Epstein Secrets

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

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

rs, the same standard governs the addition of parties under Rule 21 and Rule 15. See Goston v. Potter, No. 08-cv-478 FJS ATB, 2010 WL 4774238, at *5 (N.D.N.Y. 2010) (citing Bridgeport Music, Inc. v. Universal Music Grp., Inc., 248 F.R.D. 408, 412 (S.D.N.Y. 2008)). 4 GIUFFRE002847 HOUSE_OVERSIGHT_014680

and correct copy of a statement on behalf of Ms. Maxwell dated January 2, 2015. 3. Attached as Exhibit B 1s a true and correct copy of an article by Sharon Churcher titled “Teenage girl recruited by paedophile Jeffrey Epstein reveals how she twice met Bill Clinton,” DAILY MAIL, dated March 5, 2011. HOUSE_OVERSI

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

s sexual trafficking victims in a case pending in the Southern District of Florida, specifically case no. 08-cv-80736- KA

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

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

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

dential with the Court, it was to additionally file a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York. Id. ¶ 10. Absent consent of the producing party, designated documents "shall not ... be disclosed."3 Id. 115 . WESTLAW 2018 Thomson Reuters. No c