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

4 THE COURT: And why do you have it in your expert's 15 report? 16 MS. SCHULTZ: Well, our expert is -- I'm assuming 17 you're referring to Dr. Kliman, who is a physician. He's a 18 medical doctor. He took a full -- 19 THE COURT: There's a whole thing about it. Are you 20 going to withdraw the

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

2 23 24 25 THE COURT: And why do you have it in your expert's report? MS. SCHULTZ: Well, our expert is -- I'm assuming you're referring to Dr. Kliman, who is a physician. He's a medical doctor. He took a full -- THE COURT: There's a whole thing about it. Are you going to withdraw the -- MS. SCHUL

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

reexisting. = THE COURT: And why do you have it in your expert's report? MS. SCHULTZ: Well, our expert is -- I'm assuming you're referring to Dr. Kliman, who is a physician. He's a medical doctor. He took a full -- THE COURT: There's a whole thing about it. Are you going to withdraw the -- MS. SCHUL

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

w information Plaintiff may present in her case-in-chief. Ms. Maxwell has filed well-founded motions in limine to exclude the testimony 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

24 BARNHART* MAZY. PA 2139 Pan lkoch Lain Boulew4 24 deposition room, he made facototace 4500151Ct IS West Pike Sack &tido 35405 25 with oar Clint He was just feet away from Page 3 Page 5 1 APPEARNCES CONTINUED... 1 her and intimidated ha, and for that reason 2 2 were not going forward.

me 50 plus visits to the Defendant's home prior to the time that she hired an attorney. Even in her interview with attorney's handpicked expert, Dr. Kliman, by her own comments, her significant emotional trauma relates to physical and verbal abuse by a prior boyfriend, Preston Vineyard, and deaths asso

edly become a child molester. During the Lewinsky-Clinton matter, Kliman was interviewed by Channel 12/20

heir real names would create a substantial risk to them of further psychological harm. See Exhibit "A", Declaration of Gilbert Kliman, M.D. 4. Dr. Kliman opines as follows: Releasing names of the plaintiffs to the public will reenact experiences of powerlessness and helplessness in the face of a boun