ember 22, 2016 Deposition of with Errata Sheet November 29, 2016 Deposition of November 30, 2016 Deposition of December 1, 2016 Deposition of Phillip Esplin December 2, 2016 Deposition of Gregory Taylor Index to BSF ShareFile Materials loaded on April 18-19 and April 23, 2019 EFTA00081371 FOIA CONFI

on with Errata Sheet November 29, 2016 Deposition of Peter Kent November 30, 2016 Deposition of Frederick Miller December 1, 2016 Deposition of Phillip Esplin December 2, 2016 Deposition of Gregory Taylor Index to BSF ShareFile Materials loaded on April 18-19 and April 23, 2019 EFTA00090987 FOIA CONFI

on with Errata Sheet November 29, 2016 Deposition of Peter Kent November 30, 2016 Deposition of Frederick Miller December 1, 2016 Deposition of Phillip Esplin December 2, 2016 Deposition of Gregory Taylor Index to BSF ShareFile Materials loaded on April 18-19, 2019 EFTA00090984 FOIA CONFIDENTIAL TREAT

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

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

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

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