Epstein Secrets

all documents and discussion of the Jane Doe 102 case, including the settlement of those claims (Motion in Limine 17) «0.0... eeeeeeeeees 26 18. The Cassell/Edwards v. Dershowitz litigation is relevant and admissible (Motion in Limine 18) oo. eeeesseesseceseesseesseceseesseesseceseesseeeseeeseeessesseessa

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

I electronically served this Defendant’s Response in Opposition to Plaintiff's Omnibus Motion In Limine via ECF on the following: Sigrid S. McCawley Paul G. Cassell Meredith Schultz 383 S. University Street BOIES, SCHILLER & FLEXNER, LLP Salt Lake City, UT 84112 401 East Las Olas Boulevard, Ste. 1200 P| Ft. Lau

ion in Limine 17) ................0005 26 18. The Cassell/Edwards v. Dershowitz litigation is relevant and

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

. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 [email protected] Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 [email protected] J. Stanley Pottinger 49 Twin Lakes Rd. South Salem, NY 10590 StanPottinger@

ntiff BY: SIGRID S. McCAWLEY, ESQ. 16 MEREDITH L. SCHULTZ, ESQ. 17 S.J. QUINNEY COLLEGE OF LAW AT THE UNIVERSITY OF UTAH For Plaintiff 18 BY: PAUL G. CASSELL, ESQ. 19 HADDON, MORGAN AND FOREMAN, P.C. Attorneys for Defendant 20 BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. 21 22 23 24 25

ive value that's past 8 sexual assault that Ms. experienced as a child is 9 completely swallowed by the prejudicial effect on the jury. 10 MR. CASSELL: Your Honor, I think I'm the next one up. 11 For purposes of clarity, we're up to point number 7 in our 12 omnibus motion. 13 This one I think

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

eys for Plaintiff BY: SIGRID S. McCAWLEY, ESQ. MEREDITH L. SCHULTZ, ESQ. S.J. QUINNEY COLLEGE OF LAW AT THE UNIVERSITY OF UTAH For Plaintiff BY: PAUL G. CASSELL, ESQ. HADDON, MORGAN AND FOREMAN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. SOUTHERN DISTRICT REPORTER

nestly be another mini trial and would take us far afield of what facts are relevant to this case. And again, any minor probative value that's MR. CASSELL: Your Honor, I think I'm the next one up. For purposes of clarity, we're up to point number 7 in our omnibus motion. This one I think is just a ve

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

ttorneys for Plaintiff BY: SIGRID S. McCAWLEY, ESQ. MEREDITH L. SCHULTZ, ESQ. S.J. QUINNEY COLLEGE OF LAW AT THE UNIVERSITY OF UTAH For Plaintiff BY: PAUL G. CASSELL, ESQ. HADDON, MORGAN AND FOREMAN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. SOUTHERN DISTRICT R (212) 805

tive value that's past sexual assault that Ms. Giuffre experienced as a child is completely swallowed by the prejudicial effect on the jury. r MR. CASSELL: Your Honor, I think I'm the next one up. For purposes of clarity, we're up to point number 7 in our omnibus motion. This one I think is just a ver

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