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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
hey have the burden of proving that what Ms. Maxwell said was false. That's what is at issue. We have to look at Ms. Maxwell's statement issued by Barden and Gow and then go backwards from there. And the burden on the plaintiff is proving falsity of that statement. It is not the situation where -- wh
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
the burden of proving that what Ms. Maxwell said was false. 16 That's what is at issue. We have to look at Ms. Maxwell's 17 statement issued by Barden and Gow and then go backwards from 18 there. And the burden on the plaintiff is proving falsity of 19 that statement. It is not the situation whe
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"
d, the media obtained copies of the motion. At issue is a January 2, 2015, statement prepared by Ms. Maxwell's British solicitor Philip Barden. Mr. Barden sent the statement to Ms. Maxwell for approval and, following approval, caused Mr. Gow to send (via email) the statement to six to thirty members of
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"
d, the media obtained copies of the motion. At issue is a January 2, 2015, statement prepared by Ms. Maxwell's British solicitor Philip Barden. Mr. Barden sent the statement to Ms. Maxwell for approval and, following approval, caused Mr. Gow to send (via email) the statement to six to thirty members of
Entities connected to both Sharon Churcher and Barden

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Bradley Edwards
PERSON
Alan Dershowitz
PERSON
Paul Cassell
PERSONSigrid McCawley
PERSON
Virginia Giuffre
PERSON
David Boies
PERSONMaria Farmer
PERSON
George W. Bush
PERSONJeffrey Pagliuca
PERSONDarren Indyke
PERSON
United States
LOCATION
Colorado
LOCATION
Kenneth Marra
PERSON
Jean-Luc Brunel
PERSON
Denver
LOCATIONLaura Menninger
PERSON
Vicky Ward
PERSON