Epstein Secrets

RULE 45 via ECF on the following: Sigrid S. McCawley Paul G. Cassell Meridith Schultz 383 S. University Street BOIES, SCHILLER & FLEXNER, LLP Salt Lake City, UT 84112 401 East Las Olas Boulevard, Ste. 1200 [email protected] Ft. Lauderdale, FL 33301 [email protected] [email protected] Bradle

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

oulevard, Suite 1200 Ft. Lauderdale, FL 33301 Tel: 954-356-0011 Fax: 954-356-0022 [email protected] University of Utah 383 University Street Salt Lake City, UT 84112 Tel: 801-585-5202 Fax: 801-585-2750 [email protected] Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman 425 North Andrews Avenue,

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"

ne Facsimile Florida Bar No.: E-mail: and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City. UT 84112 Telephone: Facsimile: E-Mail: Attorneys for Jane Doe #1 and Jane Doe #2 9 EFTA00208347 Case 9:08-cv-80736-KAM Document 51 Entered

ross the Pond, PALM BEACH POST, Mar. 9, 2011, at 2B. There are also current reports that the FBI is reopening its investigation into the matter. See Sharon Churcher, FBI Will Reopen Case Against Prince's Friend, SUNDAY MAIL (UK), Mar. 6, 2011. 7 EFTA00208345 Case 9:08-cv-80736-KAM Document 51 Entered on FLS

s Avenue, Suite 2 Fort Lauderdale Florida 33301 E-mail: and Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City. UT 84112 E-Mail: Attorneys for Jane Doe #1 and Jane Doe #2 9 EFTA00212446 Case 9:08-cv-80736-KAM Document 51 Entered on FLSD Docket 03)21.201

ross the Pond, PALM BEACH POST, Mar. 9, 2011, at 2B. There are also current reports that the FBI is reopening its investigation into the matter. See Sharon Churcher, FBI Will Reopen Case Against Prince's Friend, SUNDAY MAIL (UK), Mar. 6, 2011. 7 EFTA00212444 Case 9:08-cv-80736-KAM Document 51 Entered on FLS

mail:[email protected] Paul G Cassell [ATTORNEY TO BE NOTICED] S.J. Quinney College of Law At The University of Utah 383 S. University Street Salt Lake City, UT, USA 84112-0730 (801)-585-5202 Fax: (801)-585-2750 Email:[email protected] DEFENDANT ATTORNEY(S): Jeffrey S. Pagliuca [PRO HAC VICE;ATTORN

s. Inc.,: Daily News, L.P. Intervenor: Michael Cernovich d/b/a Cernovich Media; Alan M. Dershowitz Material Witness: Miscellaneous: Respondent: Sharon Churcher; Jeffrey Epstein DOCKET CASE NUMBER: 1:15cv7433 OTHER DOCKET CASE NUMBER: 1:17mc00025 U.S. Court of Appeals, Second Circuit, 17-01625 FILING DAT

42075 E-mail: [email protected] and Li Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile: 801-585-6833 E-Mail: [email protected] Attorneys for Jane Doe ill and Jane Doe #2 9 L, EFTA00

ross the Pond, PALM BEACH POST, Mar. 9, 2011, at 2B. There are also current reports that the FBI is reopening its investigation into the matter. See Sharon Churcher, FBI Will Reopen Case Against Prince's Friend, SUNDAY MAIL (UK), Mar. 6, 2011. 7 EFTA00177163 Case 9:08-cv-80736-KAM Document 51 Entered on FLSD

2820 Fax: (954) 524-2822 E-mail: bradarloathtoiustice.com Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 841 12 (801) 585-5202 Fax: (801) 585-6833 E-mail: cassetp(4law.utah.edu Attorneys for Jane Doe # 1 and Jane Doe # 2 54 08-80736-CV-MARRA

ross the Pond, PALM BEACH POST, Mar. 9, 2011, at 2B. There are also current reports that the FBI is reopening its investigation into the matter. See Sharon Churcher, FBI Will Reopen Case Against Prince's Friend, SUNDAY MAIL (UK), Mar. 6, 2011. 7 op 08-80736-CV-MARRA 000933 EFTA00230757 . . .. . .... r.)7

n § See Excerpts of Roberts’s Deposition Transcript, attached hereto (under seal) as Exhibit F.' i TT eee Pe See id.; see also March 2, 2011, Sharon Churcher, Daily Mail, attached hereto as Exhibit G. Dershowitz has also discovered that Roberts ee Sec Exhibit F; see also AD-006931-006933, Transcript of T

ach, Florida 33409; [email protected] to: Joni J. Jones, Esq., Assistant Utah Attorney General, Counsel for Plaintiff Cassell, 160 East 300 South, Salt Lake City, Utah 84114; [email protected] to: Bradley J. Edwards, Esq, Farmer, Jaffe et al, 425 North Andrews Avenue, Suite 2, Ft. Lauderdale, FL 33301;

Donald, I'm Prince Andrew and the 17-year-old girl his sex offender friend flew to Britain to meet . h | m This advertisement ends in 7 seconds By SHARON CHURCHER UPDATED: 08:02 EST, 2 March 2011 - Virginia Roberts reveals she is ‘Jane Doe 102' in Jeffrey Epstein case - Mother-of-three spent four years as mill

Avenue, Suite 2, Fort Lauderdale, FL 33301, By: Bradley J. Edwards, Esq., S.J. QUINNEY COLLEGE OF LAW, UNIVERSITY OF UTAH,' 383 University Street, Salt Lake City, UT 84112, By: Paul G. Cassell, Esq. Counsel for Defendant Ghislaine Maxwell: HADDON, MORGAN AND FOREMAN, P.C., 150 East 10th Avenue, Denver, CO 8

ed on the difficult balancing of the conflicting principles described below. I. Prior Proceedings In early 2011 , in an interview with journalist Sharon Churcher ("Churcher") which was published in two British tabloids, described Maxwell's alleged role as someone who recruited or facilitated the recruitment

t balancing of the conflicting principles described below. I. Prior Proceedings In early 2011 , in an interview with journalist Sharon Churcher ("Churcher") which was published in two British tabloids, described Maxwell's alleged role as someone who recruited or facilitated the recruitment of young fe

bmit this Declaration in support of Ms. Maxwell’s Motion for Summary Judgment.’ 2. Attached as Exhibit A is a true and correct copy of an article by Sharon Churcher entitled “Prince Andrew and the 17-year-old girl his sex offender flew to Britain to meet him,” DAILY MAIL, dated March 2, 2011. ' At trial, defend

S, FISTOS & LEHRMAN, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 [email protected] Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 [email protected] J. Stanley Pottinger 49 Twin Lakes Rd. South Salem, NY 10590 [email protected] /s/ Nicole Simmons Nicole Simmo