Epstein Secrets

nks, Chris EFTA00072826 Christian R Everdell COHEN & GRESSER LLP 800 Third Avenue New York NY 1002

ed, so in light of your email, attached is a draft short letter saying as much. We're happy to file if this works for you. On the timing of the 412/Daubert hearing, we're preparing a draft letter which we'll send you shortly. Thanks, From: Christian Everdell sti > Sent: Tuesday, November 2, 2021 5:15

ENCE RELATED TO ACCUSER-3 Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 100

sed" by Epstein, and Give the Jury an Appropriate Limiting Instruction 14 CONCLUSION 16 i EFTA00074480 TABLE OF AUTHORITIES Page(s) Cases Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993) 12 Esquivel-Quintana v. Sessions, 137 S. Ct. 1562 (2017) 14 Grunewald v. United State

draft it. Thanks, Chris Christian R Everdell COHEN & GRESSER LLP 800 Third Avenue New York. NY 100

ed, so in light of your email, attached is a draft short letter saying as much. We're happy to file if this works for you. On the timing of the 412/Daubert hearing, we're preparing a draft letter which we'll send you shortly. Thanks, From: Christian Everdell Sent: Tuesday, November 2, 2021 5:15 PM To

ENCE RELATED TO ACCUSER-3 Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menn

sed" by Epstein, and Give the Jury an Appropriate Limiting Instruction 14 CONCLUSION 16 i EFTA00087775 TABLE OF AUTHORITIES Page(s) Cases Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993) 12 Esquivel-Quintana v. Sessions, 137 S. Ct. 1562 (2017) 14 Grunewald v. United State

EMAN P.C. Denver Phone: Christian R. Everdell COHEN & GRESSER LLP New York NY Phone: Bobbi C. Stem

Cases Bosco v. United States, No. 14 CIV. 3525 (JFK), 2016 WL 5376205 (S.D.N.Y. Sept. 26, 2016)19 Cf. State v. Wigg, 889 A.2d 233 (Vt. 2005) 40 Daubert v. Merrell Dow Phanns., Inc., 509 U.S. 579 (1993) passim Dougherty v. County of Sttffolk,No. CV 13-6493 (AKT), 2018 WL 1902336 (E.D.N.Y. Apr. 20,

s she reckoned with the Court's findings regarding her offer to sign a so-called irrevocable waiver of her extradition rights. See United States v. Cohen, No. 10 Cr. 547 (SI), 2010 WL 5387757, at *9 n.I I (N.D. Cal. Dec. 20, 2010) ("Defendant's offers to turn in his passports, to 'renounce' his Israe

is also unacceptable because the courtroom has been, and will be, in frequent use, just as it was when the parties in this case met all day for the Daubert hearing and pretrial conference on February 4. The Court's calendar is also constantly shifting, meaning that the defense team will have little to n