Epstein Secrets

est is that today -- and today ends, for our joint effort, at 3:30 -- the defendant's motion with respect to the supplemental reports of Jansen and Kliman; the 302 motion; and there are three that seem to me to go together -- the references to the Florida action, the CVRA action; the Epstein plea agr

20 21 22 23 24 25 his that -- THE COURT: That's a whole different issue. Right? MR. PAGLIUCA: Yes. I agree. And finally, your Honor, on this Kliman issue, it seems to me that all of this is -- well, let me back up. Here are the reasons why it's prejudicial, and I don't think we can just say, t

REPORTERS, P.C. EFTA00592376 H3ulgiva 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 presentation in front of Kliman that he gets to then comment on. And so really what we're doing is we're trying to clean up the in-court testimony by an out-of-court statement to

There were no allegations prior to this time of misbehavior by Ms. Maxwell. MS. MENNINGER: That's untrue, your Honor. Plaintiff sold her story to Sharon Churcher. When she sold her story to SOUTHERN DISTRICT REPORTERS, P.C. EFTA00592412 45 H3ulgiva Sharon Churcher, she made some allegations against Ms. M

how to be a masseuse. That's what she said in the Sharon Churcher published articles. THE COURT: And that's the only reference to Maxwell in the Churcher articles. SOUTHERN DISTRICT REPORTERS, P.C. EFTA00592413 46 H3ulgiva MS. MENNINGER: In the first Churcher article. But 4 5 6 7 8 9 10 1

in the first statement. So this book contains the universe of statements -- THE COURT: Yes, I understand that obviously she was responding to this Churcher article, but there's nothing to me that indicates that she was responding to the Epstein complaint. MR. EDWARDS: Well, she's responding to what sh

plaintiff's counsel handed you a book that had the Sharon Churcher articles in and they argued to you, hey, that Jane Doe 102 is mentioned in that Sharon Churcher article and therefore, Ms. Maxwell's denial about that statement somehow related to the Jane Doe 102? Do you remember that argument? That's the sa

hat today -- and today 19 ends, for our joint effort, at 3:30 -- the defendant's motion 20 with respect to the supplemental reports of Jansen and Kliman; 21 the 302 motion; and there are three that seem to me to go 22 together -- the references to the Florida action, the CVRA 23 action; the Epst

8 H3ulgiva 1 his that 2 THE COURT: That's a whole different issue. Right? 3 MR. PAGLIUCA: Yes. I agree. 4 And finally, your Honor, on this Kliman issue, it 5 seems to me that all of this is -- well, let me back up. Here 6 are the reasons why it's prejudicial, and I don't think we can 7 ju

timony there's this staged SOUTHERN DISTRICT REPORTERS, P.C. EFTA00794381 (212) 805-0300 EFTA00794382 9 H3ulgiva 1 presentation in front of Kliman that he gets to then comment 2 on. And so really what we're doing is we're trying to clean up 3 the in-court testimony by an out-of-court stateme

t statement. 12 So this book contains the universe of statements -- 13 THE COURT: Yes, I understand that obviously she was 14 responding to this Churcher article, but there's nothing to me 15 that indicates that she was responding to the Epstein 16 complaint. 17 MR. EDWARDS: Well, she's respondin

no allegations prior to this time of misbehavior by 23 Ms. Maxwell. 24 MS. MENNINGER: That's untrue, your Honor. Plaintiff 25 sold her story to Sharon Churcher. When she sold her story to SOUTHERN DISTRICT REPORTERS, P.C. EFTA00794453 (212) 805-0300 EFTA00794454 45 H3ulgiva 1 Sharon Churcher, she m

masseuse. That's what she said in the Sharon Churcher 23 published articles. 24 THE COURT: And that's the only reference to Maxwell 25 in the Churcher articles. SOUTHERN DISTRICT REPORTERS, P.C. EFTA00794455 (212) 805-0300 EFTA00794456 46 H3ulgiva 1 MS. MENNINGER: In the first Churcher art

t, his arrest, neither of which mentioned plaintiff, 8 by the way, but they took those materials and gave them to 9 their psychiatric expert, Dr. Kliman, who made the video we 10 talked about earlier. Dr. Kliman also administered a number of 11 tests to plaintiffs to figure out whether she had any

e Jane Doe 102 complaint. Paragraph 29 of 13 that complaint references this specific letter, and of course 14 that complaint is referenced in the Churcher articles, which is 15 referenced by Ms. Maxwell's first public statement about 16 Ms. in 2011. So almost like a Russian nesting doll, 17 all t

