Epstein Secrets

s Olas Boulevard, Suite 1200 Ft. Lauderdale, FL 33301 Tel: 954-356-0011 Fax: 954-356-0022 [email protected] EFTA00792756 Meredith Schultz: Paul Cassel: Bradley Edwards: J. Stan Pottinger: Boles Schiller & Flexner 401 E. Las Olas Boulevard, Suite 1200 Ft. Lauderdale, FL 33301 Tel: 954-356-0011

Vice) FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Paul G. Cassell (Pm Hac Vice) S.J. Quinney College of Law University of Utah 383 University St. Salt Lake City, UT 84112 (801) 585-52025 Counsel for Plaintiff

auderdale, Florida 33301 (954) 524-2820 Paul G. Cassell (Pm Hac Vice) S.J. Quinney College of Law Unive

d, the media obtained copies of the motion. At issue is a January 2, 2015, statement prepared by Ms. Maxwell's British solicitor Philip Barden. Mr. Barden sent the statement to Ms. Maxwell for approval and, following approval, caused Mr. Gow to send (via email) the statement to six to thirty members of

Suite 2 Fort Lauderdale, Florida 33301 Paul G. Cassell (Pm Hac Vice) S.J. Quinney College of Law Unive

d McCawley: Boies Schiller & Flexner 401 E. Las Olas Boulevard, Suite 1200 Ft. Lauderdale, FL 33301 Tel: Fax: EFTA00617396 Meredith Schultz: Paul Cassel: Bradley Edwards: J. Stan Pottinger: Boles Schiller & Flexner 401 E. Las Olas Boulevard, Suite 1200 Ft. Lauderdale, FL 33301 Tel: Fax: Univer

Edwards (Pro Hac Vice) FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Paul G. Cassell (Pm Hac Vice) S.J. Quinney College of Law University of Utah 383 University St. 84112 Counsel for Plainttg, By: /s/ Jeffrey S. Pagliuca Laura

d, the media obtained copies of the motion. At issue is a January 2, 2015, statement prepared by Ms. Maxwell's British solicitor Philip Barden. Mr. Barden sent the statement to Ms. Maxwell for approval and, following approval, caused Mr. Gow to send (via email) the statement to six to thirty members of

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. FARMER, JAFFE, WEISSING, EDWARDS, FISTOS, LEHRMAN, P.L. Attorneys for Plaintiff BY: BRADLEY J. EDWARDS, ESQ. HADDON, MORGAN AND FOREMAN, P.

jury, statements to a jury, that they are going to be then arguing are credible, and so we have this joinder motion, drafted by Mr. Edwards and Mr. Cassell, that they would like to introduce into evidence, whole cloth into evidence, that contains the legal arguments and the statements of lawyers, thes

hey have the burden of proving that what Ms. Maxwell said was false. That's what is at issue. We have to look at Ms. Maxwell's statement issued by Barden and Gow and then go backwards from there. And the burden on the plaintiff is proving falsity of that statement. It is not the situation where -- wh

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 FARMER, JAFFE, WEISSING, EDWARDS, FISTOS, LEHRMAN, P.L. Attorneys for Plaintiff 20 BY: BRADLEY J. EDWARDS, ESQ. 21 HADDON, MORGAN AND

statements to a jury, that they are going to be then 3 arguing are credible, and so we have this joinder motion, 4 drafted by Mr. Edwards and Mr. Cassell, that they would like to 5 introduce into evidence, whole cloth into evidence, that 6 contains the legal arguments and the statements of lawyers,

the burden of proving that what Ms. Maxwell said was false. 16 That's what is at issue. We have to look at Ms. Maxwell's 17 statement issued by Barden and Gow and then go backwards from 18 there. And the burden on the plaintiff is proving falsity of 19 that statement. It is not the situation whe

101 H3v1giu2 1 MR. CASSELL: All right. Well, we thought, when we 2 filed our response, they continued to oppose it. If they had 3 just stipulated, you know, I wouldn't be t

fered for the truth of 5 the matter asserted, we want to offer it to show Ms. Maxwell's 6 state of mind when she issued her statement through Mr. Barden 7 and Mr. Gow. So the huge problem with that, your Honor, which 8 we've already dealt with, is, Ms. Maxwell has no knowledge of 9 what's in the

1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 H3v1giu2 101 MR. CASSELL: All right. Well, we thought, when we filed our response, they continued to oppose it. If they had just stipulated, you know, I wouldn't be taking

fered for the truth of 5 the matter asserted, we want to offer it to show Ms. Maxwell's 6 state of mind when she issued her statement through Mr. Barden 7 and Mr. Gow. So the huge problem with that, your Honor, which 8 we've already dealt with, is, Ms. Maxwell has no knowledge of 9 what's in the

10 id. 12 13 14 L5 16 ne) 18 life) 20 21 22 23 24 25 101 H3vlgiu2 r MR. CASSELL: All right. Well, we thought, when we filed our response, they continued to oppose it. If they had just stipulated, you know, I wouldn't be taking y

ing offered for the truth of the matter asserted, we want to offer it to show Ms. Maxwell's state of mind when she issued her statement through Mr. Barden and Mr. Gow. So the huge problem with that, your Honor, which Ww ' ve already dealt with, is, Ms. Maxwell has no knowledge of what's in these poli