Epstein Secrets

ee also LeBlanc v. Cleveland, 248 F.3d 95, 100 (2d Cir. 2001). The complaint was filed on September 21, 2015 at which time Plaintiff was living in Colorado and Defendant Ghislaine Maxwell was living in New York. Plaintiff is a United States Citizen. Plaintiff is seeking damages in excess of $75,000.00

ny Records custodians necessary 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

ee also LeBlanc v. Cleveland, 248 F.3d 95, 100 (2d Cir. 2001). The complaint was filed on September 21, 2015 at which time Plaintiff was living in Colorado and Defendant Ghislaine Maxwell was living in New York. Plaintiff is a United States Citizen. Plaintiff is seeking damages in excess of $75,000.00

ny Records custodians necessary 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

rdale, Florida 33301 7 BY: BRADLEY EDWARDS, ESQ. 8 9 HADDON MORGAN & FOREMAN, P.C. Attorneys for Defendant 10 150 East 10th Avenue Denver, Colorado 80203 11 BY: JEFFREY PAGLIUCA, ESQ. 12 13 PODHURST ORSECK, P.A. Attorneys for Deponent 14 25 West Flagler Street Suite 800 15 Miami, Flor

w information Plaintiff may present in her case-in-chief. Ms. Maxwell has filed well-founded motions in limine to exclude the testimony of both Dr. Kliman and Professor Coonan prohibiting from providing their credibility and vouching opinions. This is the subject matter of Dr. Esplin's rebuttal report

to testify 6 about her need for medications going forward, and he has been 7 the one who's talked about her previous use of medications. 8 Her Colorado doctor testified that she had misled him and not 9 fully disclosed her need for prescription medications, and 10 there's also the question about

4 THE COURT: And why do you have it in your expert's 15 report? 16 MS. SCHULTZ: Well, our expert is -- I'm assuming 17 you're referring to Dr. Kliman, who is a physician. He's a 18 medical doctor. He took a full -- 19 THE COURT: There's a whole thing about it. Are you 20 going to withdraw the

to testify 6 about her need for medications going forward, and he has been 7 the one who's talked about her previous use of medications. 8 Her Colorado doctor testified that she had misled him and not 9 fully disclosed her need for prescription medications, and 10 there's also the question about

2 23 24 25 THE COURT: And why do you have it in your expert's report? MS. SCHULTZ: Well, our expert is -- I'm assuming you're referring to Dr. Kliman, who is a physician. He's a medical doctor. He took a full -- THE COURT: There's a whole thing about it. Are you going to withdraw the -- MS. SCHUL

who wants to testify about her need for medications going forward, and he has been the one who's talked about her previous use of medications. Her Colorado doctor testified that she had misled him and not fully disclosed her need for prescription medications, and there's also the question about whether

reexisting. = THE COURT: And why do you have it in your expert's report? MS. SCHULTZ: Well, our expert is -- I'm assuming you're referring to Dr. Kliman, who is a physician. He's a medical doctor. He took a full -- THE COURT: There's a whole thing about it. Are you going to withdraw the -- MS. SCHUL