right? 10 MS. SCHULTZ: I'm sorry. I apologize, your Honor. I 11 don't think I follow your question. I think that Ms. Maxwell 12 knew about the Churcher article, which told her about the 13 litigation against Epstein. 14 THE COURT: It told her there was a complaint. 15 MS. SCHULTZ: Your Honor, t

iff who publicized to the entire world the fact that she 5 says she was sexually trafficked prior to Epstein and Maxwell. 6 She put that into her Sharon Churcher story. She got paid for 7 that story. And so one of the issues in our case are her 8 damages to her reputation. And if she's the one who was 9

tiff's counsel handed you a book that had the Sharon 6 Churcher articles in and they argued to you, hey, that Jane Doe 7 102 is mentioned in that Sharon Churcher article and therefore, 8 Ms. Maxwell's denial about that statement somehow related to 9 the Jane Doe 102? Do you remember that argument? That's t

4 THE COURT: And why do you have it in your expert's 15 report? 16 MS. SCHULTZ: Well, our expert is -- I'm assuming 17 you're referring to Dr. Kliman, who is a physician. He's a 18 medical doctor. He took a full -- 19 THE COURT: There's a whole thing about it. Are you 20 going to withdraw the

d some of that abuse did occur when she was 14 a minor. 15 THE COURT: Yes. Well, okay. But there are other 16 things that she sets forth in the Churcher articles, in the 17 motion to intervene, there are a whole series of other things 18 that are -- I mean, there are things that have been said, an

ment made? 19 MS. McCAWLEY: The statement was made in a March 5th 20 article. So not the two articles we showed you yesterday 21 THE COURT: The Churcher article. 22 MS. McCAWLEY: Yes. But it was another article that 23 came out in March of 2011. 24 And the statement was with respect to my client

by -- SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00794599 45 H3VOGIU1 1 2 3 4 5 Ms. THE COURT: I've read it. MS. MENNINGER: -- Sharon Churcher. THE COURT: Yes, I've read it. MS. MENNINGER: Okay. It's the one in which on March 5th, 2011, gave a long and lengthy 6 interview to Sharon Chur

2 23 24 25 THE COURT: And why do you have it in your expert's report? MS. SCHULTZ: Well, our expert is -- I'm assuming you're referring to Dr. Kliman, who is a physician. He's a medical doctor. He took a full -- THE COURT: There's a whole thing about it. Are you going to withdraw the -- MS. SCHUL

at abuse, and some of that abuse did occur when she was a minor. THE COURT: Yes. Well, okay. But there are other things that she sets forth in the Churcher articles, in the motion to intervene, there are a whole series of other things that are -- I mean, there are things that have been said, and my re

the statement made? MS. McCAWLEY: The statement was made in a March 5th article. So not the two articles we showed you yesterday -- THE COURT: The Churcher article. MS. McCAWLEY: Yes. But it was another article that came out in March of 2011. And the statement was with respect to my client saying she

ny Records custodians necessary to authenticate business records under FRE 803(b) 27. Any witnesses necessary for impeachment or rebuttal 28. Dr. Kliman (expert) 29. Dr. Coonan (expert) 30. Jim Jansen (expert) 31. Chris Andersen (expert) 32. Bill Chandler (rebuttal expert) 33. Dianne Flores

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"

ny Records custodians necessary to authenticate business records under FRE 803(b) 27. Any witnesses necessary for impeachment or rebuttal 28. Dr. Kliman (expert) 29. Dr. Coonan (expert) 30. Jim Jansen (expert) 31. Chris Andersen (expert) 32. Bill Chandler (rebuttal expert) 33. Dianne Flores

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"

reexisting. = THE COURT: And why do you have it in your expert's report? MS. SCHULTZ: Well, our expert is -- I'm assuming you're referring to Dr. Kliman, who is a physician. He's a medical doctor. He took a full -- THE COURT: There's a whole thing about it. Are you going to withdraw the -- MS. SCHUL

statement made? MS. McCAWLEY: The statement was made in a March 5th article. So not the two articles we showed you yesterday -- THI Gl COURT: The Churcher article. MS. McCAWLEY: Yes. But it was another article that came out in March of 2011. And the statement was with respect to my client saying she

hat abuse, and some of that abuse did occur when she was a minor. THE COURT: Yes. Well, okay. But there are other things that she sets forth in the Churcher articles, in the motion to intervene, there are a whole series of other things that are -- I mean, there are things that have been said, and my re