It’s the only logical conclusion.
The only alternative would be assuming the people burning the cities down are criminals.
Think the morons will ever figure it out?
💡🛎💡🛎💡🛎💡
If it makes them happy, who cares? Everyone needs a hobby, and therapy is expensive.
I’m sure you can see where my thoughts are going. If incompetent people are replace, can the newly elected officials pull up the list of “released rioters” and prosecute?
Examples of this money saving opportunity previously include and were not limited to CUSTOMER SERVICE and IT folks.
Now, everyone else can join in, too!
Bonus: Isn't that the entire point of the "Trans Pacific Partnership" that President Trump saved us all from?
Asking for a friend. 🤫
Or should I say “brain dead fucktard liberals who flunked high school history and civics who don’t know that a REAL insurrection would involve guns”?
They do realize how stupid they sound, right?
“Oh Em Gee - they broke in and took SELFIES! Like, wow - total cray cray bad stuff - Old People Taking Selfies? Gag me with a spoon already!”
Or whatever nonsense the fake woke spew while saying stupid shit.
Barf.
We have no laws that allow for Fake Addresses, "absentee ballots" filled in by people who neither requested or received them, or "fake ballots" delivered after hours.
We have laws already in place allowing people to monitor these situations. We have requirements that election officials sign documents that they are adhering to the laws.
We have people who BROKE THE LAW. We have people PRETENDING they don't know about it. We have people depending on "plausible deniability" when it comes to "well, someone else told me they followed the law, so I don't need to know anything else".
Anyone who wants to forget this, or pretend we can stop CRIMINALS from breaking the law with firm scoldings and their promises that NEXT TIME they will "follow the law" is part of the criminal enterprise.
The only reason to ignore this level of law breaking is because the people involved are benefiting from it.
We need a better solution than we are seeing. Right now, the criminals feel totally safe because they are getting away with it.
They need to feel safer in jail. I am not sure how that is going to happen, but it needs to happen.
tldr; ELECTION FRAUD, BALLOT BOX STUFFING AND FAKE BALLOTS ARE ALREADY ILLEGAL.
Now what?
Or do we have to pretend he is a worthwhile human being whose loss is a blow to his remaining family instead of him being a treasonous worm whose name should be scorned in perpetuity by decent human beings everywhere?
Asking for a friend.
There is a reason blatant election fraud in November 2020 was instantly ignored by the mainstream media and the people who benefited from it - voting is how we (the governed) give our consent. If election fraud happened, we do not consent - what next?
Let’s look at the recent past. In the 2016 presidential election, the people who run things in Washington immediately started pretending there was “Russian Interference” (which was not an actual happening by any stretch of the imagination). Kindly note they did not imply that ANY OTHER ELECTED OFFICIAL had been similarly compromised - only President Elect Trump. Think that through - why did nobody in power even ask “does that mean the rest of them/us weren’t elected either?”
But logic didn’t matter when the controlled media was spreading a specific message, which was that Congress, for “reasons” (badly manufactured) might have to GIVE the election to Hillary Clinton instead because RUSSIA.
It was very logical on their end - if then President-Elect Trump didn’t agree to “play ball” with THEIR PICKS for various posts, the people “in charge” were going to deny him the office under their “concerns” about “Russian Interference”.
Was it blackmail? Yes. But it was also about demonstrating Trump could be CONTROLLED. If he couldn’t, he was a danger to them, and let’s be honest - they were right.
(On a side note, the people who BELIEVED the lies about “Russian Interference” spent four years enraged that their candidate was robbed. They undoubtedly use this to justify what happened in 2020 - sauce for goose, sauce for the gander. The difference being their complaint was a manufactured publicity stunt, while ours is an actual problem.)
President Trump is not an idiot. He negotiated, and then fired people once his “power” was consolidated. The Other Powerful People still kept a leash on him (bad press, Mueller, DOJ corruption, media appearances from Congress people peddling Russian Collusion, fake impeachment, etc.) and yet he still kept the majority of his promises. He literally showed what could actually be done when an elected official was working FOR the American People.
