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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
which only 3 further substantiates Ms. testimony that at one point 4 she attempted to get away from defendant's abuse, along with -- 5 and Mr. Figueroa testified to the same. 6 So again, I would also reiterate that her reputation 7 as a child for being a truant or a runaway is not what is at 8
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
th, 2002, which only further substantiates Ms. testimony that at one point she attempted to get away from defendant's abuse, along with -- and Mr. Figueroa testified to the same. So again, I would also reiterate that her reputation as a child for being a truant or a runaway is not what is at issue in
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
which only further substantiates Ms. Giuffre's testimony that at one point she attempted to get away from defendant's abuse, along with -- and Mr. Figueroa testified to the same. So again, I would also reiterate that her reputation as a child for being a truant or a runaway is not what is at issue in t
..liti aca emia business and law inclu and Bill Clinton, attorney Alan Dershowitz, Duke of o her longst
olitico reported that axwell and E ste had friendships with several rominent individ elite circles of ..liti aca emia business and law inclu and Bill Clinton, attorney Alan Dershowitz, Duke of o her longstanding friendship1561 *th Prince Andre , and lot:paving escorted him to a " social functio • S
react to if'. He alleged the meeting had taken place in London. W223 In a court filing, Andrew's lawyers had previously referred to a statement by Figueroa's sister, Crystal Figueroa, who alleged that in her bid to find victims for Epstein, Giuffre bad asked her, "Do you know any girls who are kind of s
l abuse and prostitution.WILMAIIP) Epstein also maintained long-term relationships with various high-profile individuals, including Donald Wexner, Bill Clinton, Alan Dershowitz, an Duke of York. Contents Early life Career Jeffrey Epstein Epstein's final mugshot, 2019 Born Died Cause of death Resti
ofile individuals, including Donald Wexner, Bill Clinton, Alan Dershowitz, an Duke of York. Contents Ea
w to react to it". He alleged the meeting had taken place in London.= In a court filing, Andrew's lawyers had previously referred to a statement by Figueroa's sister, Crystal Figueroa, who alleged that in her bid to find victims for Epstein, Giuffre had asked her, "Do you know any girls who are kind of s
amous friends.= In February 2022, am.fr published a photograph o drew)along with kaxwell..kiving a tour of Buckingham Palace to Andrew's gues ill Clinto and Kevin Soca, with a member of the tour party descnbing Maxwell as "the one who led us into Buckingham Palace".11O-1— Tina Brown a journalist who
to react to it". He alleged the meeting had taken place in London.UJ In a court filing, Andrew's lawyers had previously referred to a statement by Figueroa's sister, Crystal Figueroa, who alleged that in her bid to find victims for Epstein, Giuffre had asked her, "Do you know any girls who are kind of s
part of the original group that conceived of the Clinton Global Initiative".(27§-1 Epstein co-organized a
w to react to it". He alleged the meeting had taken place in London.= In a court filing, Andrew's lawyers had previously referred to a statement by Figueroa's sister, Crystal Figueroa, who alleged that in her bid to find victims for Epstein, Giuffre had asked her, "Do you know any girls who are kind of s
want. Would 24 you like to do that? It's your right a 25 hundred percent. The court reporter can Page 468 1 BY MR. EDWARDS: 2 Q. During Mr. Clifton's questioning he asked 3 you about whether or not we had ever shown you a 4 previous taped statement that you had given to a 5 police officer,
came and found the old car in the driveway? 19 20 A. Exactly, yes, with the police, yes. 20 21 Q. How did you remember that it was Tony 21 22 Figueroa? 22 23 A. It's the only person, male that I 23 24 remember. 24 25 Q. But you don't know his name? 25 Page 445 alrie, I guess. was to help
Entities connected to both Bill Clinton and Figueroa

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Donald Trump
PERSON
George W. Bush
PERSON
Alan Dershowitz
PERSON
Marc Rich
PERSONLeon Black
PERSON
United States
LOCATION
Department of Justice
ORGANIZATION
Julie K. Brown
PERSON
Bradley Edwards
PERSON
Joe Biden
PERSON
Virginia Giuffre
PERSON
New York
LOCATION
John F. Kennedy
PERSONJane Doe
PERSON
Les Wexner
PERSON
Prince Charles
PERSON
Stephen Hawking
PERSON