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Epstein Web
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57 H3VOGIU1 1 sex slave, that she was getting paid wads of cash, thousands of 2 dollars by Jeffrey Epstein, and this was happening 24/7. And a we asked in discovery, and we got a bunch of records, not only 4 of her working at the Roadhouse Grill, but also of her working 5 at a bunch of other restaurants, at a veterinarian's office, 6 all kinds of things during the period of time that she says she 7 was a -- what is commonly known as a sex slave, is how she 8 described it in her papers. 9 Your Honor, she compounded the lie about the theft 10 because she wrote a book manuscript, as you know. And in that aL, book manuscript, she describes that it was not her who took the 12 money from the tip jar, it was her boyfriend, Tony Figueroa, 13 and that's also what she testified during her deposition. 14 She said, for example, that she didn't commit the 15 theft, that he came in at the end of her shift, and while she 16 wasn't looking, he's the one that took the tips. a Well, we deposed Tony Figueroa, and Tony Figueroa, 18 your Honor might be surprised to hear, is a gentleman with 18 several felonies to his name, which he gladly recounted on the 20 witness stand on videotape. He talked about all the thefts he eal has committed, thefts from a video store, he was charged with 22 felonies, he was put on probation for ten years, he recently 23 had gotten out, but he actually denied that he was the one who 24 took the money from the tip jar. 25 So there's the lie, there's the tip jar theft, then SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011360
February 7, 2026 at 1:04 AM
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56 H3VOGIU1 1 using drugs now that may affect her memory, or if she's 2 inappropriately used drugs in the meantime, all of that would a go to whether or not she truly has the emotional distress that 4 she claims. 5 Motion in limine 9, plaintiff's criminal history. If 6 I understand plaintiff's argument, they do not want her to be 7 cross examined either under 608(b) or 405(b) with regard to a 8 specific instance of dishonesty; that is, her theft from her 9 employer. 10 There are legions of cases, your Honor, that find ide theft to be a crime of dishonesty and admissible for proof of 12 character of dishonesty. 13 Not only, your Honor, did she get charged by the 14 authorities in Florida with this crime of theft from her 15 employer, an arrest warrant was issued for her, that arrest 16 warrant was outstanding at the time she, quote/unquote, fled to a Thailand. That arrest warrant remained outstanding until the 18 year, I think 2009 or 2010, when it was quashed. Plaintiff 18 failed to come back to this country during that entire time. 20 It got quashed because it had been such a long passage of time. Pal THE COURT: Who was the employer? 22 MS. MENNINGER: It was the Roadhouse Grill, your 23 Honor. It was a burger joint. And she was working at that 24 Roadhouse Grill in March of 2002 during the period of time she 25 claims that she was a sex slave. She claimed that she was a SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011359
February 7, 2026 at 1:04 AM
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55 H3VOGIU1 1 records may or may not be admissible depending on what she says 2 on the stand, but they are her statements and they are, a therefore, potentially admissible as admissions of a party 4 opponent under 801(d) (2). 5 Moreover, her doctor is the one who wants to testify 6 about her need for medications going forward, and he has been 7 the one who's talked about her previous use of medications. 8 Her Colorado doctor testified that she had misled him and not 9 fully disclosed her need for prescription medications, and 10 there's also the question about whether or not, if she opens ide the door and says she's properly used medications for 12 post-traumatic stress disorder, then we should be able to 13 examine her, not only with respect to that, but her other use 14 of prescription and illegal drugs. 5 And your Honor, I think it is inappropriately limiting 16 to say we can only talk about her use of drugs during the a period of '99 to 2002 because any drug use that she has used in 18 the meantime can go to establish whether or not she truly had 18 post-traumatic stress disorder or any other mental health 20 disorder. Pal She has filed a lawsuit asking for $30 million in 22 emotional distress, pain and suffering, and her doctor is going 23 to testify that she needs medications as a part of managing 24 that pain and stress and emotional distress. If she's been 25 using drugs in the interim that may affect her memory, if she's SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011358
February 7, 2026 at 1:03 AM