Those accomplishments (stopping wars, arresting human traffickers, negotiating good trade policies, etc.) cost people MONEY. When China (or Italy, or global banks, or whoever) gives your “family members” millions of dollars, they aren’t doing it because they like you - They Want Something. And either their “loyal servants” do their jobs, or the money spigot gets cut off.
The carrot-and-stick approach works. (Lots of cars blow up in Georgia all the time, right? /s) The issue is only who the “loyal servant” works for - and as the title of this piece indicates, IT IS NOT THE VOTER.
The November 2020 election was substantially rigged. It happened publicly (votes going backward on television), in polling places in swing states with fake ballots, and in front of our “elected officials”. Every safeguard we use to guard AGAINST election fraud - media monitoring, triple checking, ballot applications matching voters matching ballot counts, transparency - Every. Safeguard. Was. Violated.
And there have been zero consequences. The ILLUSION of our “consent to be governed” has been shattered. We also watched as a $1.9 TRILLION “covid relief bill” was approved by Congress, with the majority of it going to “foreign aid” which translates to “bribes, payoffs and money laundering back to our people” - and they smiled and bragged because President Trump was gone, and things were going to go back to NORMAL again.
Normal. With unnecessary wars, and foreign governments in charge of our power grid, and lockdowns, and free speech suppressed, and good jobs sent overseas, and hypocritical mouthings from Pravda news sources the order of the day as even medical decisions (want to travel? show your medical history and your compliance with forced vaccination papers, please) become government mandates.
Which we obviously AGREE WITH because we “elected* these morons?
For the love of all that is holy, we are being trained to PRETEND that this is not TYRANNY!!!
And so this meandering post, from a cynical person who doesn’t trust any of them anymore, and who has no “special connections” to information sources other than a brain that still works and critical thinking skills honed from a lifetime of problem solving, asks this board the most important question I can think of:
When Election Fraud Means Voting Won’t Change Things, What Should Good Citizens Do?
Because honestly, I don’t know.
And now we have the WE HATE YOU ALL in common.
This timeline is wild. 😂
But as we have learned from this last election, some things are best kept from the eyes of the observers.
Better luck next year, Tampa Bay! Don’t be sore losers now!
And no, I’m not talking about the normal Democrat Trolls who wander in here - I mean the actual whores who sell their bodies instead of their souls.
Hypothetically speaking, of course.
Is there a Las Vegas betting pool on how long Biden is going to be breathing? The $2M payoff to Hunter says “let my kid live” is part of the price for this farce, but once Biden falls down the stairs in Minecraft, Kamala has no obligations to “protect” her predecessors “mistakes” and focusing people on them would be a great distraction while she “mourns her mentor”.
😂😂😂
We are seriously living in a bad Hollywood movie, and the bad guys think they are the heroes. Yikes.
If they think we are going to “shut up” about ACTUAL ELECTION FRAUD, they can learn to hide from the outraged public everywhere they go because as far as I am concerned, they are treason weasels who should feel safest In Jail.
The only politicians wanted in Washington are those who can be controlled. Your state party will NOT promote anyone who will not do as they are told. If anyone uses "the power of the people" to advance, they will be quickly shut down or manipulated into "towing the line".
This truth applies equally to the DNC and the GOP. Sadly, this means we have no actual representation in Washington.
Anyone who thinks that we have a "free press" needs to spend five minutes looking at how the Russia HOAX was treated, versus the ACTUAL Election Fraud that has installed the majority of these corrupt bastards.
I made this comment elsewhere, but I think it deserves a more thorough look.
Realistically, since the “capital invasion” was a false flag planned by the Democrats, there is a good chance they planned to kill off AOC as a sacrificial martyr. It would have gotten her out of their hair, and provided more “incentive” to play up the whole “insurrection” angle, all while serving as a warning to the rest of their members about how expendable they can be if they cause “leadership” too much annoyance.
One of the clues that she was being targeted was the disabling of her “security buttons”, while the missing shoes were probably a message - “we can get to you anytime”.
It makes no sense she was in another building during the “let’s discuss Arizona election fraud” debate unless someone warned her.
I don’t think it’s the Trump supporters she needs to be afraid of - I think it is the UniParty. She is supposed to be “pretend we care” and if she thinks she has any power in Washington, she needs to understand her place, because otherwise “accidents happen” especially during false flag operations.
