Epstein Secrets

t Of Motion In Limine To Exclude In Toto Certain Depositions Designated By Plaintiff For Use At Trial via ECF on the following: Sigrid S. McCawley Paul G. Cassell Meredith Schultz 383 S. University Street BOLES, SCHILLER & FLEXNER, LLP Salt Lake it UT 4112 401 East Las Olas Boulevard, Ste. 1200 Ft. Laude

CF on the following: Sigrid S. McCawley Paul G. Cassell Meredith Schultz 383 S. University Street BOLE

essions, the Motion in Limine to exclude the use of the designated portions of these depositions in toto must be granted. B. As a Retained Expert, Phillip Esplin Cannot Be Deemed Unavailable Plaintiff's argument concerning Phillip Esplin fails to acknowledge or even address the cases cited that require that

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

H3V0GIU1 1 these other things that are circulating about her that have 2 nothing to do with Ms. Maxwell. 3 Mr. Cassell referred to our expert Phillip Esplin, 4 Dr. Esplin, and saying that he agreed not to refer to 5 as a prostitute. Your Honor, that came up in the 6 context of a cross examination in

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

VOGIU1 53 1 these other things that are circulating about her that have 2 nothing to do with Ms. Maxwell. 3 Mr. Cassell referred to our expert Phillip Esplin, 4 Dr. Esplin, and saying that he agreed not to refer to 5 s a prostitute. Your Honor, that came up in the 6 context of a cross examination in

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

24 25 53 H3VOGIU1 these other things that are circulating about her that have nothing to do with Ms. Maxwell. Mr. Cassell referred to our expert Phillip Esplin, Dr. Esplin, and saying that he agreed not to refer to Virginia Roberts as a prostitute. Your Honor, that came up in the context of a cross examina

s and Responses (served) PRODUCTIONS Plaintiff's Production 000001 009349 Defendant's Productions MAXWELL 00001 01364 Non-Party Productions CASSELL 000001 014402 MAR-A-LAGO 0001 0607 000001 000558 RG(UK) 000001 000009 VICTIMS_REFUSE_SILENCE 0001 0091 Transcripts (ALL) April 22, 2016

ember 22, 2016 Deposition of with Errata Sheet November 29, 2016 Deposition of November 30, 2016 Deposition of December 1, 2016 Deposition of Phillip Esplin December 2, 2016 Deposition of Gregory Taylor Index to BSF ShareFile Materials loaded on April 18-19 and April 23, 2019 EFTA00081371 FOIA CONFI

s and Responses (served) PRODUCTIONS Plaintiff's Production 000001 009349 Defendant's Productions MAXWELL 00001 01364 Non-Party Productions CASSELL 000001 014402 MAR-A-LAGO 0001 0607 000001 000558 000001 000009 VICTIMS_REFUSE_SILENCE 0001 0091 Deposition Transcripts (ALL) April 22,

on with Errata Sheet November 29, 2016 Deposition of Peter Kent November 30, 2016 Deposition of Frederick Miller December 1, 2016 Deposition of Phillip Esplin December 2, 2016 Deposition of Gregory Taylor Index to BSF ShareFile Materials loaded on April 18-19 and April 23, 2019 EFTA00090987 FOIA CONFI

s and Responses (served) PRODUCTIONS Plaintiff's Production 000001 009349 Defendant's Productions MAXWELL 00001 01364 Non-Party Productions CASSELL 000001 014402 MAR-A-LAGO 0001 0607 W 000001 000558 000001 000009 VICTIMS_REFUSE_SILENCE 0001 0091 Transcripts (ALL) April 22, 2016 De

on with Errata Sheet November 29, 2016 Deposition of Peter Kent November 30, 2016 Deposition of Frederick Miller December 1, 2016 Deposition of Phillip Esplin December 2, 2016 Deposition of Gregory Taylor Index to BSF ShareFile Materials loaded on April 18-19, 2019 EFTA00090984 FOIA CONFIDENTIAL TREAT