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54 H3VOGIU1 1 remember the names of the foreign presidents that she was 2 trafficked to, and these other famous people, because she was a taking so many drugs she just can't remember. 4 Obviously, your Honor, a witness' ability to perceive 5 and recall and relate events that happened a long time ago that 6 were affected by drug use need to be brought to light before 7 the jury. 8 The second issue, your Honor, relates to the use of 9 prescription medication. What you heard plaintiff say is they 10 would like to introduce evidence that she's taking prescription ide drugs properly, but they want to exclude us from cross 12 examining her about that to see whether or not she was taking 13 prescription drugs improperly. That's called cross 14 examination, your Honor. 5 Her use of prescription drugs has been well-documented 16 in her doctor's records, and she has made false statements to a her doctors regarding her need for prescription drugs. She's 18 gone from one doctor to the next, telling one that she hasn't 18 taken any Valium for years, and then the next one -- and then 20 we have the records showing that that's just not true. She's Pal told doctors that she was stressed out about a big litigation 22 in New York, she told a doctor that in the year 2014, this 23 lawsuit wasn't filed until 2015, so she's made statements to 24 doctors that are inaccurate. 25 Your Honor, her statements reflected in her medical SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011357
February 7, 2026 at 1:03 AM
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53 H3VOGIU1 1 these other things that are circulating about her that have 2 nothing to do with Ms. Maxwell. a Mr. Cassell referred to our expert Phillip Esplin, 4 Dr. Esplin, and saying that he agreed not to refer to Virginia 5 Roberts as a prostitute. Your Honor, that came up in the 6 context of a cross examination in which he said he has no idea 7 whether any of her claims are credible or not. He does not 8 believe it's within the province of the psychiatrist to be G making credibility determinations. So he was not in any way 10 suggesting, in fact he testified for hours to the contrary, ide that he knows whether her claims of being a prostitute are true 12 or not true, and he agreed not to talk about. 13 The only context in which I think this comes up, your 14 Honor, are witnesses or people on the internet who have made 5 disparaging remarks about the plaintiff that have to be the 16 subject of her reputation and her request for damages that she a says are related to Ms. Maxwell. 18 Plaintiff's drug abuse, motion in limine number 8. 18 They have conceded, as they must, that the period of time about 20 which Ms. Giuffre is testifying is fair game for her discussion Pal of all of her illegal drug use. And it wasn't just 22 prescription drugs, she has testified that she was on a number 23 of different drugs at the time, and that because of those 24 drugs, her memory of events from 2000 are, quote/unquote, 25 foggy. And she says that's one of the reasons she can't SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011356
February 7, 2026 at 1:03 AM
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52 H3VOGIU1 1 claiming she has damages of post-traumatic stress disorder, and 2 she is the one who is going to call to the stand her a psychiatrist to talk about that patient, and she is the one 4 that gave him evidence about these other acts to him and on 5 which he has relied in reaching his conclusions. It is 6 impossible for us to not be able to cross examine her expert 7 about preexisting PTSD caused by incidents and events unrelated 8 to Ms. Maxwell. 9 Motion in limine number 7, whether or not Ms. Giuffre 10 can be called a prostitute. Your Honor, no one in this case, ide no counsel, nobody that I'm aware of involved with the 12 litigation has referred to Virginia Giuffre as a slut. That is 13 something that plaintiff's counsel has brought up, and you will 14 notice there is absolutely no cite in any record, in any 5 document referring to her as such. 6, What has come up, your Honor, are internet sites in a which Ms. Giuffre has been called all kinds of things that are 18 unrelated to Ms. Maxwell, that do not cite Ms. Maxwell. For 18 example, her friends gave interviews to the press in which they 20 described -- and this is attached as my Exhibit L -- described Pal Virginia Giuffre as "a money hungry sex kitten who enjoyed her 22 lavish lifestyle". We cannot talk about plaintiff's reputation 23 on the internet without talking about what is out there on the 24 internet. We cannot cross examine her or cross examine her 29 experts about what her reputation is if we can't ask about SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011355
February 7, 2026 at 1:02 AM
