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Case 1:15-cv-07433-LAP Document 1331-36 Filed 01/05/24 Page 9 of 10
quite clear that the types of questions posed to Mr. Epstein, leading pejorative questions,
designed to suggest that the answer would be yes, are precisely the types of questions that
should be excluded from evidence under 403.
Opposition to Motion to Present Epstein Testimony at 12. Requiring Mr. Epstein’s live Fifth
Amendment invocation in front of the jury in response to the very same questions would be no less
prejudicial and no more probative and would provide no independent basis to justify the burdens it
imposes on Mr. Epstein or the damage to the integrity of the trial which will likely result from the
media circus generated by Mr. Epstein’s personal appearance.
CONCLUSION
For all the foregoing reasons, Mr. Epstein’s Motion to Quash should be granted.
Respectfully submitted,
JEFFREY EPSTEIN
By his attorneys,
/s/ Jack Alan Goldberger
Jack Alan Goldberger
Atterbury, Goldberger & Weiss, P.A.
250 Australian Avenue South, #1400
West Palm Beach, Florida 33401
(561) 659-8305
(561) 835-8691 (fax)
jgoldberger@agwpa.com
/s/ Martin G. Weinberg
Martin G. Weinberg
20 Park Plaza, Suite 1000
Boston, Massachusetts 02116
(617) 227-3700
(617) 338-9538 (fax)
owlmgw(@att.net
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| Filename | Giuffre_Maxwell_Batch6_p00380.png |
| File Size | 233.9 KB |
| OCR Confidence | 94.8% |
| Has Readable Text | Yes |
| Text Length | 1,264 characters |
| Indexed | 2026-02-04 12:47:02.422359 |