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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
handling that. 5 This is essentially a hearsay exercise. We want information to 6 be excluded regarding Rebecca Boylan. Why? Because Rebecca 7 Boylan has not been deposed and is not going to be a witness in 8 the case. 9 As we understand what the defendant is planning to do, 10 she's planning
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
handling that. 5 This is essentially a hearsay exercise. We want information to 6 be excluded regarding Rebecca Boylan. Why? Because Rebecca 7 Boylan has not been deposed and is not going to be a witness in 8 the case. 9 As we understand what the defendant is planning to do, 10 she's planning
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
tness in the case. As we understand what the defendant is planning to do, she's planning to call Mr. Dershowitz. Mr. Dershowitz is going to say Ms. Boylan told him that Ms. Giuffre told him something, and so we have the classic hearsay within a hearsay situation. The problem, of course, is that Boylan
g is relevant and admissible (Motion in Limine 19)... eee 29 20. The transcript of the tape recording of Mr. Dershowitz’s conversation with Rebecca Boylan is admissible (Motion 1n Limine 20)... ceececesessseeseeceeeeseeneeceseeseeneeeeeerseeeaees 31 C. Plaintiff's Remaining Motions In Limine Are Prematu
Page: HOUSE_OVERSIGHT_011465 →7 Mich. App. 1, 12, 602 N.W.2d 233, 239 (1999)... eee 13 Longmire v. Ala. State Univ., 151 F.R.D. 414, 419 (M.D.Ala. 1992)... cece ee eee ee ee eee 3 Minemyer v. R-Boc Representatives, Inc., No. 07 C 1763, 2012 WL 379904, at *4 (N.D. IIL Feb. 6, 2012) oo eeeeseseessesscssenecrscsecseesecsesessesesseseesses
Page: HOUSE_OVERSIGHT_011467 →Microsoft Word - 2017.03.16 Deft Resp IO to Ptfs Omnibus Motn in Limine (MASTER).docx
nt and admissible (Motion in Limine 19).................00. 29 20. The transcript of the tape recording of Mr. Dershowitz’s conversation with Rebecca Boylan is admissible (Motion in Limine 20)... ccccccccccceceeceeeceseeesecneesseesteeesaeenes 31 C. Plaintiff's Remaining Motions In Limine Are Premature an
Page: HOUSE_OVERSIGHT_014790 →ss'n, 237 Mich. App. 1, 12, 602 N.W.2d 233, 239 (1999)... 13 Longmire v. Ala. State Univ., 151 F.R.D. 414, 419 (M.D.Ala. 1992). 000.00. cece cee ed Minemyer v. R-Boc Representatives, Inc., No. 07 C 1763, 2012 WL 379904, at *4 (N.D. ILL. Feb. 6, 2012) oe ceecceececcecccecceseeecesecsecseeceeeseesecseesaec
Page: HOUSE_OVERSIGHT_014792 →Entities connected to both Minemyer and Boylan

Jeffrey Epstein
PERSON
Virginia Giuffre
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
Bill Clinton
PERSON
Alfredo Rodriguez
PERSON
Ghislaine Maxwell
PERSONMaria Farmer
PERSON
Robert Mueller
PERSONJeffrey Pagliuca
PERSON
Bradley Edwards
PERSON
Paul Cassell
PERSONJane Doe
PERSON
David Boies
PERSONSigrid McCawley
PERSON
Schafer
PERSON
Kenneth Marra
PERSON
Time, Inc.
ORGANIZATION
Denver
LOCATION
United States
LOCATION