Epstein Secrets

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

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

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

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

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

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

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

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