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motion reads like a list 9 of everything plaintiff has lied about or anything that would 10 undercut her claim for damages. 11 Plaintiff quoted Passim in her reply brief from a 12 particular federal evidence treatise, and I would like to tell 13 the Court, she left out the most important parts,
H3V0GIU1 1 these other things that are circulating about her that have 2 nothing to do with Ms. Maxwell. 3 Mr. Cassell referred to our expert Phillip Esplin, 4 Dr. Esplin, and saying that he agreed not to refer to 5 as a prostitute. Your Honor, that came up in the 6 context of a cross examination in
he omnibus motion reads like a list of everything plaintiff has lied about or anything that would undercut her claim for damages. Plaintiff quoted Passim in her reply brief from a particular federal evidence treatise, and I would like to tell the Court, she left out the most important parts, and that
VOGIU1 53 1 these other things that are circulating about her that have 2 nothing to do with Ms. Maxwell. 3 Mr. Cassell referred to our expert Phillip Esplin, 4 Dr. Esplin, and saying that he agreed not to refer to 5 s a prostitute. Your Honor, that came up in the 6 context of a cross examination in
The omnibus motion reads like a list of everything plaintiff has lied about or anything that would undercut her claim for damages. Plaintiff quoted Passim in her reply brief froma particular federal evidence treatise, and I would like to tell the Court, she left out the most important parts, and that i
24 25 53 H3VOGIU1 these other things that are circulating about her that have nothing to do with Ms. Maxwell. Mr. Cassell referred to our expert Phillip Esplin, Dr. Esplin, and saying that he agreed not to refer to Virginia Roberts as a prostitute. Your Honor, that came up in the context of a cross examina
Entities connected to both Passim and Phillip Esplin

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Paul Cassell
PERSON
Alan Dershowitz
PERSON
Colorado
LOCATION
Bradley Edwards
PERSONKliman
PERSONEsplin
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Alfredo Rodriguez
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Bill Clinton
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David Boies
PERSONSigrid McCawley
PERSONJeffrey Pagliuca
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Peter Mandelson
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Prince Andrew
PERSONScott Rothstein
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George W. Bush
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Virginia Giuffre
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Kenneth Marra
PERSONJack Scarola
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