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5 I. PLAINTIFF'S LACK OF DILIGENCE 6 6 B. Ross Gow 9 C. Jean Luc Brunel 10 D. Jeffrey Epstei
extra time to take these six depositions. The only witnesses for whom depositions should be permitted following the discovery cut-off are: (1) Ms. Sharon Churcher, Plaintiff's friend, advocate and former journalist with the Daily Mail, who filed a Motion to Quash her subpoena on the day before her scheduled d
re for trial. Thus, if the Court grants Plaintiff's motion, the remaining deadlines in the Scheduling Order ought to be extended accordingly. 2 Ms. Churcher's motion to quash will be heard this Thursday by the Court. Ms. Maxwell is filing simultaneously with this Response a Motion to Re-Open Plaintiffs D
A00792761 Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 is o no
llegations. Prince Andrew is an example. Disclosing her story publicly for the first time in March 2011 in an "exclusive" relationship with reporter Sharon Churcher, plaintiff had every incentive and opportunity to tell her entire story honestly and completely. She told Churcher she 5 EFTA00792760 did not ha
relationship with reporter Sharon Churcher, plaintiff had every incentive and opportunity to tell her entire story honestly and completely. She told Churcher she 5 EFTA00792760 did not have sex with Prince Andrew. Less than four years later, after engaging a lawyer, plaintiff alleged she was "forced"
A00617401 Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 is so n
llegations. Prince Andrew is an example. Disclosing her story publicly for the first time in March 2011 in an "exclusive" relationship with reporter Sharon Churcher, plaintiff had every incentive and opportunity to tell her entire story honestly and completely. She told Churcher she 5 EFTA00617400 did not ha
relationship with reporter Sharon Churcher, plaintiff had every incentive and opportunity to tell her entire story honestly and completely. She told Churcher she 5 EFTA00617400 did not have sex with Prince Andrew. Less than four years later, after engaging a lawyer, plaintiff alleged she was "forced"
28 10:53* Newsweek 37. 38. 39. Al Gore 40. Ross Gow 41. Fred Graff 42. Philip Guderyon 43. RED
ACTED 7. Cate Blanchett 8. David Boies 9. Laura Boothe 10. 11. Rebecca Boylan 12. Joshua Bunner 13. Naomi Campbell 14. 15. Paul Cassell 16. Sharon Churcher 17. Bill Clinton 18. David Copperfield 19. 20. Cameron Diaz 21. Leonardo DiCaprio 22. Alan Dershowitz 23. Dr. Mona Devanesan 24. REDACTED 25
y me. You are the one who introduced me to Steve Ross as my agent, who has made my life a living hell,
of Callahan, I had to go into isolation and hiding for two years, and you all put my life in danger when Epstein located me in Barcelona. It was Sharon Churcher, a Daily Mail journalist who went down to see with a photographer and took her and her husband to the FBI in Sydney. It was the Daily Mail that Pu
me. You are the one who introduced me to Steve Ross as my agent, who has made my life a living hell,
of Callahan, I had to go into isolation and hiding for two years, and you all put my life in danger when Epstein located me in Barcelona. It was Sharon Churcher, a Daily Mail journalist who went down to see with a photographer and took her and her husband to the FBI in Sydney. It was the Daily Mail that P
me. You are the one who introduced me to Steve Ross as my agent, who has made my life a living hell,
een Callahan, I had to go into isolation and hiding for two years, and you all put my life in danger when Epstein located me in Barcelona. It was Sharon Churcher, a Daily Mail journalist who went down to see with a photographer and took her and her husband to the FBI in Sydney. It was the Daily Mail that P
I'm correct. So at present we have six witnesses that we still need to depose, the three that we had alternative service for, and then we have Mr. Ross GOw, who was the defendant's agent who issued the defamatory statement, Mr. Brunel -- THE COURT: How much time do you want? MS. McCAWLEY: Sorry. We
to get access to these accounts, review them, and determine -- treat it as the Apple accounts have been treated. OK. So that solves that problem. Churcher's motion to quash. MR. PAGLIUCA: Your Honor, before we move on, I have one point of clarification with regard to the earlier ruling about counsel
Entities connected to both Wilbur Ross and Sharon Churcher

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Prince Andrew
PERSON
Joe Biden
PERSON
Marc Rich
PERSON
Richard Kahn
PERSON
Donald Trump
PERSON
Ghislaine Maxwell
PERSONLeon Black
PERSON
Julie K. Brown
PERSON
United States
LOCATION
Alan Dershowitz
PERSON
Bill Clinton
PERSON
Eric Trump
PERSON
Virginia Giuffre
PERSON
Stephen Hawking
PERSON
Department of Justice
ORGANIZATION
Samantha Power
PERSON
Lesley Groff
PERSON
Prince Charles
PERSON