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14 Let me turn then to point number 19. Here again, we 15 have a narrow issue presented to your Honor. We are asking 16 that you exclude Judge Marra's ruling on the joinder motion. 17 As your Honor is well aware, the triggering event in this case 18 was when Ms. then known as Jane Doe Number
o your Honor. We are asking 16 that you exclude Judge Marra's ruling on the joinder motion. 17 As your Hono
t's defamation. 3 I'm going to move on to point number 9. Ms. 4 seeks to exclude any alleged criminal history from coming into 5 this case. And the Federal Rules of Evidence bar the 6 introduction of this evidence, full stop. 7 As the Court is aware, the only way criminal history 8 could come into evidence is through Rule 609
14 Let me turn then to point number 19. Here again, we 15 have a narrow issue presented to your Honor. We are asking 16 that you exclude Judge Marra's ruling on the joinder motion. 17 As your Honor is well aware, the triggering event in this case 18 was when Ms. , then known as Jane Doe Numbe
o your Honor. We are asking 16 that you exclude Judge Marra's ruling on the joinder motion. 17 As your Hono
defendant's defamation. I'm going to move on to point number 9. Ms. seeks to exclude any alleged criminal history from coming into this case. And the Federal Rules of Evidence bar the introduction of this evidence, full stop. As the Court is aware, the only criminal history could come into evidence is through Rule 609, but that
you already. Let me turn then to point number 19. Here again, we have a narrow issue presented to your Honor. We are asking that you exclude Judge Marra's ruling on the joinder motion. As your Honor is well aware, the triggering event in this case was when Ms. Giuffre, then known as Jane Doe Number 3,
ed to your Honor. We are asking that you exclude Judge Marra's ruling on the joinder motion. As your Honor is
ant's defamation. I'm going to move on to point number 9. Ms. Giuffre seeks to exclude any alleged criminal history from coming into this case. And the Federal Rules of Evidence bar the introduction of this evidence, full stop. As the Court is aware, the only way criminal history could come into evidence is through Rule 609, but th
Entities connected to both Kenneth Marra and the Federal Rules of Evidence bar the

Jeffrey Epstein
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Paul Cassell
PERSON
Alan Dershowitz
PERSONthe Southern District
LOCATION
George W. Bush
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Virginia Giuffre
PERSON
Bill Clinton
PERSONScott Rothstein
PERSONJack Scarola
PERSON
Alfredo Rodriguez
PERSON
Al Gore
PERSON
David Boies
PERSON
Bernie Sanders
PERSON
Colorado
LOCATIONSigrid McCawley
PERSONEleventh Circuit
ORGANIZATION