Epstein Secrets

ld solve many of the problems that we 11 just talked about, however. 12 Okay. Where are we? Yes. Evidence of Maxwell's 13 involvement. 14 MR. CASSELL: Is this 686? 15 THE COURT: Yes. 16 MR. CASSELL: Yes, your Honor. Paul Cassell for 17 Ms. I'm arguing this motion. 18 As you know, the motio

ay. Where are we? Yes. Evidence of Maxwell's 13 involvement. 14 MR. CASSELL: Is this 686? 15 THE COURT: Yes. 16 MR. CASSELL: Yes, your Honor. Paul Cassell for 17 Ms. I'm arguing this motion. 18 As you know, the motion was an affirmative motion to 19 avoid disputes arising in the middle of trial,

second category of evidence we seek to introduce 19 at trial, your Honor, relates to testimony by her fianc 20 Michael Ostrich and her boyfriend Tony Figueroa. The facts on 21 this, your Honor, are that Ms. met Mr. Ostrich, he was 22 the brother of someone she was in rehab with, she was in drug 23 re

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

ipt, as you know. And in that 11 book manuscript, she describes that it was not her who took the 12 money from the tip jar, it was her boyfriend, Tony Figueroa, 13 and that's also what she testified during her deposition. 14 She said, for example, that she didn't commit the 15 theft, that he came in at

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

manuscript, as you know. And in that book manuscript, she describes that it was not her who took the money from the tip jar, it was her boyfriend, Tony Figueroa, and that's also what she testified during her deposition. She said, for example, that she didn't commit the theft, that he came in at the end of he

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,

Designated Testimony of James Austrich June 24, 2016 Designated Testimony of Tony Figueroa Volume 1 (Ex. 1) June 24, 2016 Designated Testimony of Tony Figueroa Volume 2 September 8, 2016 Designated Testimony of Brittany Henderson (M) September 9, 2016 Designated Testimony of Jeffrey Epstein (Exs. 1-6, 8)