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eclare as follows: 1. Iam an attorney at law duly licensed in the State of New York and admitted to practice in the United States District Court for the Southern District of New York. Iam a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell in this action. I respectfully submit
Page: HOUSE_OVERSIGHT_014797 →howed that her lawyers had sent a letter to Buckingham Palace asking to interview the prince under oath. In her sworn affidavit, the woman described Buckingham Palace's denial that sexual contact ever took place between the pair as "false and hurtful to me." Interview request The woman, identified by Buckingham Pal
Page: HOUSE_OVERSIGHT_014824 →Microsoft Word - Exhibit K.docx
udge for the Crime Victims’ Rights Act lawsuit agreed that the affidavit was misplaced in that case, and it was dropped. Prince Andrew’s spokesman at Buckingham Palace did not respond to an email requesting comment. Roberts, now 35, said it has taken her a long time to stand up to Epstein. She and 20 other victims
Page: HOUSE_OVERSIGHT_017808 →th, veracity or substantiation,” Menninger noted in a 2016 response filed in the case. In February, the Miami Herald filed a federal court motion in the Southern District of New York, seeking access to documents that were sealed in the Maxwell case. The motion, which was not opposed by Roberts, could have cast light on the full sc
Page: HOUSE_OVERSIGHT_017814 →n in Limine 3).................+ 8 4. Louis Freeh’s testimony and report are admissible evidence (Motion in Limine 4) ....... 9 5. Prince Andrew and Buckingham Palace’s denials of Plaintiff's claims are not offered for the truth of the matter asserted (Motion in Limine 5)... i.e seeeesseeseereeeeeeneeeneeees 11 6. E
Page: HOUSE_OVERSIGHT_011464 →eday & Co., Inc., 518 F.2d 638, 639-40 (2d Cir.1975) 0. ceeeesceseesseeeseeneeeeeeees 13 Chamblee v. Harris & Harris, Inc., 154 F. Supp. 2d 670, 681 (S.D.N-Y. 2001)... eeeeeeeeneees 22 Chnapkova v. Koh, 985 F.2d 79, 82 (2d Cir. 1993) oes cecccsscessecseeceseesseeseeeseceseesseesseeeseeeeeeseeeseeees 22 Dani
Page: HOUSE_OVERSIGHT_011466 →Entities connected to both Buckingham Palace and District Court for the Southern District of New York

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Marc Rich
PERSONJane Doe
PERSON
United States
LOCATION
Donald Trump
PERSON
Bill Clinton
PERSON
Bradley Edwards
PERSON
U.S. Virgin Islands
LOCATION
Paul Cassell
PERSON
Virginia Giuffre
PERSON
Alan Dershowitz
PERSON
Kenneth Marra
PERSON
Alexander Acosta
PERSONLaura Menninger
PERSON
David Boies
PERSONJack Goldberger
PERSON
Stephen Hawking
PERSONSigrid McCawley
PERSON