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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,
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
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
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
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
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 Passim and Kirkpatrick

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
George W. Bush
PERSON
David Boies
PERSON
Ghislaine Maxwell
PERSON
Virginia Giuffre
PERSON
Bill Clinton
PERSON
Bradley Edwards
PERSON
Bernie Sanders
PERSON
Colorado
LOCATION
Robert Mueller
PERSON
Alan Dershowitz
PERSONSigrid McCawley
PERSON
Al Gore
PERSON
Kenneth Marra
PERSONthe Southern District
LOCATIONJane Doe
PERSONJack Scarola
PERSON
Alfredo Rodriguez
PERSONScott Rothstein
PERSON