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ible (Motion in Limine 18) oo. eeeesseesseceseesseesseceseesseesseceseesseeeseeeseeessesseessaeeseecseeesaeesaecsseesseeseeeeeeseessees 26 19. Judge Marra’s ruling is relevant and admissible (Motion in Limine 19)... eee 29 20. The transcript of the tape recording of Mr. Dershowitz’s conversation with R
Page: HOUSE_OVERSIGHT_011465 →eeseecseeesaeesaecsseesseeseeeeeeseessees 26 19. Judge Marra’s ruling is relevant and admissible (Motion in Li
Page: HOUSE_OVERSIGHT_011465 →g is relevant and admissible (Motion in Limine 19)... eee 29 20. The transcript of the tape recording of Mr. Dershowitz’s conversation with Rebecca Boylan is admissible (Motion 1n Limine 20)... ceececesessseeseeceeeeseeneeceseeseeneeeeeerseeeaees 31 C. Plaintiff's Remaining Motions In Limine Are Prematu
Page: HOUSE_OVERSIGHT_011465 →Microsoft Word - 2017.03.16 Deft Resp IO to Ptfs Omnibus Motn in Limine (MASTER).docx
and admissible (Motion in Limine 18) ooo... cecccecccccccccesscececsseececsseeeceseescesseesssueescnsssescesseessesssesensseeesssaeeess 26 19. Judge Marra’s ruling is relevant and admissible (Motion in Limine 19).................00. 29 20. The transcript of the tape recording of Mr. Dershowitz’s convers
Page: HOUSE_OVERSIGHT_014790 →sueescnsssescesseessesssesensseeesssaeeess 26 19. Judge Marra’s ruling is relevant and admissible (Motion in Li
Page: HOUSE_OVERSIGHT_014790 →nt and admissible (Motion in Limine 19).................00. 29 20. The transcript of the tape recording of Mr. Dershowitz’s conversation with Rebecca Boylan is admissible (Motion in Limine 20)... ccccccccccceceeceeeceseeesecneesseesteeesaeenes 31 C. Plaintiff's Remaining Motions In Limine Are Premature an
Page: HOUSE_OVERSIGHT_014790 →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
handling that. 5 This is essentially a hearsay exercise. We want information to 6 be excluded regarding Rebecca Boylan. Why? Because Rebecca 7 Boylan has not been deposed and is not going to be a witness in 8 the case. 9 As we understand what the defendant is planning to do, 10 she's planning
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
handling that. 5 This is essentially a hearsay exercise. We want information to 6 be excluded regarding Rebecca Boylan. Why? Because Rebecca 7 Boylan has not been deposed and is not going to be a witness in 8 the case. 9 As we understand what the defendant is planning to do, 10 she's planning
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
tness in the case. As we understand what the defendant is planning to do, she's planning to call Mr. Dershowitz. Mr. Dershowitz is going to say Ms. Boylan told him that Ms. Giuffre told him something, and so we have the classic hearsay within a hearsay situation. The problem, of course, is that Boylan
Entities connected to both Kenneth Marra and Boylan

Jeffrey Epstein
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Scarlett Johansson
PERSON
Paul Cassell
PERSON
United States
LOCATION
Alan Dershowitz
PERSONthe Southern District
LOCATIONLeon Black
PERSON
George W. Bush
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSONFBI
ORGANIZATION
Virginia Giuffre
PERSON
Donald Trump
PERSON
Salt Lake City
LOCATION
Bill Clinton
PERSONScott Rothstein
PERSON