Epstein Secrets

d the puppet. You characterized puppet, I characterize it as, I don't know, as a characterization of Andrew. Q. Do you recollect asking to sit on Prince Andrew's lap with the caricature of Prince Andrew? A. I do not recollect that. Q. What do you remember about the caricature of the Prince Andrew caricature

the puppet but I don't recollect anything around the puppet. You characterized puppet, I characterize it as, I don't know, as a characterization of Andrew. Q. Do you recollect asking to sit on Prince Andrew's lap with the caricature of Prince Andrew? A. I do not recollect that. Q. What do you remem

r trips with you? • Did you meet Prince Andrew, the Duke of York, in about March of 2001 in London? See McCawley

Deposit Co. of Maryland, 45 F.3d 969 (5th Cir. 1995) 6 In re WorldCom, Inc. Securities Litigation, 2005 WL 375315 (S.D.N.Y. Feb. 17, 2005) 17 LiButti v. United States, 107 F.3d 110 (2d Cir. 1997) passim Rules Fed. R. Evid. 611(c) 16 ii EFTA00622177 Plaintiff respectfully submits her repl

st 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://n

iduals such as Donald Trump, Bill Clinton, Prince Andrew. See, e.g., New York Post, "The 'sex slave' scan

he party knows will assert his Fifth Amendment privilege, see, e.g., Brinks, Inc. v. City of New York, 717 F.2d 700, 708-10 (2d Cir. 1983); see also LiButti v. United States, 107 F.3d 110 (2d Cir. 1997), neither is this Court required to permit it in all cases. Instead, the question must be evaluated on

hanged over time from what was published in 2011 and what was published in 2015 and after and, in particular, the question of whether had sex with Prince Andrew or not. In 2011, the article stated that there was not evidence that that happened. In 2015, after court papers stated that it had happened, they

ar, the question of whether had sex with Prince Andrew or not. In 2011, the article stated that there w

t would not justify a deposition, which leaves really the Fifth Amendment implications that have been represented will be made, and that raises the LiButti issue. And under LiButti, your Honor, really the permeating factor is control. And the typical case -- really, most of the cases, to the extent co