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51 H3VOGIU1 1 the internet anywhere quoted in whole. 2 Also, Alan Dershowitz widely circulated his denials of a plaintiff's claims. He was on Good Morning America, he was on 4 CNN's Nancy Grace Show, he was on Fox News. All of those 5 places he called Virginia Roberts a liar, and a serial liar, 6 and other things. 7 We are entitled, your Honor, both through cross 8 examination of plaintiff as well as cross examination of her 9 experts, to challenge whether or not anything said by 10 Ms. Maxwell caused damage to her reputation or whether other ide people calling her a liar on national news and international 12 news is, in fact, the cause of any damage to her reputation. 13 She is the one, of course, who has put her reputation 14 at issue. Having the Duke of York and Buckingham Palace issue 15 denials is not hearsay, your Honor, it is offered for the fact 16 that the denial was widely circulated and very likely a contributed to people considering plaintiff to be a liar. 18 Motion in limine number 6, plaintiff's sexual history 19 and reputation. This salient point, your Honor, of course, 20 again, under 405(b), is that once you have put your reputation Pal for being a liar in question, then other specific instances of 22 false claims become highly relevant and probative of your 23 character for truthfulness, particularly with regard to sexual 24 assault and sexual abuse. 25 Furthermore, your Honor, plaintiff is the one who's SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011354
February 7, 2026 at 1:02 AM
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50 H3VOGIU1 1 response an FBI 302 motion -- excuse me -- statement of -- she 2 claims is authentic, but she doesn't know how it was redacted, 3 doesn't explain how it's redacted, but she wants to admit that 4 into evidence. 5 We are actually offering to put on the stand the 6 person who submitted the FOIA request to explain what was 7 requested and what was received. That is not expert testimony 8 your Honor, that's chain of custody. 9 With regard to motion in limine number 5, evidence of 10 denials by Prince Andrew and Buckingham Palace. Again, your ide Honor, in a defamation case -- and I'm now quoting from 12 plaintiff's treatise that they cited throughout their response 13 and their reply -- excuse me -- "In defamation cases, 14 defendants can also prove that other liables and rumors about 5 the claimant are circulating, at least if they are widespread, 16 to demonstrate that it is not what the defendant said about the a plaintiff that causes her reputation to suffer but what others 18 said." 18 Plaintiff also cites Sack of Defamation. He supports 20 our position, your Honor. Here, we have a statement by Pal Buckingham Palace that was issued on the internet and widely 22 circulated. There is also a videotape of Prince Andrew denying 23 Virginia Roberts' claims. Both of those were far more 24 circulated than anything Ms. Maxwell said, as evidenced by the 25 fact that plaintiff can't even find Ms. Maxwell's statement on SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011353
February 7, 2026 at 1:02 AM
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49 H3VOGIU1 1 Jeffrey Epstein and Virginia Roberts. 2 Plaintiff's counsel has said statements made in the a newspaper articles are hearsay. That is often true, but when 4 it's plaintiff's statement in a news article, it's called a 5 party admission. 6 Plaintiff complains that she didn't have the 7 opportunity to depose President Clinton. Your Honor, 8 plaintiff's counsel sought to depose President Clinton in their 9 reply brief at the end of June, 2016, about a week before 10 discovery was to close. They didn't even mention it in their ide opening brief, they raised it in docket number 211. 12 In that request, which I didn't have an opportunity to 13 object to because it came in reply, she said she wanted to 14 depose him to, "establish his close personal relationship with LS Epstein", she said nothing about wanting to see whether he had 6, been on the island, whether he flew in a helicopter, or a anything like that. 18 With regard to Louie Freeh, your Honor, we disclosed 19 him as a witness in our Rule 26 disclosures last March -- 20 excuse me -- February of 2016. Plaintiff made no effort to try eal to depose him, made no effort to find out his basis of 22 knowledge. We produced in discovery his report in which he 23 submitted a FOIA request. 24 Yesterday, you will recall Ms. McCawley testifying 29 about how she, herself, issued a FOIA request and got in SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011352
February 7, 2026 at 1:02 AM
