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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, her claim that it is simply inadmissible is clearly overbroad. The Court will need to address any objection to admission of the police report in the context of the particular occasion in which it arises. For example, Defendant’s own expert — Dr. Esplin — has apparently reviewed the police report as part of his testimony. Presumably, this is because he believes that under Rule 703 the report is the kind of information that experts in this area need to rely upon. More broadly, the Palm Beach police report, which was properly used to try and refresh HE collection during her deposition, may be admitted at trial for multiple reasons. To begin with, the report may be admissible for various non-hearsay purposes — e.g., admissible because it would not be admitted for the truth of any matters asserted in the report. For instance, Defendant has indicated that she was aware of the police report. Accordingly, the report may be admissible - not to show that its contents are true - but to show Defendant’s state of mind — specifically that when Defendant called Ms. Giuffre a liar, she not only knew, she herself had abused Ms.Giuffre, she was doing so knowing that the Palm Beach Police Department had found that dozens of girls in circumstances similar to Ms. Giuffre’s had been abused. Moreover, the report may come in to show Defendant’s strong ties to Epstein — i.e., that after she knew, by way of the police report, that he had sexually abused several dozen minor girls, she continued to associate with him. Beyond that, the report may be properly admissible under exceptions to the hearsay rule. For example, it seems likely to qualify for admission under Rule 804(8) as a public record for an investigating government agency. Or, if for any reason it fails to fit Rule 804(8), it would be admissible under Rule 807, the residual hearsay clause.