giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…how she intends to
introduce that evidence in a trial of this defamation claim between Plaintiff and Ms. Maxwell.
Apart from these witnesses stated intent to take the Fifth Amendment which renders their
testimony inadmissible, as discussed more fully below…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.1
8 pg
…plea of guilty to the offense charged or a lesser offense;
(6) Information the lawyer or law firm knows is likely to be inadmissible at trial and
would if disclosed create a substantial likelihood of prejudicing an impartial trial; and
…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.18
11 pg
…issuing the denial. Plaintiff’s attempt to amplify this proceeding into
something broader should not be condoned.
Because the evidence sought is nothing more than extraneous inadmissible
“circumstantial evidence” 7 irrelevant to proving the essential elements of the claim, “the…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.12
32 pg
…how she intends to
introduce that evidence in a trial of this defamation claim between Plaintiff and Ms. Maxwell.
Apart from these witnesses stated intent to take the Fifth Amendment which renders their
testimony inadmissible, as discussed more fully below…
giuffre-maxwell
gov.uscourts.nysd.447706.1057.0
17 pg
…Reports, some redacted, some unredacted, with multiple
references to Non-Party Does. Exhibit 4 and 7 are inadmissible hearsay transcripts from an
unreliable deceased individual never deposed by Ms. Maxwell. Exhibits 5 and 6 concern J. Doe 1.
III. DE…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.20
11 pg
…issuing the denial. Plaintiff’s attempt to amplify this proceeding into
something broader should not be condoned.
Because the evidence sought is nothing more than extraneous inadmissible
“circumstantial evidence”7 irrelevant to proving the essential elements of the claim, “the…
giuffre-maxwell
1320-20
11 pg
…issuing the denial. Plaintiff’s attempt to amplify this proceeding into
something broader should not be condoned.
Because the evidence sought is nothing more than extraneous inadmissible
“circumstantial evidence”7 irrelevant to proving the essential elements of the claim, “the…
giuffre-maxwell
1320-28
32 pg
…how she intends to
introduce that evidence in a trial of this defamation claim between Plaintiff and Ms. Maxwell.
Apart from these witnesses stated intent to take the Fifth Amendment which renders their
testimony inadmissible, as discussed more fully below…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.7
21 pg
…cv-07433-LAP Document 1331-7 Filed 01/05/24 Page 7 of 21
requirements have been met, mandating that the designated portions of Dr. Esplin’s testimony
should be ruled inadmissible at trial. Id.; see also Aubrey Rogers Agency…
giuffre-maxwell
gov.uscourts.nysd.447706.189.0
11 pg
…issuing the denial. Plaintiff’s attempt to amplify this proceeding into
something broader should not be condoned.
Because the evidence sought is nothing more than extraneous inadmissible
“circumstantial evidence” 7 irrelevant to proving the essential elements of the claim, “the…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.19_2
32 pg
…how she intends to
introduce that evidence in a trial of this defamation claim between Plaintiff and Ms. Maxwell.
Apart from these witnesses stated intent to take the Fifth Amendment which renders their
testimony inadmissible, as discussed more fully below…
giuffre-maxwell
gov.uscourts.nysd.447706.185.8
24 pg
…withheld
4
See supra, fn. 2.
3
Case 1:15-cv-07433-LAP Document 185-8 Filed 06/01/16 Page 5 of 24
what they contend is irrelevant, inadmissible, and/or privileged discovery. Again, Plaintiffs are
in error…
giuffre-maxwell
gov.uscourts.nysd.447706.185.7
26 pg
…Response to Defendant's Motion to Compel
Page 11
discussed below, any material covered by the attorney-client or attorney-work product would
also be beyond the scope of discovery, irrelevant and/or inadmissible.
b. Request for Production Nos. 10…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.13
22 pg
…recounting
Epstein's sexual abuse.
8
Case 1:15-cv-07433-LAP Document 1331-13 Filed 01/05/24 Page 13 of 22
With regard to Defendant’s general objections that the Palm Beach Police Report is
inadmissible hearsay…
giuffre-maxwell
gov.uscourts.nysd.447706.851.0
158 pg
…like
9 running away, is inadmissible and a defamation action where the
10 damages relate to her reputation. That she ran away from home
11 or was an ill-behaved child does not go to truthfulness.
12 These events also…
giuffre-maxwell
gov.uscourts.nysd.447706.983.0
24 pg
… But
2 something that is inadmissible should not become a core
3 judicial document by virtue of the fact that one party
4 inappropriately is trying to submit evidence to a jury that
5 shouldn't be allowed.
6 THE…
giuffre-maxwell
gov.uscourts.nysd.447706.561.0
22 pg
…all of the Dershowitz testimony is inadmissible under the Rules of Evidence in
any event.
FACTUAL BACKGROUND
1
Case 1:15-cv-07433-LAP Document 561 Filed 01/27/17 Page 6 of 22
Defendant designated for use in…
giuffre-maxwell
gov.uscourts.nysd.447706.1196.0
32 pg
…little weight at
23 this stage with respect to these specific documents. The
24 public's First Amendment right of access to these documents is
25 not outweighed by the prospective inadmissibility of certain of
SOUTHERN DISTRICT REPORTERS, P.C.••
…