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48 H3VOGIU1 1 helicopter with him by plaintiff in her Sharon Churcher 2 published articles. a And here, in January of 2015, Ms. Maxwell is saying he 4 was never on the island. It doesn't depend on Louie Freeh or 5 anybody else. That's obviously -- in this particular email, 6 your Honor, she's cataloged all of the changed stories of 7 Virginia Roberts, all of the lies Virginia Roberts has told, 8 all of the different news articles in which those lies were 9 told, and said that this is going to be the basis of her press 10 complaint in the UK. aL, Likewise, on the next page, your Honor, GM009, at the 12 bottom, again, she specifically refutes the claims about Bill 13 Clinton being on the island and says, "He was never there." 14 Right after that, she says, "Virginia discussed that Al Gore 5 and his wife Tipper were also guests on the island." And 6, Ms. Maxwell writes, "They have also never been on the island, a and I don't believe they even know Jeffrey Epstein." 18 So when the jury is asked to consider what Ms. Maxwell 18 meant when she issued, through her attorney and her press 20 agent, the January 2nd, 2015 statement, we have a Pal contemporaneous document drafted by her that was produced in 22 discovery a year ago. None of it refers to the Jane Doe 102 23 complaint, none of it refers to the CVRA joinder motion. None 24 of it. It refers simply to press allegations that have been 25 floating around about her and about her involvement with SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011351
February 7, 2026 at 1:01 AM
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47 H3VOGIU1 1 Complaints", because Ms. Maxwell says she's preparing a press 2 complaint in the UK, in other words a legal action, the third a page, your Honor, is the document that was attached that was 4 produced over a year ago. 5 How this document reads at the top, "Drafted by 6 Ms. Maxwell. I have copied direct lines and quotes from 7 articles, and my comments are in orange after the quote. The 8 relevant article that the quotes came from is listed below the 9 last quote. Below, I think, are some of the irrefutable 10 contradictions and interesting additional details that can be ide used in the letter to the mail and in the following press 12 complaints. In addition, this article on Rothstein you may 13 find helpful. 14 "What is the number one lie that Ms. Maxwell points LS to? Number 1. Bill Clinton identified in lawsuit against his 16 former friend and pedophile Jeffrey Epstein who had regular a orgies." 18 And then Ms. Maxwell's commentary directly afterwards, 18 in a quotation, "Huge problem is that Clinton never came to the 20 island." Pal Your Honor, in plaintiff's response -- excuse me -- 22 reply brief, they claim Ms. Maxwell had no knowledge in early 23 January, 2015 that Bill Clinton had never been to the island. 24 Obviously, she had knowledge of that because she was claimed to 25 have been there with him and claimed to have flown on a SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011350
February 7, 2026 at 1:01 AM
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46 H3VOGIU1 1 say, "You got it wrong. I never saw Ghislaine Maxwell on a 2 helicopter with Bill Clinton. I never said that to you,' she 3 did none of that. 4 So your Honor, the last document, and it really, I 5 think, actually helps clarify the question your Honor raised 6 when you came out to court this morning, is an email. It's an 7 email from Ghislaine Maxwell to Alan Dershowitz, January 6, 8 2015, and it has a document attached called "Four Press 9 Complaints". 10 Your Honor will notice that this document is not ide marked confidential, it was produced by Ms. Maxwell over a year 12 ago, it is marked Ghislaine Maxwell 0006, and it's a 13 communication between herself and Alan Dershowitz, someone with 14 whom she does not have a joint defense agreement, and that's 5 why she produced this email. 6, Your Honor, this email, as you can tell from the date, a was sent four days after the allegedly defamatory statement at 18 issue. It reflects Ms. Maxwell's dossier of all of the 18 statements from the papers that have been shown to be 20 completely untrue or show inconsistency in her story. Each Pal article is listed so you can find that link that references the ae lies are inconsistencies. 23 Your Honor, if you look at this document that was sent 24 just a few days after the January 2nd email, and you turn to 25 page 3, which is actually the attached document, "Four Press SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011349
February 7, 2026 at 1:01 AM
