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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
motion reads like a list 9 of everything plaintiff has lied about or anything that would 10 undercut her claim for damages. 11 Plaintiff quoted Passim in her reply brief from a 12 particular federal evidence treatise, and I would like to tell 13 the Court, she left out the most important parts,
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
he omnibus motion reads like a list of everything plaintiff has lied about or anything that would undercut her claim for damages. Plaintiff quoted Passim in her reply brief from a particular federal evidence treatise, and I would like to tell the Court, she left out the most important parts, and 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
The omnibus motion reads like a list of everything plaintiff has lied about or anything that would undercut her claim for damages. Plaintiff quoted Passim in her reply brief froma particular federal evidence treatise, and I would like to tell the Court, she left out the most important parts, and that i
Entities connected to both Minemyer and Passim

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