Epstein Secrets

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

our Honor. The defendant's own expert report 3 described our client as a prostitute. Your Honor has under 4 advisement the expert report from Dr. Esplin, and so I deposed 5 Dr. Esplin, and I said, "Are you sure that's an accurate term 6 in the context of this case? Because we have a child who 7

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

No, your Honor. The defendant's own expert report described our client as a prostitute. Your Honor has under advisement the expert report from Dr. Esplin, and so I deposed Dr. Esplin, and I said, "Are you sure that's an accurate term in the context of this case? Because we have a child who cannot co

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

pen? No, your Honor. The defendant's own expert report described our client as a prostitute. Your Honor has under advisement th xpert report from Dr. Esplin, and so I deposed Dr. Esplin, and I said, "Are you sure that's an accurate term in the context of this case? Because we have a child who cannot co

at the same MAGNAO LEGAL SERVICES EFTA00595629 Page 43 1 - CONFIDENTIAL 2 THE WITNESS: I do remember having several 3 conversations about Bill Clinton and others. 4 BY MR. EDWARDS: 5 Q. What do you remember saying about Bill 6 Clinton? 7 A. They went on a trip to Africa with Kevin 8 Spac

I do remember having several 3 conversations about Bill Clinton and others. 4 BY MR. EDWARDS: 5 Q. What do you remember saying about Bill 6 Clinton? 7 A. They went on a trip to Africa with Kevin 8 Spacey and that it really -- there was nothing 9 specific about Bill Clinton other than I thi

timony of both Dr. Kliman and Professor Coonan prohibiting from providing their credibility and vouching opinions. This is the subject matter of Dr. Esplin's rebuttal report which explains that there is no reliable or scientific methodology by which an expert could reliably come to such opinions. Of co