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45 H3VOGIU1 E THE COURT: I've read it. 2 MS. MENNINGER: -- Sharon Churcher. 3 THE COURT: Yes, I've read it. 4 MS. MENNINGER: Okay. It's the one in which 5 Ms. Giuffre, on March 5th, 2011, gave a long and lengthy 6 interview to Sharon Churcher describing her experience on the 7 island with Bill Clinton, with Al Gore, with Al Gore's wife, 8 with all kinds of famous people. And the island event featured 9 large and media coverage. If you notice the date of that 10 article, your Honor, it's March 5th, 2011. ide The next document I provided is a press statement 12 issued by Ghislaine Maxwell on March 10th, 2011, so five days 13 later, in which she writes, care of her attorneys, "Ghislaine 14 Maxwell denies the various allegations about her that have 5 appeared recently in the media. These allegations are all 16 entirely false." Ley Your Honor, the last document I would like to direct 18 your attention to -- by the way, after Ms. Maxwell published 19 this press release, Virginia Roberts did not sue her, she did 20 not claim that she had been emotionally distressed or injured Pal by being called, essentially, a liar in this particular press 22 release. And also, with respect to the Bill Clinton article, 23 your Honor, the evidence at trial will show a substantial 24 number of emails between Virginia Roberts and Ms. Churcher 29 contemporaneous with this article. In none of them does she SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011348
February 7, 2026 at 1:00 AM
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44 H3VOGIU1 1 plaintiff a liar, to call her claims obvious lies that have 2 been shown to be untrue demands the same meaning. Plaintiff a cannot be making claims shown to be untrue that are obvious 4 lies without being a liar." 5 Ms. Maxwell has stated in her answer after that that 6 her statement was true; that is, plaintiff is a liar. She is 7 thus entitled by Rule 405 to introduce all forms of character 8 evidence, including specific instances of conduct, opinion, and G reputation. 10 What does that evidence look like? Plaintiff's mother aL, described her as a liar, plaintiff's fiance described her as a 12 liar, plaintiff's employer from 2002 described her as a liar. 13 Your Honor, I would like to start with the first one 14 that plaintiff started with, and that is motion in limine 2, 5 which is Bill Clinton being on the island. 16 Ms. Maxwell is going to testify at this trial, and a she's going to testify regarding the obvious lies that 18 plaintiff told her. One story that plaintiff has told is that 19 Ms. Maxwell was on the island with Bill Clinton and herself at 20 a dinner party. If I may approach, your Honor? I have three 21 exhibits. Two for now. 22 THE COURT: I think in duplicate, to the extent that I 23 think. 24 MS. MENNINGER: I'd like to first direct the Court's 29 attention to the news article by -- SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011347
February 7, 2026 at 1:00 AM
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43 H3VOGIU1 1 so that we can keep the fact that we have done something bad 2 that should then be held against our client away from the jury. a But all these remaining things we are in agreement, I 4 think with the suggestion you were perhaps making a moment ago, 5 we can deal with these issues at trial. 6 That's our omnibus motion in limine, your Honor. 7 THE COURT: Thank you. 8 MS. MENNINGER: The omnibus motion reads like a list 9 of everything plaintiff has lied about or anything that would 10 undercut her claim for damages. ide Plaintiff quoted Passim in her reply brief froma 12 particular federal evidence treatise, and I would like to tell 13 the Court, she left out the most important parts, and that is 14 the ones that relate to 405(b). 15 As that treatise reads, "Character is an element of a 16 defense in a defamation case if the defending party claims that a the statements in question are true and seeks to prove that the 18 plaintiff has the character ascribed to her or to reduce 18 damages by showing that her reputation is so bad the statement 20 did no harm. eal "In such cases, pursuant to Rule 405, all forms of 22 character evidence are admissible wherever relevant, including 23 opinion, reputation, and specific instances of conduct." 24 As your Honor found in our motion to dismiss ruling of 25 February 29th of last year, "Though defendant never called SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011346
February 7, 2026 at 1:00 AM
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42 H3VOGIU1 1 I am about done at this point. 2 With regard to the remaining issues, you'll be happy a to hear that I think things can be sped up. We believe that 4 these issues should simply be, as your Honors I think was 5 suggesting a moment ago, deferred to trial. 6 Items 21, 22, 23, 24, 25, 26, 27, 28, and 29, those 7 were sort of just kind of protective measures. The one 8 footnote or caveat we would add to that, your Honor. We think 9 this gets punted to the trial, but we would simply ask your 10 Honor to direct defense counsel before they let the cat out of ide the bag on any of these that there be a sidebar or hearing 12 outside of the jury just so that, you know, our motion in 13 limine doesn't become moot because they've already effectively 14 put it in front of the jury. 5 The one that's of particular concern is alleged bad 16 acts by the defense team. At various points, I think your Ley Honor, unfortunately, has seen some, you know, frankly 18 aggressive language directed to the plaintiff's team here by 18 the defense team. We're prepared to respond to each and every 20 one of those allegations. We've tried not to get into the back 21 and forth because we think it's irrelevant. ae But if there was to be some kind of an attack launched 23 on any of the members of the Boies Schiller Firm, of Brad 24 Edwards, myself, we would ask that we be given leave to address 25 that at sidebar, in-camera, or outside the presence of the jury SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011345
