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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
t's defamation. 3 I'm going to move on to point number 9. Ms. 4 seeks to exclude any alleged criminal history from coming into 5 this case. And the Federal Rules of Evidence bar the 6 introduction of this evidence, full stop. 7 As the Court is aware, the only way criminal history 8 could come into evidence is through Rule 609
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
defendant's defamation. I'm going to move on to point number 9. Ms. seeks to exclude any alleged criminal history from coming into this case. And the Federal Rules of Evidence bar the introduction of this evidence, full stop. As the Court is aware, the only criminal history could come into evidence is through Rule 609, but that
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
ant's defamation. I'm going to move on to point number 9. Ms. Giuffre seeks to exclude any alleged criminal history from coming into this case. And the Federal Rules of Evidence bar the introduction of this evidence, full stop. As the Court is aware, the only way criminal history could come into evidence is through Rule 609, but th
Entities connected to both Phillip Esplin and the Federal Rules of Evidence bar the

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