Epstein Secrets

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

no reason we should be allowed to ask about all these 14 other bad acts. 15 Sack cites, your Honor, to an Eleventh Circuit case, 16 Schafer vs. Time, Inc. In that case, your Honor, Sack says the 17 Eleventh Circuit found the district court had been correct when 18 it ruled that the defendant, which

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

no reason we should be allowed to ask about all these 14 other bad acts. 15 Sack cites, your Honor, to an Eleventh Circuit case, 16 Schafer vs. Time, Inc. In that case, your Honor, Sack says the 17 Eleventh Circuit found the district court had been correct when 18 it ruled that the defendant, which

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

ere is just no reason we should be allowed to ask about all these other bad acts. Sack cites, your Honor, to an Eleventh CircuLt case, Schafer vs. Time, Inc. In that case, your Honor, Sack says the Eleventh Circuit found the district court had been correct when it ruled that the defendant, which allegedl

g is relevant and admissible (Motion in Limine 19)... eee 29 20. The transcript of the tape recording of Mr. Dershowitz’s conversation with Rebecca Boylan is admissible (Motion 1n Limine 20)... ceececesessseeseeceeeeseeneeceseeseeneeeeeerseeeaees 31 C. Plaintiff's Remaining Motions In Limine Are Prematu

essment rere memeneistseee 13, 28 S.E.C. v. Collins & Aikman Corp., 256 F.R.D. 403, 412 (S.D.N-Y. 2009) oo. ceeeeeecesteeteeteeeeeeeees 19 Schafer v. Time, Inc., 142 F.3d 1361, 1364-75 (1 1th Cir. 1998) oo. eee ceseesseesseeeseeeseeeseeeneessaee 3 Seligson, Morris & Neuburger v Fairbanks Whitney Corp., 257 N

nt and admissible (Motion in Limine 19).................00. 29 20. The transcript of the tape recording of Mr. Dershowitz’s conversation with Rebecca Boylan is admissible (Motion in Limine 20)... ccccccccccceceeceeeceseeesecneesseesteeesaeenes 31 C. Plaintiff's Remaining Motions In Limine Are Premature an

2015 WL 3533844, at *5 (D. Utah i eb) 13,28 S.E.C. v. Collins & Aikman Corp., 256 F.R.D. 403, 412 (S.D.N.Y. 2009) oo. cccccteeeseeeee 19 Schafer v. Time, Inc., 142 F.3d 1361, 1364-75 (11th Cir. 1998) oo ccceeeeeseteeteesetseteeteesenes 3 Seligson, Morris & Neuburger v Fairbanks Whitney Corp., 257 N.Y.S.2d