Epstein Secrets

ion in March 2011. Constitutionally protected opinion. The United States Constitution and the New York Constitution renders opinion nonactionable. United Kingdom's Defamation Act of 2013. Mr. Barden prepared the January 2015 statement in compliance with the Defamation Act. To the extent the Act applies in this

ssary 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 (expert) Plaintiff reserv

ion in March 2011. Constitutionally protected opinion. The United States Constitution and the New York Constitution renders opinion nonactionable. United Kingdom's Defamation Act of 2013. Mr. Barden prepared the January 2015 statement in compliance with the Defamation Act. To the extent the Act applies in this

ssary 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 (expert) Plaintiff reserv

nduct, which will somehow prejudice the defendant. (Def. Mot. 4 at 13). The Court should not assume that the jury will speculate about principles of United Kingdom law and apply them to this case. The Court will properly instruct the jury on the elements of the offenses charged in the Indictment and the evidenc

s case, and evidence that adds context and dimension to the government's proof of the charges can have that tendency." Id.; accord United States v. Coonan, 938 F.2d 1553, 1561 (2d Cir. 1991). The Second Circuit has repeatedly held that actions and statements are admissible as direct evidence of the cri