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fered for the truth of 5 the matter asserted, we want to offer it to show Ms. Maxwell's 6 state of mind when she issued her statement through Mr. Barden 7 and Mr. Gow. So the huge problem with that, your Honor, which 8 we've already dealt with, is, Ms. Maxwell has no knowledge of 9 what's in the
advance the 3 search for truth. And here we have a conspiracy, and I'm using 4 that term not as a lawyer but as a layperson for this purpose. 5 Webster's defines to conspire means to join together in a 6 secret agreement to do an unlawful or wrongful act or an act 7 which becomes unlawful as a re
fered for the truth of 5 the matter asserted, we want to offer it to show Ms. Maxwell's 6 state of mind when she issued her statement through Mr. Barden 7 and Mr. Gow. So the huge problem with that, your Honor, which 8 we've already dealt with, is, Ms. Maxwell has no knowledge of 9 what's in the
is whether admitting the evidence will advance the search for truth. and I'm using that term not as a lawyer but as a layperson for this purpose. Webster's defines Of course once you determine that something's relevant, you then have to consider possible prejudicial effect. Obviously this is a case
ing offered for the truth of the matter asserted, we want to offer it to show Ms. Maxwell's state of mind when she issued her statement through Mr. Barden and Mr. Gow. So the huge problem with that, your Honor, which Ww ' ve already dealt with, is, Ms. Maxwell has no knowledge of what's in these poli
ence will advance the search for truth. And here we have a conspiracy, and I'm using that term not as a lawyer but as a layperson for this purpose. Webster's defines to conspire means to join together ina secret agreement to do an unlawful or wrongful act or an act which becomes unlawful as a result of
Entities connected to both Barden and Webster

Jeffrey Epstein
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Ghislaine Maxwell
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Virginia Giuffre
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United States
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George W. Bush
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Alan Dershowitz
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Prince Andrew
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Bradley Edwards
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Colorado
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Alfredo Rodriguez
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Wilbur Ross
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Denver
LOCATIONMartin Weinberg
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Vicky Ward
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Paul Cassell
PERSONJack Goldberger
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Alexander Acosta
PERSONJeffrey Pagliuca
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