Pure speculation, of course. Right up there with her “I could have been killed” speculation. But very logical.
Thoughts?
Just a happy reminder. 😁
Pages 1-7 here, 8-14 in comment Link: https://www.courtlistener.com/recap/gov.uscourts.nysd.447706/gov.uscourts.nysd.447706.730.0.pdf
Case 1:15-cv-07433-LAP Document 730 Filed 03/17/17 Page 1 of 14 Virginia L. Giuffre, Plaintiff, v. Ghislaine Maxwell, Defendant. ________________________________/ Case No.: 15-cv-07433-RWS United States District Court Southern District of New York PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S MOTION IN LIMINE TO EXCLUDE FBI 302 STATEMENT OF PLAINTIFF Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, PL 425 North Andrews Avenue, Suite 2 FORT LAUDERDALE, FL 33301 (954)524-2820 TELEPHONE
Case 1:15-cv-07433-LAP Document 730 Filed 03/17/17 Page 2 of 14 I. II. III. PRELIMINARY STATEMENT ............................................................................................. 1 FACTUAL BACKGROUND.............................................................................................. 1 DISCUSSION ...................................................................................................................... 2 TABLE OF CONTENTS A. Ms. Giuffre’s FBI 302 is Offered to Prove That She Reported Her Allegations to Law Enforcement, Not to Prove the Truth of any Matters Asserted Therein. ......................... 2 B. Even if Treated as Hearsay, The FBI 302 is Admissible Pursuant to Rule 803(8) as a Public Record. .................................................................................................................. 5 C. THE FBI 302 IS NOT UNDULY PREJUDICIAL .......................................................... 9 IV. CONCLUSION.................................................................................................................. 10 Page i
Case 1:15-cv-07433-LAP Document 730 Filed 03/17/17 Page 3 of 14 Cases TABLE OF AUTHORITIES Bingham v. Jefferson Cnty., No. 1:11-cv-48, 2013 WL 1312563, at *7 (E.D. Tex. Mar. 1, 2013) 8 Moss v. Ole South Real Estate, Inc., 933 F.2d 1300, 1305 (5th Cir. 1991).................................... 8 Parsons v. Honeywell, Inc., 929 F.2d 901, 907 (2d Cir.1991) .................................................... 6-7 Spanierman Gallery, Profit Sharing Plan v. Merritt, No. 00CIV5712LTSTHK, 2003 WL 22909160, at *5 (S.D.N.Y. Dec. 9, 2003)................................................................................... 6 U.S. ex rel. Wuestenhoefer v. Jefferson, No. 4:10-CV-00012-DMB, 2014 WL 7185428, at *2 (N.D. Miss. Dec. 16, 2014)......................................................................................................... 7 U.S. v. Puente, 826 F.2d 1415 (5th Cir. 1987)). ............................................................................. 6 United States v. Brennan, 798 F.2d 581, 589 (2d Cir. 1986).......................................................... 5 United States v. Dunloy, 584 F.2d 6, 11 (2d Cir.1978)................................................................... 3 United States v. Everett, 825 F.2d 658, 661 (2d Cir. 1987).......................................................... 10 United States v. Khan, 821 F.2d 90 (2d Cir. 1987)...................................................................... 4-5 United States v. Song, 436 F.3d 137, 139 (2d Cir. 2006) ............................................................... 3 Upstate Shredding, LLC v. Ne. Ferrous, Inc., No. 312CV1015LEKDEP, 2016 WL 865299, at *13 (N.D.N.Y. Mar. 2, 2016)...................................................................................................... 6 Other Authorities 5 JONES ON EVIDENCE § 34:13 (7th ed.).......................................................................................... 6 Rules Fed. R. Evid. 403 ............................................................................................................................ 9 Fed. R. Evid. 801(c)(2) ................................................................................................................... 3 Fed. R. Evid. 801(d)(1)(B)(i) .......................................................................................................... 3 Fed. R. Evid. 801(d)(2)(B)(i) .......................................................................................................... 4 Fed. R. Evid. 803(6).................................................................................................................... 6, 7 Fed. R. Evid. 803(8).................................................................................................................... 6, 7 Fed. R. Evid. 803(8)(A) .............................................................................................................. 1, 8 Fed. R. Evid. 803(8)(A)(ii) ......................................................................................................... 7, 9 Fed. R. Evid. 803(8)(B) .............................................................................................................. 8, 9 Page ii
