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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
ipt, as you know. And in that 11 book manuscript, she describes that it was not her who took the 12 money from the tip jar, it was her boyfriend, Tony Figueroa, 13 and that's also what she testified during her deposition. 14 She said, for example, that she didn't commit the 15 theft, that he came in at
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
manuscript, as you know. And in that book manuscript, she describes that it was not her who took the money from the tip jar, it was her boyfriend, Tony Figueroa, and that's also what she testified during her deposition. She said, for example, that she didn't commit the theft, that he came in at the end of he
ell, indirectly, 9 I suppose you could say so. No, they'd never met. I 10 was at a dinner where I met Ted, but it wasn't -- I 11 was with President Clinton. President Clinton was my 12 friend, not Epstein's friend. 13 And Epstein had flown him and there was a 14 dinner and Ted came to the din
r where I met Ted, but it wasn't -- I 11 was with President Clinton. President Clinton was my 12 friend, not Epstein
, Tony, and then whoever 6 else underneath her. And that is how it started. 7 TODD BLANCHE: So before her -- 8 LEAH SAFFIAN: Tony Figueroa. 9 GHISLAINE MAXWELL: Tony Figueroa is her 10 boyfriend. 11 TODD BLANCHE: Before her -- so now going 12 back in the '90s. Yo
Entities connected to both Bill Clinton and Tony Figueroa

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Donald Trump
PERSON
George W. Bush
PERSON
Alan Dershowitz
PERSON
Marc Rich
PERSON
United States
LOCATION
Joe Biden
PERSON
Bradley Edwards
PERSON
Virginia Giuffre
PERSONJane Doe
PERSONMaria Farmer
PERSONthe Southern District
LOCATIONJack Goldberger
PERSON
Alexander Acosta
PERSON
Kenneth Marra
PERSON
Al Gore
PERSON
Alfredo Rodriguez
PERSON
Paul Cassell
PERSON