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

lare as follows: 1. I am an attorney at law duly licensed in the State of New York and admitted to practice in the United States District Court for the Southern District of New York. I am a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell in this action. I resp

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

403. Whether or not Ms. ever 6 used drugs while not being abused by defendant does not go to 7 any claim or defenses in this case. 8 Courts in the Southern District of New York routinely 9 exclude evidence of prior drug use under both of these rules, 10 as fully briefed in the papers. Defendant attempts to ad

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

le 403. Whether or not Ms. Giuffre ever used drugs while not being abused by defendant does not go to any claim or defenses in this case. Courts in the Southern District of New York routinely xclud vidence of prior drug use under both of these rules, as fully briefed in the papers. Defendant attempts to admit this ev