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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
against 10 him, and what's at issue in this case is, again, Maxwell's 11 statements against my client. 12 The case that they cite actually, the Minemyer case, 13 goes against them. It actually talks about how you would have 14 to call the reporter, that that couldn't come into evidence. 15 And 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
y my client against him, and what's at issue in this case is, again, Maxwell's statements against my client. The case that they cite actually, the Minemyer case, goes against them. It actually talks about how you would have to call the reporter, that that couldn't come into evidence. And so, your Hono
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
by my client against him, and what's at issue in this case is, again, Maxwell's statements against my client. The case that they cite actually, the Minemyer case, goes against them. It actually talks about how you would have to call the reporter, that that couldn't come into evidence. And so, your Hono
Must Release Redacted Portions Of Mueller Report Before Election. • Intel Officials Urged Ratcliffe Not To Disclose Unverified Russian Claims About Clinton. • Andrew Weissmann Says He Hasn't Been Subpoenaed In Durham Probe. • FBI Releases Film On Chinese Spy Recruitment Threat. • FBI Says Risk Of Vote
kedown. FierceHealthcare <https://www. fiercehealthcare.com/payer/doj-charges-hundreds-connection-6b-healthcare- fraud-largest-takedown-ever> (9/30, Minemyer, 146K) reports, "The Department of Justice charged 345 people across 51 federal districts in the largest healthcare fraud takedown in the agency's h
Must Release Redacted Portions Of Mueller Report Before Election. • Intel Officials Urged Ratcliffe Not To Disclose Unverified Russian Claims About Clinton. • Andrew Weissmann Says He Hasn't Been Subpoenaed In Durham Probe. • FBI Releases Film On Chinese Spy Recruitment Threat. • FBI Says Risk Of Vote
mer UAW president Gary Jones has also been convicted. US Charges Hundreds In Connection With $6B Healthcare Fraud Takedown. FierceHealthcare (9/30, Minemyer, 146K) reports, "The Department of Justice charged 345 people across 51 federal districts in the largest healthcare fraud takedown in the agency's h
Must Release Redacted Portions Of Mueller Report Before Election. • Intel Officials Urged Ratcliffe Not To Disclose Unverified Russian Claims About Clinton. • Andrew Weissmann Says He Hasn't Been Subpoenaed In Durham Probe. • FBI Releases Film On Chinese Spy Recruitment Threat. • FBI Says Risk Of Vote
mer UAW president Gary Jones has also been convicted. US Charges Hundreds In Connection With $6B Healthcare Fraud Takedown. FierceHealthcare (9/30, Minemyer, 146K) reports, "The Department of Justice charged 345 people across 51 federal districts in the largest healthcare fraud takedown in the agency's
Must Release Redacted Portions Of Mueller Report Before Election. • Intel Officials Urged Ratcliffe Not To Disclose Unverified Russian Claims About Clinton. EFTA01658495 • Andrew Weissmann Says He Hasn't Been Subpoenaed In Durham Probe. • FBI Releases Film On Chinese Spy Recruitment Threat. • FBI Sa
mer UAW president Gary Jones has also been convicted. US Charges Hundreds In Connection With $6B Healthcare Fraud Takedown. FierceHealthcare (9/30, Minemyer, 146K) reports, "The Department of Justice charged 345 people across 51 federal districts in the largest healthcare fraud takedown in the agency's
ign presidents, and world leaders are highly relevant and admissible (Motion in Limine 1) .0...... ce ceeeeseeeseeeseeeseeeseeeneeesees 6 2. Meeting Bill Clinton at Jeffrey Epstein’s private island twice (Motion in Limine 2)..... 8 3. FOIA responses and related materials are admissible (Motion in Limine 3)....
Page: HOUSE_OVERSIGHT_011464 →eeseeeseeeseeeseeeseeeneeesees 6 2. Meeting Bill Clinton at Jeffrey Epstein’s private island twice (Motion
Page: HOUSE_OVERSIGHT_011464 →7 Mich. App. 1, 12, 602 N.W.2d 233, 239 (1999)... eee 13 Longmire v. Ala. State Univ., 151 F.R.D. 414, 419 (M.D.Ala. 1992)... cece ee eee ee ee eee 3 Minemyer v. R-Boc Representatives, Inc., No. 07 C 1763, 2012 WL 379904, at *4 (N.D. IIL Feb. 6, 2012) oo eeeeseseessesscssenecrscsecseesecsesessesesseseesses
Page: HOUSE_OVERSIGHT_011467 →Microsoft Word - 2017.03.16 Deft Resp IO to Ptfs Omnibus Motn in Limine (MASTER).docx
, foreign presidents, and world leaders are highly relevant and admissible (Motion in Limine 1) ..00...0.. eee eceeeeeeeeeeeeeeteeneene 6 2. Meeting Bill Clinton at Jeffrey Epstein’s private island twice (Motion in Limine 2)..... 8 FOIA responses and related materials are admissible (Motion in Limine 3)......
Page: HOUSE_OVERSIGHT_014789 →. eee eceeeeeeeeeeeeeeteeneene 6 2. Meeting Bill Clinton at Jeffrey Epstein’s private island twice (Motion
Page: HOUSE_OVERSIGHT_014789 →ss'n, 237 Mich. App. 1, 12, 602 N.W.2d 233, 239 (1999)... 13 Longmire v. Ala. State Univ., 151 F.R.D. 414, 419 (M.D.Ala. 1992). 000.00. cece cee ed Minemyer v. R-Boc Representatives, Inc., No. 07 C 1763, 2012 WL 379904, at *4 (N.D. ILL. Feb. 6, 2012) oe ceecceececcecccecceseeecesecsecseeceeeseesecseesaec
Page: HOUSE_OVERSIGHT_014792 →Entities connected to both Bill Clinton and Minemyer

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Donald Trump
PERSON
George W. Bush
PERSON
Hillary Clinton
PERSON
Barack Obama
PERSON
Alan Dershowitz
PERSON
Marc Rich
PERSONLeon Black
PERSON
United States
LOCATION
Department of Justice
ORGANIZATION
Julie K. Brown
PERSON
Joe Biden
PERSON
Bradley Edwards
PERSON
Virginia Giuffre
PERSONJane Doe
PERSON
Stephen Hawking
PERSONMaria Farmer
PERSON
George Mitchell
PERSON