February 7, 2026 at 12:59 AM
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41 H3VOGIU1 1 or was not privileged. We don't take jury evidence on that, 2 you know, Judge Marra's ruling, and therefore, that should be 3 excluded. So that is item number 19. 4 Let me turn then to item 20, and I'm handling that. 5 This is essentially a hearsay exercise. We want information to 6 be excluded regarding Rebecca Boylan. Why? Because Rebecca 7 Boylan has not been deposed and is not going to be a witness in 8 the case. 9 As we understand what the defendant is planning to do, 10 she's planning to call Mr. Dershowitz. Mr. Dershowitz is going ide to say Ms. Boylan told him that Ms. Giuffre told him something, 12 and so we have the classic hearsay within a hearsay situation. 13 The problem, of course, is that Boylan is not here. 14 The defendant's pleadings say, ah-hah, but this is an 5 admission by Ms. Giuffre, and it would be if Ms. Boylan were on 6, the stand so we could ask her questions about, well, did a Ms. Giuffre really say that? And what did she mean? And 18 wasn't she saying that she's been abused by Ms. Maxwell? But 18 they want to skip over that intermediate stuff, have Dershowitz 20 describe what Boylan describes Ms. Giuffre said, and that's Pal obviously -- and then I'm assuming Dershowitz is going to put 22 his spin on what Ms. Boylan allegedly said to him. There are 23 no set of circumstances in which that hearsay within hearsay 24 could be admissible because Ms. Boylan has not been deposed, 25 and is not here, it's rank multiple hearsay. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011344
February 7, 2026 at 12:59 AM
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40 H3VOGIU1 1 Of course, we would want to explain that there were nine 2 separate reasons why those allegations were included. Judge a Marra referred to the first of the nine reasons. We have eight 4 other additional reasons why those were included. It would 5 essentially, again, be a mini trial about, well, what does a 6 joinder motion mean? Did you file under Rule 15? It should 7 have been under Rule 21. What did the judge do? 8 It has no bearing at all on the issues in the case, 9 and it, of course, has very substantial prejudicial effect 10 because it leads to a confusion of the jury. The jury's trying ide to figure out, well, what's going on in the Crime Victims 12 Rights Act case when the issue is whether or not Ms. Giuffre 13 defamed. 14 Now, there is an issue in their pleadings. They say, 5 well, this could end up being relevant because there might be 16 some kind of a privileged setting issue. Again, I think your a Honor correctly was pointing out a moment ago, if things show 18 up in the trial, it's possible that something could change, but 18 we don't anticipate that becoming an issue in the trial at this 20 point. If the issue of whether this was a privileged setting eal somehow becomes an issue in the case, then it would be time to 22 revisit that during the trial. 23 In any event, issues of whether this was a privileged 24 setting or not aren't litigated in front of the jury, that's a 25 legal issue for your Honor to determine whether the setting was SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011343
February 7, 2026 at 12:59 AM
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39 H3VOGIU1 1 Dershowitz that we would then believe, in light of your ruling, 2 should be redacted. But until we have any rulings from your a Honor restricting the case, it's our position that all -- 4 THE COURT: But you don't have an edited version of 5 the intervention motion that you would like me to consider. 6 MR. CASSELL: We would propose one once we get rulings 7 from your Honor on the motions in limine. 8 THE COURT: By the way, just parenthetically, folks, 9 these motions in limine are good fun, and we're all having a 10 nice time, but they're not binding. I mean by that, I'm ide expressing my view, or I will, I hope, some day express my view 12 on these issues, but the trial may turn in a different 13 direction and, you know, who knows. Okay. 14 MR. CASSELL: We understand. And one of the reasons 5 we have not proposed a redacted joinder motion, that showed up 16 in a reply brief from the defendant, we didn't move to file a a surreply with a possible motion. We think the best way to 18 proceed, and we're happy to get guidance from your Honor, but 18 once we have rulings from you on what's in the case and what's 20 out, then we might go through the joinder motion. But where Pal we're sitting today, the joinder motion goes in in its 22 entirety. 23 But what does not come in is then, all right, that's a 24 legal pleading. Gee, I wonder what happened. Judge Marra made 25 a ruling, we don't need to get into the details of that ruling. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011342
