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against 10 him, and what's at issue in this case is, again, Maxwell's 11 statements against my client. 12 The case that they cite actually, the Minemyer case, 13 goes against them. It actually talks about how you would have 14 to call the reporter, that that couldn't come into evidence. 15 And s
t's defamation. 3 I'm going to move on to point number 9. Ms. 4 seeks to exclude any alleged criminal history from coming into 5 this case. And the Federal Rules of Evidence bar the 6 introduction of this evidence, full stop. 7 As the Court is aware, the only way criminal history 8 could come into evidence is through Rule 609
y my client against him, and what's at issue in this case is, again, Maxwell's statements against my client. The case that they cite actually, the Minemyer case, goes against them. It actually talks about how you would have to call the reporter, that that couldn't come into evidence. And so, your Hono
defendant's defamation. I'm going to move on to point number 9. Ms. seeks to exclude any alleged criminal history from coming into this case. And the Federal Rules of Evidence bar the introduction of this evidence, full stop. As the Court is aware, the only criminal history could come into evidence is through Rule 609, but that
by my client against him, and what's at issue in this case is, again, Maxwell's statements against my client. The case that they cite actually, the Minemyer case, goes against them. It actually talks about how you would have to call the reporter, that that couldn't come into evidence. And so, your Hono
ant's defamation. I'm going to move on to point number 9. Ms. Giuffre seeks to exclude any alleged criminal history from coming into this case. And the Federal Rules of Evidence bar the introduction of this evidence, full stop. As the Court is aware, the only way criminal history could come into evidence is through Rule 609, but th
Entities connected to both Minemyer and the Federal Rules of Evidence bar the

Virginia Giuffre
PERSON
Jeffrey Epstein
PERSON
Alan Dershowitz
PERSON
Prince Andrew
PERSON
Bill Clinton
PERSON
Robert Mueller
PERSON
Alfredo Rodriguez
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSONSigrid McCawley
PERSON
Ghislaine Maxwell
PERSON
Schafer
PERSONJane Doe
PERSON
Paul Cassell
PERSONthe Southern District
LOCATIONJeffrey Pagliuca
PERSON
Time, Inc.
ORGANIZATION
David Boies
PERSONBoylan
PERSONEsplin
PERSON