EFTA00728201Set 9
2009-03-0253p14,628w
without waiving his constitutional privileges, the
information sought is privileged and confidential, and inadmissible pursuant to
the terms of the deferred prosecution agreement, Fed. Rule of Evidence ... without waiving his constitutional privileges, the
information sought is privileged and confidential, and inadmissible pursuant to
the terms of the deferred prosecution agreement, Fed. Rule of Evidence ... Epstein
Page 4
information sought is privileged and confidential, and inadmissible pursuant to
the terms of the deferred prosecution agreement, Fed. Rule of Evidence
https://www.justice.gov/epstein/files/DataSet%209/EFTA00728201.pdf
EFTA00802160Set 9
2017-09-1525p7,925w
limine seeks to prohibit any reference to evidence at trial by first having
its inadmissibility determined outside the presence of the jury. Rosa v. Fla. Power & Light ... motion in limine is especially appropriate to preclude inadmissible evidence
that will be highly prejudicial to the moving party and, if referenced in a question or by counsel,
would unlikely ... prior convictions, acquittals or arrests
is irrelevant in a civil action and thus inadmissible. Eggers v. Phillips Hardware Company, 88
So. 2d 507 (Fla.1956); Kelley v. Mutnich
https://www.justice.gov/epstein/files/DataSet%209/EFTA00802160.pdf
EFTA00585420Set 9
2017-09-1525p7,884w
limine seeks to prohibit any reference to evidence at trial by first having
its inadmissibility determined outside the presence of the jury. Rosa v. Fla. Power & Light ... motion in limine is especially appropriate to preclude inadmissible evidence
that will be highly prejudicial to the moving party and, if referenced in a question or by counsel,
would unlikely ... prior convictions, acquittals or arrests
is irrelevant in a civil action and thus inadmissible. Eggers v. Phillips Hardware Company, 88
So. 2d 507 (Fla.1956); Kelley v. Mutnich
https://www.justice.gov/epstein/files/DataSet%209/EFTA00585420.pdf
EFTA00728979Set 9
2009-08-0416p4,490w
without waiving his constitutional privileges, the
information sought is privileged and confidential, and inadmissible pursuant to
the terms of the deferred prosecution agreement, Fed. Rule of Evidence ... without waiving his constitutional privileges, the
information sought is privileged and confidential, and inadmissible pursuant to
the terms of the deferred prosecution agreement, Fed. Rule of Evidence ... without waiving his constitutional privileges, the
information sought is privileged and confidential, and inadmissible pursuant to
the terms of the deferred prosecution agreement, Fed. Rule of Evidence
https://www.justice.gov/epstein/files/DataSet%209/EFTA00728979.pdf
EFTA00808752Set 9
2011-02-2512p3,153w
abeveDecember 5, 2017, hearing, and consider the additional
arguments made herein.
Exhibit #132 Constitutes Inadmissible Hearsay
First and foremost, Exhibit #132 contains inadmissible hearsay to which no exception
applies. Hearsay ... cross examine the New York Post
reporter mandates a ruling that the article is inadmissible. See id. at 903.
Furthermore, any argument that the contents of the article are admissible ... evidence governing admissibility." Id.
(internal citations omitted).
In short, the newspaper article is inadmissible hearsay to which no exception applies.
Thus, it cannot come in.
Epstein's Purported Statements
https://www.justice.gov/epstein/files/DataSet%209/EFTA00808752.pdf
EFTA00808738Set 9
2011-02-2514p3,802w
additional arguments which are equally persuasive. They are set forth
below.
Exhibit #132 Constitutes Inadmissible Hearsay and Lacks Relevance
Exhibit #I32 contains inadmissible hearsay to which no exception applies. Hearsay ... cross examine the
New York Post reporter mandates a ruling that the article is inadmissible. See id. at 903
7
EFTA00808744
Furthermore, any argument that the contents of the article ... evidence governing admissibility." Id.
(internal citations omitted).
In short, the newspaper article is inadmissible hearsay to which no exception applies. Thus,
it cannot come in.
