Epstein Secrets

est is that today -- and today ends, for our joint effort, at 3:30 -- the defendant's motion with respect to the supplemental reports of Jansen and Kliman; the 302 motion; and there are three that seem to me to go together -- the references to the Florida action, the CVRA action; the Epstein plea agr

20 21 22 23 24 25 his that -- THE COURT: That's a whole different issue. Right? MR. PAGLIUCA: Yes. I agree. And finally, your Honor, on this Kliman issue, it seems to me that all of this is -- well, let me back up. Here are the reasons why it's prejudicial, and I don't think we can just say, t

REPORTERS, P.C. EFTA00592376 H3ulgiva 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 presentation in front of Kliman that he gets to then comment on. And so really what we're doing is we're trying to clean up the in-court testimony by an out-of-court statement to

strich's case, as her fiancé; in Tony Figueroa's case, as her boyfriend. We would ask that the evidence related to the Eppinger materials, Ostrich, Figueroa, and these two police incidents, be admitted at trial. THE COURT: As to Ostrich, did I understand correctly that what you want to present there is

t, his arrest, neither of which mentioned plaintiff, 8 by the way, but they took those materials and gave them to 9 their psychiatric expert, Dr. Kliman, who made the video we 10 talked about earlier. Dr. Kliman also administered a number of 11 tests to plaintiffs to figure out whether she had any

e evidence 23 that goes directly to proving the allegations that we've been 24 talking about today. For example, we're going to produce Tony 25 Figueroa, who's going to say that Epstein's assistants SOUTHERN DISTRICT REPORTERS, P.C. EFTA00794483 (212) 805-0300 EFTA00794484 60 H3ulgiva 1 regu

4 THE COURT: And why do you have it in your expert's 15 report? 16 MS. SCHULTZ: Well, our expert is -- I'm assuming 17 you're referring to Dr. Kliman, who is a physician. He's a 18 medical doctor. He took a full -- 19 THE COURT: There's a whole thing about it. Are you 20 going to withdraw the

which only 3 further substantiates Ms. testimony that at one point 4 she attempted to get away from defendant's abuse, along with -- 5 and Mr. Figueroa testified to the same. 6 So again, I would also reiterate that her reputation 7 as a child for being a truant or a runaway is not what is at 8

2 23 24 25 THE COURT: And why do you have it in your expert's report? MS. SCHULTZ: Well, our expert is -- I'm assuming you're referring to Dr. Kliman, who is a physician. He's a medical doctor. He took a full -- THE COURT: There's a whole thing about it. Are you going to withdraw the -- MS. SCHUL

th, 2002, which only further substantiates Ms. testimony that at one point she attempted to get away from defendant's abuse, along with -- and Mr. Figueroa testified to the same. So again, I would also reiterate that her reputation as a child for being a truant or a runaway is not what is at issue in

reexisting. = THE COURT: And why do you have it in your expert's report? MS. SCHULTZ: Well, our expert is -- I'm assuming you're referring to Dr. Kliman, who is a physician. He's a medical doctor. He took a full -- THE COURT: There's a whole thing about it. Are you going to withdraw the -- MS. SCHUL

which only further substantiates Ms. Giuffre's testimony that at one point she attempted to get away from defendant's abuse, along with -- and Mr. Figueroa testified to the same. So again, I would also reiterate that her reputation as a child for being a truant or a runaway is not what is at issue in t