Epstein Secrets

F UTAH For Plaintiff BY: PAUL G. CASSELL, ESQ. FARMER, JAFFE, WEISSING, EDWARDS, FISTOS, LEHRMAN, P.L.

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

For Plaintiff 18 BY: PAUL G. CASSELL, ESQ. 19 FARMER, JAFFE, WEISSING, EDWARDS, FISTOS, LEHRMAN, P.L.

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

approved by all Plaintiffs' attorneys (including Maria Villafana, USAO) at the June 12, 2009 hearing wit

ected to past sexual history (whether consensual or by force such as molestation or rape), although Jane Does 2 through 7's psychiatrist expert Dr. Kliman, had Jane Does 2 through 7 complete detailed questionnaires including past sexual history and then interviewed them on tape about their past sexual

approved by all Plaintiffs' attorneys (including Maria Villafana, USAO) at the June 12, 2009 hearing wit

ected to past sexual history (whether consensual or by force such as molestation or rape), although Jane Does 2 through 7's psychiatrist expert Dr. Kliman, had Jane Does 2 through 7 complete detailed questionnaires including past sexual history and then interviewed them on tape about their past sexual

5-5202 Fax: 801-585-2750 [email protected] Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman 425

ny Records custodians necessary to authenticate business records under FRE 803(b) 27. Any witnesses necessary for impeachment or rebuttal 28. Dr. Kliman (expert) 29. Dr. Coonan (expert) 30. Jim Jansen (expert) 31. Chris Andersen (expert) 32. Bill Chandler (rebuttal expert) 33. Dianne Flores

as Olas Boulevard, Suite 1200 Ft. Lauderdale, FL 33301 Tel: Fax: University of Utah 383 University Street Salt Lake Cit , UT 84112 Tel: Fax: Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman 425 North Andrews Avenue, Suite 2 Ft. Lauderdale, FL 33301 Tel: Fax: 49 Twin Lakes Road South Salem

ny Records custodians necessary to authenticate business records under FRE 803(b) 27. Any witnesses necessary for impeachment or rebuttal 28. Dr. Kliman (expert) 29. Dr. Coonan (expert) 30. Jim Jansen (expert) 31. Chris Andersen (expert) 32. Bill Chandler (rebuttal expert) 33. Dianne Flores

00 Ft. Lauderdale FL 33301 Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L

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

. I 2009. Mai 31v n Lf (sEms) NOTARY PUBLIC/STATE OF FLORIDA i .• COMMLSSION NO.: • MY COMMISSIONnEtES: Wits tr °744 .t) :, My Owen DSO Maria 2010 • W. COMeeli Sfy..4°usoo..4bel 4?,?;: teCep ...... 09/12/2019 P CONFIDE CONFIDENTIAL Agency to Agency Requet: 19-011 SDNY_GM_00331981

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

Thomas 8am - DMV in St. Thomas 9am - Meeting at Maria Hodges office ( • ' • ) 10-11am - 6100 Red Hook

n can that circumstance be addressed by a motion such as the instant one.) 11. Next, Plaintiffs, Jane Does 2-8, attempt to use the Affidavit of Dr. Kliman for every motion for protective order/objection filed to date. This also includes the two most recent motions, which attempt to prevent Defendant's

Thomas 8am - DMV in St. Thomas 9am - Meeting at Maria Hodges office (1340 Taarneberg) 10-11am - 6100 Re

n can that circumstance be addressed by a motion such as the instant one.) 11. Next, Plaintiffs, Jane Does 2-8, attempt to use the Affidavit of Dr. Kliman for every motion for protective order/objection filed to date. This also includes the two most recent motions, which attempt to prevent Defendant's