Exhibit #132 is Irrelevant
Edwards
https://www.justice.gov/epstein/files/DataSet%209/EFTA00808738.pdf
EFTA00078646Set 9
2021-11-1916p4,502w
because Maxwell's subpoena seeks information that is largely
(if not entirely) inadmissible under Federal Rule of Evidence 408, it fails the test in United States
v. Nixon ... because (i) compliance would be unreasonable or
oppressive; (ii) it seeks documents that are inadmissible under Rule 408 of the Federal Rules of
Evidence; and (iii) it seeks "statements ... oppressive
and, accordingly, this Court should quash the subpoena.
B. The documents sought are inadmissible under Federal Rule ofEvidence 408.
The subpoena should also be quashed because the records sought
https://www.justice.gov/epstein/files/DataSet%209/EFTA00078646.pdf
EFTA00024954Set 8
2013-02-0228p4,678w
Independently Admissible 12
C. Any Undisclosed Significance of Dr. Hall's Opinions Is Inadmissible 14
D. Dr. Hall's Fact Testimony Is Inadmissible 15
III. THE COURT SHOULD PRECLUDE ... summarized information about Minor Victim-4's past is hearsay or
otherwise inadmissible. Dr. Hall was obviously not a percipient witness to any of the conduct
discussed in his report ... F.3d 179, 197 (2d Cir. 2008). Instead, "if facts or data would otherwise
be inadmissible, the proponent of the opinion may disclose them to the jury only if their probative
https://www.justice.gov/epstein/files/DataSet%208/EFTA00024954.pdf
EFTA00301856Set 9
2011-08-1225p6,961w
Epstein is plainly prohibited by Rule 410 and Rule 11,
Further, given the clear inadmissibility of the sought after discovery and the fact that plaintiffs
have no identified a principled ... participant in the plea discussions"); FED. R. CRIM. P. 11(0 ("the
admissibility or inadmissibility of . . . a plea discussion and any related statement is governed by
Federal Rule of Evidence ... bargain. And Rules 410 and 11 plainly
prohibit this.
B.
BECAUSE PLEA NEGOTIATIONS ARE INADMISSIBLE, THE PLAINTIFFS
BEAR THE BURDEN OF PARTICULARIZING A PROPER BASIS FOR DISCOVERY
When a discovery
https://www.justice.gov/epstein/files/DataSet%209/EFTA00301856.pdf
EFTA01154260Set 9
1997-10-1011p5,336w
profession, emotional, battery, gender, coerces, acts of prostitution, reasonably
calculated to lead, legislative intent, inadmissible, compensatory, involvement, relevancy, variance
LEXISNEXIS® HEADNOTES el-lide
https://www.lexic.rom/research/hurronl,ink? m=R7RRff6677204076R3R72.dd291e
064cf& xfercite ... trial context and a party may be permitted to discover evidence that
would be inadmissible at trial, if it would lead to the discovery of relevant evidence. More Like
This ... discoverable matter. It is not ground for objection that the information
sought will be inadmissible at the trial if the information sought appears reasonably calculated to
lead to the discovery
https://www.justice.gov/epstein/files/DataSet%209/EFTA01154260.pdf
EFTA00076468Set 9
2018-06-1320p6,187w
obtain
documents that would be excluded on hearsay grounds or would otherwise be "inadmissible as
evidence at trial." United States v. Brown ... from local law enforcement agencies in
advance of trial . . . because such evidence is generally inadmissible at trial."), affd, 711 F.3d
316 (2d Cir. 2013).
Defendants contend that their request ... produce,
Defendants' request is improper because investigative files often contain many documents that
arc inadmissible on hearsay or other grounds. See. e.g., United States v. Boyle
https://www.justice.gov/epstein/files/DataSet%209/EFTA00076468.pdf
EFTA00598547Set 9
2016-03-3113p7,587w
outside the United States is an extraordinary measure
used sparingly to allow an otherwise inadmissible alien to the United States and to seek parole into the United States ... entry, and you may not be admitted
if you are found to be inadmissible under any applicable provision of INA sections 212(a), 235, or any other
provision ... regarding denial of admission to the United States. If DHS determines that you are
inadmissible, you may be subject to expedited removal proceedings or to removal proceedings before an
immigration
https://www.justice.gov/epstein/files/DataSet%209/EFTA00598547.pdf