Case 1:15-cv-07433-LAP Document 730 Filed 03/17/17 Page 4 of 14 I. Plaintiff, Virginia Giuffre, by and through her undersigned counsel, hereby files this response in opposition to Defendant’s Motion in Limine to Exclude FBI 302 Statement of Plaintiff [DE 667]. PRELIMINARY STATEMENT Defendant has filed a motion in limine seeking to exclude from evidence Ms. Giuffre’s statement to the FBI in 2011 about Jeffrey Epstein’s and Defendant’s sex trafficking crimes, raising a hearsay objection. In Defendant’s Motion in Limine to Exclude FBI 302 Statement of Plaintiff (hereinafter “Mot.”), she appears to misunderstand the purpose for which this document will be admitted—to establish that Ms. Giuffre properly reported her allegations to law enforcement. Accordingly, the document is not being admitted to prove the truth of any matters asserted therein, and thus is not a hearsay statement. In any event, even if the statement is regarded as hearsay, it easily falls within a recognized exception, such as the public record exception of 803(8)(A). Numerous courts, including this one, have admitted FBI 302s under this authority. The statement is also trustworthy because it is simply the FBI’s recording of Ms. Giuffre’s own statement and, of course, Ms. Giuffre is fully available to answer any questions about it at trial. FACTUAL BACKGROUND It appears to be undisputed that on March 17, 2011, Ms. Giuffre was interviewed by FBI Special Agents—along with a telephonically present Assistant United States Attorney—at the United States Consulate in Sydney, Australia, as part of an ongoing investigation into Jeffrey Epstein sexual abuse and sex trafficking conspiracy. In due course, a Special Agent prepared a standard summary of Ms. Giuffre’s statement—commonly referred to as an FBI “302.” Ms. Giuffre’s FBI 302 was generated in relation to file number 31E-MM-108062, and was drafted on July 5, 2013. The 302 was published on federally-issued Form FD-302/FD-302a (Rev. 5-8-10) II. 1
Case 1:15-cv-07433-LAP Document 730 Filed 03/17/17 Page 5 of 14 III. bearing the official seal of the Federal Bureau of Investigation, and explicitly indicating that the document is an “Official Record” wherein “[a]ll signatures have been verified by a certified FBI information system.” See Edwards Dec., Ex. 1 at 1. Ms. Giuffre properly provided her FBI 302 to the Defendant in discovery. (GIUFFRE001235). Now, Ms. Giuffre intends to present that FBI 302 at trial. DISCUSSION In her motion raising a hearsay objection, Defendant mischaracterizes Ms. Giuffre’s purpose for offering the self-authenticating FBI 302. The subject evidence is not being offered for the truth of the matter asserted, rather to rebut the assertion that Ms. Giuffre has failed to properly report her allegations to law enforcement and engaged in a recent fabrication to baselessly initiate the pending litigation. Accordingly, it is not being offered to prove the truth of any matter asserted and thus is not excluded by the rule against hearsay. The FBI 302 is also covered by various hearsay exceptions, and its introduction at trial is not unduly prejudicial in any way. A. MS. GIUFFRE’S FBI 302 IS OFFERED TO PROVE THAT SHE REPORTED HER ALLEGATIONS TO LAW ENFORCEMENT, NOT TO PROVE THE TRUTH OF ANY MATTERS ASSERTED THEREIN. Defendant claims at the beginning of her motion to be confused about why Ms. Giuffre intends to offer her FBI 302 into evidence. See Mot. at 1. In fact, the reason is clear: Ms. Giuffre properly reported her allegations of sex abuse and sex trafficking to federal law enforcement agents in 2011, well before the disputed events in this case occurred. The jury may use that fact of a prior report to law enforcement as one of piece of evidence supporting Ms. Giuffre’s credibility. Of course, because the evidence is coming in to support credibility, the underlying truth of anything that Ms. Giuffre may have stated to the FBI is not at issue. The hearsay rules only 2
