It should not be about, 21 for example, Clinton and whether or not he was on an island, or 22 Mr. Dershowitz or these other world leaders, it should be about 23 the defendant and her statements
hat she didn't have the 7 opportunity to depose President Clinton. Your Honor, 8 plaintiff's counsel sought to de
SCHILLER & FLEXNER LLP 15 Attorneys for Plaintiff BY: SIGRID S. McCAWLEY, ESQ. 16 MEREDITH L. SCHULTZ, ESQ. 17 S.J. QUINNEY COLLEGE OF LAW AT THE UNIVERSITY OF UTAH For Plaintiff 18 BY: PAUL G. CASSELL, ESQ. 19 HADDON, MORGAN AND FOREMAN, P.C. Attorneys for Defendant 20 BY: JEFFREY S. PAGLIUCA, ESQ. LAUR
s of her press complaint in the UK. Likewise, on the next page, your Honor, GM009, at the bottom, again, she specifically refutes the claims about Bill Clinton being on the island and says, "He was never there." Right after that, she says, " discussed that Al Gore and his wife Tipper were also guests on t
to my client, as well. So in our view, it's highly prejudicial under 403. Those groupings should not come in. It should not be about, for example, Clinton and whether or not he was on an island, or Mr. Dershowitz or these other world leaders, it should be about the defendant and her statements that my
s that she didn't have the opportunity to depose President Clinton. Your Honor, plaintiff's counsel sought to depos
NCES BOIES, SCHILLER & FLEXNER LLP Attorneys for Plaintiff BY: SIGRID S. McCAWLEY, ESQ. MEREDITH L. SCHULTZ, ESQ. S.J. QUINNEY COLLEGE OF LAW AT THE UNIVERSITY OF UTAH For Plaintiff BY: PAUL G. CASSELL, ESQ. HADDON, MORGAN AND FOREMAN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNING
d with, and that is motion in limine 2, which is Bill. Clinton being on the island. Ms. Maxwell is going to tes
to my client, as well. So in our view, it's highly prejudicial under 403. Those groupings should not come in. It should not be about, for example, Clinton and whether or not he was on an island, or Mr. Dershowitz or these other world leaders, it should be about the defendant and her statements that my
s that she didn't have the opportunity to depose President Clinton. Your Honor, plaintiff's counsel sought to depos
PEARANCES BOIES, SCHILLER & FLEXNER LLP Attorneys for Plaintiff BY: SIGRID S. McCAWLEY, ESQ. MEREDITH L. SCHULTZ, ESQ. S.J. QUINNEY COLLEGE OF LAW AT THE UNIVERSITY OF UTAH For Plaintiff BY: PAUL G. CASSELL, ESQ. HADDON, MORGAN AND FOREMAN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ES
e start that Epstein would spare no legal expense and that his team of veteran lawyers, whose cases ranged from O.J. Simpson to the investigation of Clinton's relationship with an intern, would play rough. When the Palm Beach police started to identify victims, according to Detective report, Dershowitz
n the same flights as underage girls. A high-profile trial threatened to splash mud over all sorts of big players, just as both Gov. Richardson and Bill Clinton's wife were runnin for resident. Also, a hedge fund prosecution in which Epstein offered to give evidence was heating up. , who was U.S. attorney gen
sults.aspx?NNumbei 909JE&x=15&y... 12/10/2010 EFTA01712000 3,c- as"— locro4a_.23.3 SAL • • • C EFTA01712001 S.J.QUINNEY • COLLEGE OF LAW THE UNIVERSITY OF UTAH March 1, 2011 Wifredo A. Ferrer United States Attorney Southern District of Florida 99 N.E.4th Street Miami, FL 33132 • • PAUL. G. CASSELL Ron
n the same flights as underage girls. A high-profile trial threatened to splash mud over ell sorts of big players, just as both Gov. Richardson and Bill Clinton's wife were running for president. Also, a hedge fund prosecution in which Epstein offered to give evidence was heating up. Alberto Gonzales, who was
e start that Epstein would spare no legal expense and that his team of veteran lawyers, whose cases ranged from O.J. Simpson to the investigation of Clinton's relationship with an intern, would play rough. When the Palm Beach police started to identify victims, according to Detective Joe Recarey's report
nquiry/NNum_Results.aspx?NNumbertxt=909JE&x=158cy... 12/10/2010 EFTA01688964 3i g^on- lotofra.-.23, sac sliC • • • C EFTA01688965 Tli . „, THE UNIVERSITY OF UTAH S.J. QUINNEY ) • COLLEGE OF LAW March 1, 2011 Wifredo A. Ferrer United States Attorney Southern District of Florida 99 N.E.4th Street Miami
Entities connected to both Bill Clinton and THE UNIVERSITY OF UTAH

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Donald Trump
PERSON
George W. Bush
PERSON
Alan Dershowitz
PERSON
Marc Rich
PERSONLeon Black
PERSON
United States
LOCATION
Department of Justice
ORGANIZATION
Bradley Edwards
PERSON
Joe Biden
PERSON
Virginia Giuffre
PERSON
New York
LOCATION
John F. Kennedy
PERSONJane Doe
PERSONMaria Farmer
PERSON
Eric Trump
PERSONthe Southern District
LOCATIONJack Goldberger
PERSON