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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
second category of evidence we seek to introduce 19 at trial, your Honor, relates to testimony by her fianc 20 Michael Ostrich and her boyfriend Tony Figueroa. The facts on 21 this, your Honor, are that Ms. met Mr. Ostrich, he was 22 the brother of someone she was in rehab with, she was in drug 23 re
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
ipt, as you know. And in that 11 book manuscript, she describes that it was not her who took the 12 money from the tip jar, it was her boyfriend, Tony Figueroa, 13 and that's also what she testified during her deposition. 14 She said, for example, that she didn't commit the 15 theft, that he came in at
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
manuscript, as you know. And in that book manuscript, she describes that it was not her who took the money from the tip jar, it was her boyfriend, Tony Figueroa, and that's also what she testified during her deposition. She said, for example, that she didn't commit the theft, that he came in at the end of he
Entities connected to both Sharon Churcher and Tony Figueroa

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
Bradley Edwards
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
Paul Cassell
PERSON
Bill Clinton
PERSONSigrid McCawley
PERSON
David Boies
PERSONJane Doe
PERSONMaria Farmer
PERSON
George W. Bush
PERSON
Kenneth Marra
PERSON
Virginia Giuffre
PERSON
United States
LOCATIONJeffrey Pagliuca
PERSON
Donald Trump
PERSON
Al Gore
PERSON
Joe Biden
PERSON
Peter Mandelson
PERSON