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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
o the back 21 and forth because we think it's irrelevant. 22 But if there was to be some kind of an attack launched 23 on any of the members of the Boies Schiller Firm, of Brad 24 Edwards, myself, we would ask that we be given leave to address 25 that at sidebar, in-camera, or outside the presence of the jury S
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
t to get into the back and forth because we think it's irrelevant. But if there was to be some kind of an attack launched on any of the members of the Boies Schiller Firm, of Brad Edwards, myself, we would ask that we be given leave to address that at sidebar, in-camera, or outside the presence of the jury SOUTHERN
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
t to get into the back and forth because we think it's irrelevant. But if there was to be some kind of an attack launched on any of the members of the Boies Schiller Firm, of Brad Edwards, myself, we would ask that we be given leave to address that at sidebar, in-camera, or outside the presence of the jury SOUTHERN
Entities connected to both Bill Clinton and the Boies Schiller Firm

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