Epstein Secrets

timony 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 which explains that there is no reliable or scientific methodology by which an expert could reliably come to such opinions. Of co

EFENDANT'S REPLY IN SUPPORT OF MOTION IN LIMINE TO EXCLUDE IN TOTO CERTAIN DEPOSITIONS DESIGNATED BY PLAINTIFF FOR USE AT TRIAL Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 EFTA00595612 Defendant Ghislaine Maxwell ("Ms. Maxwell") files h

7 18 19 20 21 22 23 24 25 MAG NA 0 LEGAL SERVICES EFTA00595627 2 3 INDEX Page 4 Examination by Mr. Edwards 4 Examination by Mr. Pagliuca 57 5 Further Examination by Mr. Edwards 68 6 7 8 EXHIBITS 9 Deposition Exhibit 1 6 Police Interview 10 11 12 13 14 15 16 17 1

our Honor. The defendant's own expert report 3 described our client as a prostitute. Your Honor has under 4 advisement the expert report from Dr. Esplin, and so I deposed 5 Dr. Esplin, and I said, "Are you sure that's an accurate term 6 in the context of this case? Because we have a child who 7

D FOREMAN, P.C. Attorneys for Defendant 20 BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. 21 22 23 24 25 SO

P.C. Attorneys for Defendant 20 BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. 21 22 23 24

No, your Honor. The defendant's own expert report described our client as a prostitute. Your Honor has under advisement the expert report from Dr. Esplin, and so I deposed Dr. Esplin, and I said, "Are you sure that's an accurate term in the context of this case? Because we have a child who cannot co

N AND FOREMAN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. SOUTHERN DISTRICT REPO

AN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. SOUTHERN DISTRIC

pen? No, your Honor. The defendant's own expert report described our client as a prostitute. Your Honor has under advisement th xpert report from Dr. Esplin, and so I deposed Dr. Esplin, and I said, "Are you sure that's an accurate term in the context of this case? Because we have a child who cannot co

GAN AND FOREMAN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. SOUTHERN DISTRICT R (2

EMAN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. SOUTHERN DISTRICT