February 7, 2026 at 12:59 AM
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38 H3VOGIU1 1 rights of similarly situated victims" -- 2 THE COURT: I'm familiar with it. a MR. CASSELL: Okay. Right. So that's Judge Marra's 4 ruling. 5 And you understand that was obviously on a technical 6 joinder issue. The joinder issue, whether that was a 7 good joinder motion or a bad motion, has nothing to do with 8 whether or not Ms. Giuffre was defamed. 9 THE COURT: How do you propose to handle the joinder 10 motion evidentially? ide MR. CASSELL: Right. We think the joinder motion 12 should simply come into evidence as the pleading to which 13 Ms. Giuffre -- I'm sorry -- Ms. Maxwell was responding. 14 THE COURT: Lock, stock, and barrel? 5 MR. CASSELL: So we are obviously waiting for guidance 16 from your Honor. For example, if you say, look, Dershowitz, a let's just not get into that, that's -- 18 THE COURT: That didn't answer my question. Please. 18 MR. CASSELL: I apologize. 20 THE COURT: You talk about many trials, many Pal arguments. You want to put in the entire motion? 22 MR. CASSELL: Yes, unless your Honor -- I want to be 23 direct here. 24 Yes. However, if you say, look, Dershowitz isn't 25 coming into this case, there are some allegations about SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011341
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37 H3VOGIU1 E that Edwards and Cassell made in this other lawsuit are somehow 2 binding on Ms. Giuffre. Edwards and Cassell had separate legal a counsel, Florida attorney Jack Scarola. Whatever was going on 4 in that case isn't binding on Ms. Giuffre. 5 Under the relevant rules, an attorney's statements are 6 binding on a client only on a matter within the scope of the 7 relationship. And this was vindicating separate professional 8 interests, this was not vindicating some interest of i) Ms. Giuffre. 10 So for all those reasons, we ask that the defamation ide litigation between Dershowitz and Edwards and Cassell be 12 excluded. Of course, you have the separate issue of Dershowitz 13 in front of you already. 14 Let me turn then to point number 19. Here again, we 5 have a narrow issue presented to your Honor. We are asking 16 that you exclude Judge Marra's ruling on the joinder motion. a As your Honor is well aware, the triggering event in this case 18 was when Ms. Giuffre, then known as Jane Doe Number 3, filed a 18 motion to join Jane Doe 1 and Jane Doe 2 in the Florida pro 20 bono Crime Victims Rights action. eal Now, Judge Marra denied that motion to join, but at 22 the same time he said, "The reason I'm denying the motion to 23 join is you can participate in the case in other ways without 24 being a formal party." He cited, and I quote, "Of course, Jane 25 Doe 3 can participate in this litigated effort to vindicate the SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011340
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36 H3VOGIU1 1 without getting into the details of another separate lawsuit 2 that did not involve Ms. Giuffre as a party, and so we've moved 3 in limine. 4 And let me make clear that I emphasize the narrowness 5 of our motion here. We seek to preclude evidence involving 6 that litigation. Your Honor has already heard from my 7 colleague, Ms. McCawley, who has presented our argument for why 8 Dershowitz should not be in this case at all, and of course, if 9 we prevail on point 1, this point becomes irrelevant. 10 But in addition to point 1, we don't need to be ide getting into the details of the separate lawsuit. It's not 12 relevant to the case of Giuffre versus Maxwell. Defendants, in 13 their responsive brief, if I understand correctly what they say 14 is, oh, well look. Why didn't Ms. Giuffre join the lawsuit or 5 why hasn't she filed a lawsuit against Dershowitz? What's 16 going on there? Ley Well, of course, your Honor is aware, there are a 18 variety of statutes of limitation around the country, and 19 indeed around the world. Ms. Giuffre has not -- those statutes 20 have not all run at this point. There are varying Pal considerations that go into whether or not someone like 22 Ms. Giuffre would file a lawsuit, and these issues shouldn't be 23 discussed in front of the jury. That's nothing to do with this 24 particular lawsuit. 29 Moreover, defendant apparently argues that statements SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011339
