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

hey have the burden of proving that what Ms. Maxwell said was false. That's what is at issue. We have to look at Ms. Maxwell's statement issued by Barden and Gow and then go backwards from there. And the burden on the plaintiff is proving falsity of that statement. It is not the situation where -- wh

hat today -- and today 19 ends, for our joint effort, at 3:30 -- the defendant's motion 20 with respect to the supplemental reports of Jansen and Kliman; 21 the 302 motion; and there are three that seem to me to go 22 together -- the references to the Florida action, the CVRA 23 action; the Epst

8 H3ulgiva 1 his that 2 THE COURT: That's a whole different issue. Right? 3 MR. PAGLIUCA: Yes. I agree. 4 And finally, your Honor, on this Kliman issue, it 5 seems to me that all of this is -- well, let me back up. Here 6 are the reasons why it's prejudicial, and I don't think we can 7 ju

timony there's this staged SOUTHERN DISTRICT REPORTERS, P.C. EFTA00794381 (212) 805-0300 EFTA00794382 9 H3ulgiva 1 presentation in front of Kliman that he gets to then comment 2 on. And so really what we're doing is we're trying to clean up 3 the in-court testimony by an out-of-court stateme

the burden of proving that what Ms. Maxwell said was false. 16 That's what is at issue. We have to look at Ms. Maxwell's 17 statement issued by Barden and Gow and then go backwards from 18 there. And the burden on the plaintiff is proving falsity of 19 that statement. It is not the situation whe

ny Records custodians necessary to authenticate business records under FRE 803(b) 27. Any witnesses necessary for impeachment or rebuttal 28. Dr. Kliman (expert) 29. Dr. Coonan (expert) 30. Jim Jansen (expert) 31. Chris Andersen (expert) 32. Bill Chandler (rebuttal expert) 33. Dianne Flores

d, the media obtained copies of the motion. At issue is a January 2, 2015, statement prepared by Ms. Maxwell's British solicitor Philip Barden. Mr. Barden sent the statement to Ms. Maxwell for approval and, following approval, caused Mr. Gow to send (via email) the statement to six to thirty members of

ny Records custodians necessary to authenticate business records under FRE 803(b) 27. Any witnesses necessary for impeachment or rebuttal 28. Dr. Kliman (expert) 29. Dr. Coonan (expert) 30. Jim Jansen (expert) 31. Chris Andersen (expert) 32. Bill Chandler (rebuttal expert) 33. Dianne Flores

d, the media obtained copies of the motion. At issue is a January 2, 2015, statement prepared by Ms. Maxwell's British solicitor Philip Barden. Mr. Barden sent the statement to Ms. Maxwell for approval and, following approval, caused Mr. Gow to send (via email) the statement to six to thirty members of