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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
fender registration. THE COURT: Okay. Agreed. MR. EDWARDS: So at the time -- THE COURT: So? MR. EDWARDS: So at the time she issues her statement SOUTHERN DISTRICT REPORTERS, P.C. EFTA00592418 51 H3ulgiva in 2015, which is, all of these allegations that deal with 4 5 6 7 8 9 10 11 12 13 14 15 1
ff BY: BRADLEY J. EDWARDS, ESQ. HADDON, MORGAN AND FOREMAN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. SOUTHERN DISTRICT REPORTERS, P.C. EFTA00592369 H3ulgiva (Case called) THE COURT: We have a problem, folks. By my count 4 5 6 7 8 9 10 11 12 13 14 15
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
ration. 22 THE COURT: Okay. Agreed. 23 MR. EDWARDS: So at the time 24 THE COURT: So? 25 MR. EDWARDS: So at the time she issues her statement SOUTHERN DISTRICT REPORTERS, P.C. EFTA00794465 (212) 805-0300 EFTA00794466
DWARDS, ESQ. 21 HADDON, MORGAN AND FOREMAN, P.C. Attorneys for Defendant 22 BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. 23 24 25 SOUTHERN DISTRICT REPORTERS, P.C. EFTA00794367 (212) 805-0300 EFTA00794368 2 H3ulgiva 1 2 (Case called) 3 THE COURT: We have a problem, folks. By my count
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
e pages they're now 24 talking about, Dershowitz is asked a question by -- not 25 Mr. Edwards, who's the defendant in that case, your Honor, and SOUTHERN DISTRICT REPORTERS, P.C. EFTA00794467 (212) 805-0300 EFTA00794468 52 H3ulgiva 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 2
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
ntiff BY: PAUL G. CASSELL, ESQ. HADDON, MORGAN AND FOREMAN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00612250 H3VOGIU1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
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"
United States District Court Southern District of New York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant JOINT PRETRIAL STATEMENT Pursuant to this Court's individual
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"
United States District Court Southern District of New York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant JOINT PRETRIAL STATEMENT Pursuant to this Court's individual
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
GM_00060324 CONFIDENTIAL - PURSUANT TO FED. R.QQN(F IDENTIAL DB-SONY-0023148 EFTA_00 170862 EFTA01297311 Page 2 Giuffre V. Maxwell 1:15cv7433 SOUTHERN DISTRICT OF NEW YORK (Foley Square - NYC) V. Maxwell PLAINTIFF: DEFENDANT: Ghislaine Maxwell (Terminated 5/25/2017) Applicant: John Stanley Pottinger In
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
to me that we're not going to complete a variety of discovery issues by July 1. The problem, I think, your Honor, is the cascading effect of that SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA_R1_00024109 EFTA01737513 3 G6ndgium 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22
Entities connected to both Sharon Churcher and Southern District

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Department of Justice
ORGANIZATION
Bradley Edwards
PERSONJack Goldberger
PERSON
Alan Dershowitz
PERSONJane Doe
PERSON
Alexander Acosta
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSON
United States
LOCATIONLeon Black
PERSON
George W. Bush
PERSONRobert D. Critton
PERSONJeffrey Pagliuca
PERSONFBI
ORGANIZATION
A. Marie Villafana
PERSONMartin Weinberg
PERSON
Scarlett Johansson
PERSON