Epstein Secrets

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

tiff did not dispute—and thereby confessed—that this statement is not actionable. Accordingly, we assume this statement is not in issue at trial. 2 Blair v. Inside Ed. Prods., 7 F. Supp. 3d 348, 358 & n.6 (S.D.N.Y. 2014) (citing DiBella v. Hopkins, 403 F.3d 102, 111 (2d Cir. 2005)). 8 EFTA00792763

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

tiff did not dispute—and thereby confessed—that this statement is not actionable. Accordingly, we assume this statement is not in issue at trial. 2 Blair v. Inside Ed. Prods., 7 F. Supp. 3d 348, 358 & n.6 (S.D.N.Y. 2014) (citing DiBella v. Hopkins, 403 F.3d 102, 111 (2d Cir. 2005)). 8 EFTA00617403

n can that circumstance be addressed by a motion such as the instant one.) 11. Next, Plaintiffs, Jane Does 2-8, attempt to use the Affidavit of Dr. Kliman for every motion for protective order/objection filed to date. This also includes the two most recent motions, which attempt to prevent Defendant's

• • inator, Office of Executive Clemency, 2601 Blair Stone Road, Building sC", Room 229, Tallahassee,

n can that circumstance be addressed by a motion such as the instant one.) 11. Next, Plaintiffs, Jane Does 2-8, attempt to use the Affidavit of Dr. Kliman for every motion for protective order/objection filed to date. This also includes the two most recent motions, which attempt to prevent Defendant's

Coordinator, Office of Executive Clemency, 2601 Blair Stone Road, Building Room 229, Tallahassee, Flor