Epstein Secrets

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

s, Plaintiff represents that she only seeks to take three de ositions beyond the limit of ten and that she no longer seeks depositions of witnesses Emmy Taylor, JoJo Fontanilla. and Michael Reiter. (Doc. #224 at 2 n.4) She does not state her intentions with respect to other witnesses, like Maria Alessi, th

he no longer seeks depositions of witnesses Emmy Taylor, JoJo Fontanilla. and Michael Reiter. (Doc. #224

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"

EFTA00792771 33. Gregory B. Taylor (live) Kyle D. Jacobson Taylor, Jacobson & Associates, P.C. 390 South Kline Street Lakewood, CO 80226 34. Emmy Taylor (live) do Philip Barden Devonshires Solicitors LLP 33 Finsbury Circus London, United Kingdom EC2M 7DT DX: 33856 Finsbury Square 35. Katie Vaugh

odgers (video) 16 EFTA00792771 33. Gregory B. Taylor (live) Kyle D. Jacobson Taylor, Jacobson & Asso

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

TA01297307 Page 12 No. Full Name 4: VISOSKI. TAYLOR JOSEPHINE TAYLOR, VISOSKI 5: VISOSKI. BROOKE

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

ion.' United States' Nobles, 422 U.S. 225, 238 (1975). The work-product doctrine applies in civil and criminal litigation. Id. at 236. In Hickman' Taylor, the Supreme Court described the policy behind the doctrine protecting the opinion work-product of lawyers. The Court explained that a lawyer is bou

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

craving for that which is sensational and impure."). IsiPretrial discovery is intended to aid the parties in their search for truth. See Hickman v. Taylor, 329 U.S. 495, 501, 67 S.Ct. 385, 91 L.Ed. 451 (1947) (celebrating that "[t]he deposition-discovery regime set out by the Federal Rules of Civil Pr

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

is houses, lying in a hammock. ‘We all dined together that night. Jeffrey was at the head of the table. Bill was at his left. | sat across from him. Emmy Tayler, Ghislaine’s blonde British assistant, sat at my right. ‘Ghislaine was at Bill's left and at the left of Ghislaine there were two olive-skinned brun

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

his houses, lying in a hammock.‘We all dined together that night. Jeffrey was at the head of the table. Bill was at his left. | sat across from him. Emmy Tayler, Ghislaine’s blonde British assistant, sat at my right. ‘Ghislaine was at Bill’s left and at the left of Ghislaine there were two olive-skinned brune