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

no reason we should be allowed to ask about all these 14 other bad acts. 15 Sack cites, your Honor, to an Eleventh Circuit case, 16 Schafer vs. Time, Inc. In that case, your Honor, Sack says the 17 Eleventh Circuit found the district court had been correct when 18 it ruled that the defendant, which

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 reason we should be allowed to ask about all these 14 other bad acts. 15 Sack cites, your Honor, to an Eleventh Circuit case, 16 Schafer vs. Time, Inc. In that case, your Honor, Sack says the 17 Eleventh Circuit found the district court had been correct when 18 it ruled that the defendant, which

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

ere is just no reason we should be allowed to ask about all these other bad acts. Sack cites, your Honor, to an Eleventh CircuLt case, Schafer vs. Time, Inc. In that case, your Honor, Sack says the Eleventh Circuit found the district court had been correct when it ruled that the defendant, which allegedl

t organizations by the United States government. See Bohn II, 291 F.3d at 1002 (noting Hamas was designated a terrorist organization by President Clinton in 1995 and by the Sec- retary of State in 1997); see also Consoli- dated Plaintiffs Opp. to Prince Sultan's Motion to Dismiss at 16-17 (citing Pate

amas was designated a terrorist organization by President Clinton in 1995 and by the Sec- retary of State in 1997);

in intentional wrongdoing—albeit extraterri- torially—expressly directed at forum") (citing Calder v. Jones, 465 U.S. at 789-90, 104 S.Ct. 1482)); Time, Inc. v. Simpson, No. 02 Civ. 4917(MBM), 2003 WL 23018890, at *5 (S.D.N.Y. Dec. 22, 2003) (finding Calder turned on "personal in- volvement of the indiv

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)....

eeseeeseeeseeeseeeseeeneeesees 6 2. Meeting Bill Clinton at Jeffrey Epstein’s private island twice (Motion

essment rere memeneistseee 13, 28 S.E.C. v. Collins & Aikman Corp., 256 F.R.D. 403, 412 (S.D.N-Y. 2009) oo. ceeeeeecesteeteeteeeeeeeees 19 Schafer v. Time, Inc., 142 F.3d 1361, 1364-75 (1 1th Cir. 1998) oo. eee ceseesseesseeeseeeseeeseeeneessaee 3 Seligson, Morris & Neuburger v Fairbanks Whitney Corp., 257 N

, 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)......

. eee eceeeeeeeeeeeeeeteeneene 6 2. Meeting Bill Clinton at Jeffrey Epstein’s private island twice (Motion

2015 WL 3533844, at *5 (D. Utah i eb) 13,28 S.E.C. v. Collins & Aikman Corp., 256 F.R.D. 403, 412 (S.D.N.Y. 2009) oo. cccccteeeseeeee 19 Schafer v. Time, Inc., 142 F.3d 1361, 1364-75 (11th Cir. 1998) oo ccceeeeeseteeteesetseteeteesenes 3 Seligson, Morris & Neuburger v Fairbanks Whitney Corp., 257 N.Y.S.2d

rorist organizations by the United States government. See Bown I, 291 F.3d at 1002 (noting Hamas was designated a terrorist organization by President Clinton in 1995 and by the Sec- retary of State in 1997); see also Consoli- dated Plaintiffs’ Opp. to Prince Sultan’s Motion to Dismiss at 16-17 (citing Flat

Hamas was designated a terrorist organization by President Clinton in 1995 and by the Sec- retary of State in 1997);

nt in intentional wrongdoing—albeit extraterri- torially—expressly directed at forum”) (citing Calder v. Jones, 465 U.S. at 789-90, 104 S.Ct. 1482)); Time, Inc. v. Sumpson, No. 02 Civ. 49170MBM), 2003 WL 23018890, at *5 (S.D.N.Y. Dec. 22, 2003) (finding Calder turned on “personal in- volvement of the individu