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

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

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

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

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

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

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

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

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

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

Donald, I'm Prince Andrew and the 17-year-old girl his sex offender friend flew to Britain to meet . h | m This advertisement ends in 7 seconds By SHARON CHURCHER UPDATED: 08:02 EST, 2 March 2011 - Virginia Roberts reveals she is ‘Jane Doe 102' in Jeffrey Epstein case - Mother-of-three spent four years as mill

n § See Excerpts of Roberts’s Deposition Transcript, attached hereto (under seal) as Exhibit F.' i TT eee Pe See id.; see also March 2, 2011, Sharon Churcher, Daily Mail, attached hereto as Exhibit G. Dershowitz has also discovered that Roberts ee Sec Exhibit F; see also AD-006931-006933, Transcript of T

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"

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

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

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"

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

t engaged in sex acts with him. She did not raise those claims until 2014. Also in when was still writing her memoir, she exchanged emails with Sharon Churcher, a reporter for the Mail on Sunday. In one email.Misked Churcher to help her put together a list of Epstein's well-known associates so that could i

ne email.Misked Churcher to help her put together a list of Epstein's well-known associates so that could include them in her memoir. In response. Churcher wrote, "Don't forget Alan Dershowitz. JE's buddy and lawyer. Good name for your pitch... We all suspect Alan is a pedo and tho no proof of that, you

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

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

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

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

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

ntiff's Brief in Support of the Privilege Claimed for In Camera Submission • 155 — Defendant's Motion to Compel Non-Privileged Documents • 215 - Sharon Churcher Motion to Quash Subpoena • 231 — Defendant's Motion to Reopen Deposition of Plaintiff Counsel for Ms. Maxwell is available for a telephone confere

h noon ET Saturday deadline re Mr Bradley Edwards vs Mr Jeffrey Epstein Tonja Haddad Coleman, Esq. Sent from my iPhone Begin forwarded message: From: Sharon Churcher Date: October 18, 2013 at 6:32:28 PM EDT To: " Ce: Nick Pyke < L, Liz. Hartley Subject: Request for comment from The Mail on Sunday with noon ET Satu

Phone On Oct 18, 2013, at 6:38 PM, Tonja Haddad Coleman iii, wrote: Tonja Haddad Coleman, Esq. Sent from my iPhone Begin forwarded message: From: Sharon Churcher Date: October 18, 2013 at 6:32:28 PM EDT Ce: Nick Pykc Si Li: Hartley Subject: Request for comment from The Mail on Sunday with noon ET Saturday de

my iPhone On Oct 18, 2013, at 6:38 PM, Tonja Haddad Coleman < > wrote: Tonja Haddad Coleman, Esq. Sent from my iPhone Begin forwarded message: From: Sharon Churcher < Date: October 18, 2013 at 6:32:28 PM EDT To: Cc: Nick Pyke 1 7, Liz Hartley Subject: Request for comment from The Mail on Sunday with noon ET Satur

om my iPhone On Oct 18, 2013, at 6:38 PM, Tonja Haddad Coleman > wrote: Tonja Haddad Coleman, Esq. Sent from my iPhone Begin forwarded message: From: Sharon Churcher < Date: October 18. 2013 at 6:32:28 PM EDT To: " <tonja@,tonjahaddad.com> Cc: Nick Pyke 1 LP, Liz Hartley < Subject: Request for comment from The Mai

oon ET Saturday deadline re Mr Bradley Edwards vs Mr Jeffrey Epstein Tonja Haddad Coleman, Esq. Sent from my iPhone Begin forwarded message: From: Sharon Churcher Date: October 18, 2013 at 6:32:28 PM EDT Ce: Nick Pyke 7 Harty TT Subject: Request for comment from The Mail on Sunday with noon ET Saturday deadli

from my iPhone On Oct 18, 2013, at 6:38 PM, Tonja Haddad Coleman wrote: Tonja Haddad Coleman, Esq. Sent from my iPhone Begin forwarded message: From: Sharon Churcher Date: October 18, 2013 at 6:32:28 PM EDT To: Cc: Nick Pyke ?, Liz Hartley < Subject: Request for comment from The Mail on Sunday with noon ET Saturda

of New York, on the 11th day of September, two thousand twenty. Plaintiff-Appellee, ORDER v. 20-2413 Ghislaine Maxwell, Defendant-Appellant. Sharon Churcher, Jeffrey Epstein, Respondents, Julie Brown, Miami Herald Media Company, Alan M. Dershowitz, Michael Cemovich, DBA Cemovich Media, Intervenors. I