EFTA00613999Set 9
2011-07-2125p7,382w
apply to
the "oral contract" claim, as the parol evidence rule only operates to exclude evidence
where there is an integrated, written agreement, and does not apply to an alleged ... Wife (L. 0.), 418 A.2d 994, 996 (Del. 1980) ("The parol
evidence rule excludes evidence of additional terms to a written contract, when that
contract is a complete integration
https://www.justice.gov/epstein/files/DataSet%209/EFTA00613999.pdf
EFTA01077375Set 9
2011-07-2125p7,381w
apply to
the "oral contract" claim, as the parol evidence rule only operates to exclude evidence
where there is an integrated, written agreement, and does not apply to an alleged ... Wife (L. 0.), 418 A.2d 994, 996 (Del. 1980) ("The parol
evidence rule excludes evidence of additional terms to a written contract, when that
contract is a complete integration
https://www.justice.gov/epstein/files/DataSet%209/EFTA01077375.pdf
EFTA00090721Set 9
2021-09-0352p13,922w
minimum, this Court should hold a Dauber: hearing. 23
IV. THE COURT SHOULD EXCLUDE EVIDENCE RELATED
24
V. THE GOVERNMENT CONCEDES THAT IT WILL NOT OFFER EVIDENCE OF MS.
MAXWELL ... which to do so.
5 Bear in mind that the government also moved to exclude evidence that these same "abused"
individuals reported to the police that they had no interactions ... minimum, therefore, this Court should hold a Daubert hearing.
IV. THE RT SHOULD EXCLUDE EVIDENCE RELATED
The government's arguments in favor of admitting evidence related
as direct evidence
https://www.justice.gov/epstein/files/DataSet%209/EFTA00090721.pdf
EFTA00794556Set 9
2017-03-31159p41,795w
this case.
8 Courts in the Southern District of New York routinely
9 exclude evidence of prior drug use under both of these rules,
10 as fully briefed ... turning to point number 12. We've
11 asked the Court to exclude evidence relating to the tax
12 compliance of Ms. not-for-profit Victims Refuse
13 Silence. Rule ... chief and is relevant
19 evidence.
20 On point number 13, we move to exclude evidence
21 relating to Ms. alleged tax compliance. Your Honor,
22 this is a defamation
https://www.justice.gov/epstein/files/DataSet%209/EFTA00794556.pdf
EFTA00087774Set 9
2007-05-0121p5,654w
GHISLAINE MAXWELL,
Defendant.
x
GHISLAINE MAXWELL'S MOTION IN LIMINE
TO EXCLUDE EVIDENCE RELATED TO ACCUSER-3
Christian R. Everdell
COHEN & GRESSER LLP
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON ... Evid. 704 12
iii
EFTA00087777
Ghislaine Maxwell respectfully moves in lintine to exclude evidence related to
Accuser-31 because it is not probative of the charged conspiracies and inadmissible under ... would mislead the jury and
unfairly prejudice Ms. Maxwell. Accordingly, the Court should exclude evidence related to
Accuser-3.
BACKGROUND
The original indictment against Ms. Maxwell, filed on June
https://www.justice.gov/epstein/files/DataSet%209/EFTA00087774.pdf
EFTA00074479Set 9
2007-05-0121p5,698w
GHISLAINE MAXWELL,
Defendant.
x
GHISLAINE MAXWELL'S MOTION IN LIMINE
TO EXCLUDE EVIDENCE RELATED TO ACCUSER-3
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York ... Evid. 704 12
iii
EFTA00074482
Ghislaine Maxwell respectfully moves in lintine to exclude evidence related to
Accuser-31 because it is not probative of the charged conspiracies and inadmissible under ... would mislead the jury and
unfairly prejudice Ms. Maxwell. Accordingly, the Court should exclude evidence related to
Accuser-3.
BACKGROUND
The original indictment against Ms. Maxwell, filed on June
https://www.justice.gov/epstein/files/DataSet%209/EFTA00074479.pdf
EFTA00612250Set 9
2017-03-31158p38,362w
turning to point number 12. We've
11 asked the Court to exclude evidence relating to the tax
12 compliance of Ms.
13 Rule 401 is the first rule under ... chief and is relevant
19 evidence.
20 On point number 13, we move to exclude evidence
21 relating to Ms. alleged tax compliance. Your Honor,
22 this is a defamation ... your
6 Honor, where the cause of action is centered on nontax
7 compliance exclude evidence of prior tax noncompliance when it
takes the case too far afield
https://www.justice.gov/epstein/files/DataSet%209/EFTA00612250.pdf
EFTA00622711Set 9
2017-06-306p1,407w
LIMINE TO STRIKE THE JUNE 30, 2017 AFFIDAVIT OF JEFFREY EPSTEIN AND
TO EXCLUDE EVIDENCE AS TO WHICH DISCOVERY WAS WITHHELD UNDER
CLAIMS OF PRIVILEGE
Bradley J. Edwards ... Limine to Strike the June 30, 2017
Affidavit of Jeffrey Epstein and to Exclude Evidence As to Which Discovery Was Withheld Under
Claims of Privilege and states:
In response ... Limine to Strike the June 30, 2017 Affidavit of
Jeffrey Epstein and to Exclude Evidence As To Which Discovery Was Withheld Under Claims of Privilege
Page
https://www.justice.gov/epstein/files/DataSet%209/EFTA00622711.pdf
EFTA00803113Set 9
2017-03-31158p39,273w
turning to point number 12. We've
11 asked the Court to exclude evidence relating to the tax
12 compliance of Ms.
13 Rule 401 is the first rule under ... chief and is relevant
19 evidence.
20 On point number 13, we move to exclude evidence
21 relating to Ms. alleged tax compliance. Your Honor,
22 this is a defamation ... your
6 Honor, where the cause of action is centered on nontax
7 compliance exclude evidence of prior tax noncompliance when it
takes the case too far afield
https://www.justice.gov/epstein/files/DataSet%209/EFTA00803113.pdf