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Case 1:15-cv-07433-LAP Document 1331-36 Filed 01/05/24 Page 7 of 10
particularly true when the spectre of this trial’s becoming even more of a media event is factored into
the analysis.‘
Plaintiff also argues in her motion that she should be permitted to call Mr. Epstein as a
witness to forestall the possibility that the jury would find it odd that she had not called Mr. Epstein
to testify. Motion to Present Epstein Testimony at 13-15. As defendant argues in the Opposition to
Motion to Present Epstein Testimony:
To the extent a jury wonders why Mr. Epstein is not called by Plaintiff, they will also wonder
why Ms. Maxwell is not calling him if he has exonerating information. There are a myriad
of reasons why a witness may or may not testify or why evidence may or may not be
presented at trial. Fortunately, this is a problem that is easily remedied through jury
instructions.
* Mr. Epstein has been, and continues to be, the subject of extensive publicity, much of it
salacious. A Google search for “Jeffrey Epstein” returns 508,000 entries, the most recent of which
center on the new nominee for Secretary of Labor, Alexander Acosta, who, when he was United
States Attorney for the Southern District of Florida, approved Mr. Epstein’s nonprosecution
agreement. See, e.g., New York Daily News, “Labor Secretary nominee Alexander Acosta gave
‘sweetheart deal’ to sex offender Jeffrey Epstein,’ February 16, 2017, available at
http://www.nydailynews.com/news/national/labor-pick-acosta-gave-sweetheart-deal-sex-offender
-epstein-article-1.2975065 (last visited February 17, 2017); Politico, “Trump’s Labor nominee
oversaw ‘sweetheart plea deal’ in billionaire’s underage sex case,” February 16, 2017, available at
http://www.politico.com/story/2017/02/alexander-acosta-trump-jeffrey-epstein-plea-235096 (last
visited February 17, 2017). Mr. Epstein’s name has been widely linked in the press with prominent
individuals such as Donald Trump, Bill Clinton, Prince Andrew. See, e.g., New York Post, “The ‘sex
slave’ scandal that exposed pedophile billionaire Jeffrey Epstein,” October 9, 2016, available at
http://nypost.com/2016/10/09/the-sex-slave-scandal-that-exposed-pedophile-billionaire-jeffrey-e
pstein/ (last visited February 17, 2017); Newsweek, “Jeffrey Epstein: the Sex Offender Who Mixes
with Princes and Premiers,” January 29, 2015, available at
http://www.newsweek.com/2015/02/06/sex-offender-who-mixes-princes-and-premiers-302877.html
(last visited February 17, 2017). He is the subject of a recently released book by best-selling author
James Patterson titled Filthy Rich: A Powerful Billionaire, the Sex Scandal that Undid Him, and All
the Justice that Money Can Buy - The Shocking True Story of Jeffrey Epstein (Little, Brown & Co.
October 10, 2016). His personal appearance at the trial of this case would predictably be the focus
of massive media attention, of both the mainstream and gutter variety.
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Document Details
| Filename | Giuffre_Maxwell_Batch6_p00378.png |
| File Size | 418.1 KB |
| OCR Confidence | 94.8% |
| Has Readable Text | Yes |
| Text Length | 2,929 characters |
| Indexed | 2026-02-04 12:47:03.216384 |