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35 H3VOGIU1 1 "mistake", and that was indicated in the pleading withdrawing 2 the summary judgment motion as follows: "Edwards and Cassell a do acknowledge that the public filing in the Crime Victims 4 Rights Act case of the client's allegations against Defendant 5 Dershowitz became a major distraction from the merits of the 6 well-founded Crime Victims Rights Act case by causing delay 7 and, as a consequence, turned out to be a tactical mistake." 8 "Tactical mistake." "For that reason Edwards and Cassell have 9 chosen to withdraw the referenced filing as a condition of the 10 settlement." ide That's all a very interesting lawsuit, but that's a 12 lawsuit that does not have Ms. Giuffre as a party. It was 13 Cassell and Edwards versus Alan Dershowitz, with claims going 14 back and forth. Cassell and Edwards were, of course, 5 vindicating their own professional interests and their 16 professional reputation responding to the attacks that had been a made by Mr. Dershowitz, and they chose to settle the case, as 18 did Mr. Dershowitz, for undisclosed financial reasons. 19 And also, from the fact I think your Honor is now 20 aware, that there were some witnesses who were not available. Pal Sarah Ransome has come forward in this case to say that she was 22 a traffic to Alan Dershowitz in the same way that Ms. Giuffre 23 alleges, and that was information that has only recently become 24 available. 25 The point is, you have enough business on your hands SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011338
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34 H3VOGIU1 1 amount has something that the jury should consider. Your 2 Honor, the papers set forth very clearly that there's a a specific rule of evidence directly on point with respect to 4 settlement agreements, and they can't be used in that manner. 5 Your Honor, we cite to our papers on that with respect 6 to any prior settlement agreement being entered into evidence 7 at the trial. 8 MR. CASSELL: I believe I have the next three. 9 Item 18 then is defamation litigation. And your Honor 10 is aware that there was a separate lawsuit that's spun out of aa. this situation where Cassell and Edwards filed a defamation 12 action in Florida State Court against Alan Dershowitz. Alan 13 Dershowitz then counterclaimed. That was litigated in Florida 14 State Court for about a year. Ultimately, the parties settled 15 their differences in an undisclosed financial arrangements and, 16 as part of the comprehensive settlement, Cassell and Edwards a then withdraw summary judgment against Dershowitz. 18 It was as expressly understood when the parties agreed 19 upon this confidential settlement, there was then a statement 20 in which it was said that Ms. Giuffre reaffirms her Pal allegations, and the withdrawal of the reference to the filings 22 is not intended to be and should not be construed as being an 23 acknowledgment by Edwards and Cassell that the allegations made 24 by Ms. Giuffre were mistaken. 25 There was a portion of the statement that talked about SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011337
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33 H3VOGIU1 1 might be admitted at trial. Both are orders resolving 2 discovery disputes under Rule 26. 3 Apart from her medical records, while defendant was 4 abusing her, such as when defendant took her to a hospital here 5 in New York when she was only 17, and the psychological records 6 related to Ms. Giuffre, which have been produced, which 7 incidentally are from 2011 and name defendant as her abuser, no 8 other medical records are relevant and should be excluded under i) Rule 401. 10 Ms. Giuffre is seeking damages for emotional distress ide from defamation. It does not open up the flood gates to every 12 single medical issue she's ever had in her life. Ms. Giuffre 13 has produced records, everything from treatment for a ferret 14 bite to details of her giving birth. These are not relevant, 5 and we can have a ruling in advance of trial that these things 16 should be excluded. a Defendant only seeks to use these records to confuse 18 the issues before the jury. Defendant offers no reason for 18 addressing the relevance of such documents one by one at trial 20 and I think these can be safely excluded at this juncture. eal MS. McCAWLEY: Your Honor, next is number 17, which we 22 addressed in our papers, as well, about the prior settlement 23 agreement. You've heard about it in this case, and we have 24 said that that should not come into evidence. 25 I think they'd like to use it to propose that that SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011336
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