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handling that. 5 This is essentially a hearsay exercise. We want information to 6 be excluded regarding Rebecca Boylan. Why? Because Rebecca 7 Boylan has not been deposed and is not going to be a witness in 8 the case. 9 As we understand what the defendant is planning to do, 10 she's planning
that overview. 2 They reference Mueller and Kirkpatrick, a treatise 3 that we think is very instructive on this particular point. 4 Mueller and Kirkpatrick says, "It is true that in a 5 defamation case there is more latitude to introducing 6 reputational types of evidence. However, it's important to
UTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00794625 71 H3V0GIU1 1 so let meet respond to that overview. 2 They reference Mueller and Kirkpatrick, a treatise 3 that we think is very instructive on this particular point. 4 Mueller and Kirkpatrick says, "It is true that in a 5 defamation ca
handling that. 5 This is essentially a hearsay exercise. We want information to 6 be excluded regarding Rebecca Boylan. Why? Because Rebecca 7 Boylan has not been deposed and is not going to be a witness in 8 the case. 9 As we understand what the defendant is planning to do, 10 she's planning
spond to that overview. They reference Mueller and Kirkpatrick, a treatise that we think is very instructive on this particular point. Mueller and Kirkpatrick says, "It is true that in a defamation case there is more latitude to introducing reputational types of evidence. However, it's important to remem
7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 H3V0GIU1 -1 so let meet respond to that overview. They reference Mueller and Kirkpatrick, a treatise that we think is very instructive on this particular point. Mueller and Kirkpatrick says, "It is true that in a defamation case there
tness in the case. As we understand what the defendant is planning to do, she's planning to call Mr. Dershowitz. Mr. Dershowitz is going to say Ms. Boylan told him that Ms. Giuffre told him something, and so we have the classic hearsay within a hearsay situation. The problem, of course, is that Boylan
10 id. 12 13 14 L5 16 ne) 18 life) 20 21 22 23 24 25 val H3VOGIU1 so let meet respond to that overview. They reference Mueller and Kirkpatrick, a treatise that we think is very instructive on this particular point. Mueller and Kirkpatrick says, "It is true that ina defamation case there i
spond to that overview. They reference Mueller and Kirkpatrick, a treatise that we think is very instructive on this particular point. Mueller and Kirkpatrick says, "It is true that ina defamation case there is more latitude to introducing reputational types of evidence. However, it's important to rememb
Entities connected to both Boylan and Kirkpatrick

Jeffrey Epstein
PERSON
Prince Andrew
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Donald Trump
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Virginia Giuffre
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George W. Bush
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David Boies
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Ghislaine Maxwell
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Bill Clinton
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Bradley Edwards
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Joe Biden
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Alan Dershowitz
PERSONLeon Black
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Barack Obama
PERSONSigrid McCawley
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United States
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Colorado
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Department of Justice
ORGANIZATION
Bernie Sanders
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Al Gore
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Scarlett Johansson
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