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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
at entire time. 20 It got quashed because it had been such a long passage of time. 21 THE COURT: Who was the employer? 22 MS. MENNINGER: It was the Roadhouse Grill, your 23 Honor. It was a burger joint. And she was working at that 24 Roadhouse Grill in March of 2002 during the period of time she 25 claims
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
try during that entire time. It got quashed because it had been such a long passage of time. THE COURT: Who was the employer? MS. MENNINGER: It was the Roadhouse Grill, your Honor. It was a burger joint. And she was working at that Roadhouse Grill in March of 2002 during the period of time she claims that she was
ing but not limited to, funding received from the Clinton Global Initiative, the Clinton Foundation (a/k/a
Global Initiative, the Clinton Foundation (a/k/a William J. Clinton Foundation, a/lc/a/ the Bill, Hilary & Chelsea C
g any alleged illegal activity involving Plaintiff from the Relevant Period. This request includes, but is not limited to, any documents concerning the Roadhouse Grill in Florida. RESPONSE: Ms. Maxwell objects to this Request as vague and confusing. Ms. Maxwell is unaware of all illegal activities in which Plainti
Entities connected to both Bill Clinton and the Roadhouse Grill

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
George W. Bush
PERSON
Alan Dershowitz
PERSON
Bradley Edwards
PERSON
Virginia Giuffre
PERSONJane Doe
PERSONthe Southern District
LOCATION
Kenneth Marra
PERSON
Al Gore
PERSON
Alfredo Rodriguez
PERSON
Paul Cassell
PERSON
Colorado
LOCATION
Robert Mueller
PERSONScott Rothstein
PERSON
Bernie Sanders
PERSON
David Boies
PERSONJack Scarola
PERSONSigrid McCawley
PERSON