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4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 was supposedly sent to plaintiff, the US attorney at the time, Mr. Acosta, also sent a letter saying that he believed it was preferable to have engaged in that kind of plea bargaining with Mr. Epstein because they had a r
that he was a victim instead. That's not the situation here. So this has all the components to warrant admission under 803(8). And one more point. Alex Acosta never said he didn't have enough evidence to convict Epstein. He said it was a risk to go to trial. Every trial is a risk, and a decision not to g
est is that today -- and today ends, for our joint effort, at 3:30 -- the defendant's motion with respect to the supplemental reports of Jansen and Kliman; the 302 motion; and there are three that seem to me to go together -- the references to the Florida action, the CVRA action; the Epstein plea agr
20 21 22 23 24 25 his that -- THE COURT: That's a whole different issue. Right? MR. PAGLIUCA: Yes. I agree. And finally, your Honor, on this Kliman issue, it seems to me that all of this is -- well, let me back up. Here are the reasons why it's prejudicial, and I don't think we can just say, t
REPORTERS, P.C. EFTA00592376 H3ulgiva 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 presentation in front of Kliman that he gets to then comment on. And so really what we're doing is we're trying to clean up the in-court testimony by an out-of-court statement to
EPORTERS, P.C. EFTA00794445 (212) 805-0300 EFTA00794446 41 H3ulgiva 1 was supposedly sent to plaintiff, the US attorney at the time, 2 Mr. Acosta, also sent a letter saying that he believed it was 3 preferable to have engaged in that kind of plea bargaining with 4 Mr. Epstein because they h
hat today -- and today 19 ends, for our joint effort, at 3:30 -- the defendant's motion 20 with respect to the supplemental reports of Jansen and Kliman; 21 the 302 motion; and there are three that seem to me to go 22 together -- the references to the Florida action, the CVRA 23 action; the Epst
8 H3ulgiva 1 his that 2 THE COURT: That's a whole different issue. Right? 3 MR. PAGLIUCA: Yes. I agree. 4 And finally, your Honor, on this Kliman issue, it 5 seems to me that all of this is -- well, let me back up. Here 6 are the reasons why it's prejudicial, and I don't think we can 7 ju
timony there's this staged SOUTHERN DISTRICT REPORTERS, P.C. EFTA00794381 (212) 805-0300 EFTA00794382 9 H3ulgiva 1 presentation in front of Kliman that he gets to then comment 2 on. And so really what we're doing is we're trying to clean up 3 the in-court testimony by an out-of-court stateme
01/003 F-849 THOMAS LOCI GER° BRALOW 400 N. Ashley Deve•Suite 1100•Tam a FL 33602 (Phone (Fax) Toll Free: • I . facsimile transmittal To: R. Alexander Acosin, Esq. Fax: Judith Stevenson Arco, Esq. Michael McAuliffe, Esq. Jack Alan Goldberger, Esq. Bradley J. Edwards, Esq. William J. Berger, Esq. Fro
Z.S. Mail; /Facsimile; O Overnight Delivery to R. Alexander Acosta, United States Attorney's Office - Southern Dist
/Facsimile; O Overnight Delivery to R. Alexander Acosta, United States Attorney's Office - Southern Dist
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
as a victim instead. 4 That's not the situation here. So this has all the components 5 to warrant admission under 803(8). 6 And one more point. Alex Acosta never said he didn't 7 have enough evidence to convict Epstein. He said it was a risk 8 to go to trial. Every trial is a risk, and a decision not
ission under 803(8). 6 And one more point. Alex Acosta never said he didn't 7 have enough evidence to
t, his arrest, neither of which mentioned plaintiff, 8 by the way, but they took those materials and gave them to 9 their psychiatric expert, Dr. Kliman, who made the video we 10 talked about earlier. Dr. Kliman also administered a number of 11 tests to plaintiffs to figure out whether she had any
RALOW 400 N. Ashley Driveo$Uite I I00•Tampa. FL 33602 813.984.3060 (Phone)s8I3-984-3070 (Fax) Toll Free: 866-395-7100 facsimile transmittal To: R. Alexander Acosta, Esq. Fax: (561) 820-8777 Judith Stevenson Arco, Esq. (561)355-7351 Michael McAuliffe, Esq. Jack Alan Goldberger, Esq. (561) 835-8691 Bradley
95-7100 facsimile transmittal To: R. Alexander Acosta, Esq. Fax: (561) 820-8777 Judith Stevenson Arc
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
Entities connected to both Alexander Acosta and Kliman

Jeffrey Epstein
PERSON
A. Marie Villafana
PERSON
United States
LOCATION
Kenneth Marra
PERSONLeon Black
PERSONthe Southern District
LOCATIONJack Goldberger
PERSONJane Doe
PERSON
Bradley Edwards
PERSONSouthern District
LOCATION
Prince Andrew
PERSON
George W. Bush
PERSONRoy Black
PERSON
Alan Dershowitz
PERSONRobert C. Josefsberg
PERSON
Ghislaine Maxwell
PERSONMartin Weinberg
PERSON
the United States District Court
ORGANIZATION
Paul Cassell
PERSON
Bill Clinton
PERSON