Case 1:15-cv-07433-LAP Document 730 Filed 03/17/17 Page 6 of 14 operate to exclude out-of-court statements being offered “in evidence to prove the truth of the matter asserted in the statement.” Fed. R. Evid. 801(c)(2) Because Ms. Giuffre is not offering the statement to prove the truth of the matters asserted—i.e., that Epstein and Defendant had sexually trafficked her—the hearsay prohibition simply does not apply. See, e.g., United States v. Song, 436 F.3d 137, 139 (2d Cir. 2006) (noting that evidence was properly admitted “inasmuch as the challenged statements were offered not for the truth of the matters asserted, but rather, to demonstrate the motivation behind [the declarant’s] actions”); see also United States v. Dunloy, 584 F.2d 6, 11 (2d Cir.1978). Defendant pretends to by puzzled by all of this, and yet Defendant has clearly demonstrated her intention to make issues regarding reporting to law enforce a central part of the trial. A good illustration comes from Defendant’s recently-filed motion to exclude certain 404(b) evidence from witness Rinaldo Rizzo. Defendant argues that Rizzo’s allegations that he saw Defendant, for example, trying to force a 15-year-old Swedish girl to have sex with Epstein, should be discounted because Rizzo did not “report any such events to law enforcement.” Defendant’s Motion to Exclude Evidence Pursuant to Fed. R. Evid. 404(b) at 8. The issue of whether a witness has failed to report a crime to law enforcement is a question that immediately springs to mind. And, in this case, that issue will immediately spring to the minds of the jury considering Ms. Giuffre’s credibility. Ms. Giuffre is entitled to allay such concerns by showing that she properly met with law enforcement in 2011. In an effort to deflect such arguments, Defendant apparently concedes that the FBI 302 could be used to establish Ms. Giuffre’s credibility under Fed. R. Evid. 801(d)(1)(B)(i) if it is used to “rebut an express or implied charge that the defendant recently fabricated it or acted from a recent improper influence or motive in so testifying.” See Mot. at 4. This concession would 3
Case 1:15-cv-07433-LAP Document 730 Filed 03/17/17 Page 7 of 14 appear to be enough to establish the admissibility of the FBI 302 because it is obvious that Defendant will continue to aggressively attack Ms. Giuffre’s credibility by claiming that she is improperly seeking money through this lawsuit or through publicity that will help her write a book. Showing that, in 2011, Ms. Giuffre had reported her allegations to the FBI, will obviously respond to such suggestions. But, Defendant presents a strawman characterization of how the evidence will be used, arguing that Ms. Giuffre will attempt to use the FBI 302 only to respond to suggestions that, in meeting with journalist Sharon Churcher, Ms. Giuffre had no improper motive. See Mot. at 4. Defendant then argues that Ms. Giuffre’s 2011 meeting with Ms. Churcher pre-dated by a few weeks the 2011 FBI meeting, and thus the statement is not a prior consistent statement—i.e., was not made prior to meeting with Ms. Churcher. If this case were solely about Ms. Giuffre’s statements to Ms. Churcher, Defendant might have an argument. But obviously the case is not so limited—as the Court can immediately determine by reviewing the voluminous pleadings Defendant has filed in this case attempting to assassinate the character of Ms. Giuffre on any number of grounds. The FBI 302 rebuts many of those attacks. For example, Defendant’s press release itself suggests that, on December 30, 2014, when Ms. Giuffre filed her CVRA Joinder Motion, she was acting improperly. Of course, a meeting with FBI agents more than three years earlier—in 2011—immediately rebuts the suggestion that the December 30, 2014, the CVRA Joinder Motion was some sort of recent fabrication. Rule 801(d)(2)(B)(i) clearly allows the statement to be admitted. See, e.g., United States v. Khan, 821 F.2d 90 (2d Cir. 1987). It is important to understand that the hearsay rules do not artificially require Ms. Giuffre to point to some specific statement from Defendant attacking her credibility before she is allowed to introduce a prior consistent statement. The rule itself is broadly written, allowing a