Epstein Secrets

essions, the Motion in Limine to exclude the use of the designated portions of these depositions in toto must be granted. B. As a Retained Expert, Phillip Esplin Cannot Be Deemed Unavailable Plaintiff's argument concerning Phillip Esplin fails to acknowledge or even address the cases cited that require that

lare as follows: 1. I am an attorney at law duly licensed in the State of New York and admitted to practice in the United States District Court for the Southern District of New York. I am a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell in this action. I resp

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

403. Whether or not Ms. ever 6 used drugs while not being abused by defendant does not go to 7 any claim or defenses in this case. 8 Courts in the Southern District of New York routinely 9 exclude evidence of prior drug use under both of these rules, 10 as fully briefed in the papers. Defendant attempts to ad

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

le 403. Whether or not Ms. Giuffre ever used drugs while not being abused by defendant does not go to any claim or defenses in this case. Courts in the Southern District of New York routinely xclud vidence of prior drug use under both of these rules, as fully briefed in the papers. Defendant attempts to admit this ev