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

26 disclosures served on November 11, 2015 and two of the six were specifically mentioned in Plaintiff's Complaint. Finally, the fact that witness Rinaldo Rizzo had a deposition re-scheduled from April until June does not have any bearing on the issue presented by this motion. Mr. Rizzo was deposed on June

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"

icating whether such witness will testify in person or by deposition: Plaintiff's Statement: 1. Daniel Wilson (live) 2. (video) 3. (live) 4. Rinaldo Rizzo (live) 5. Tony Figueroa (video) 6. (live) 7. (live) 8. (video) 9. (video) 10. Detective Recarey (video) 11. Alexander Hall (voice recor

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"

icating whether such witness will testify in person or by deposition: Plaintiff's Statement: 1. Daniel Wilson (live) 2. (video) 3. (live) 4. Rinaldo Rizzo (live) 5. Tony Figueroa (video) 6. (live) 8. (video) 9. (video) 10. (video) 11. (voice recording) 12. Jean Luc Brunel (live) 13. Jeff