giuffre-maxwell
gov.uscourts.nysd.447706.1312.0
9 pg
…certain documents might be embarrassing, would expose non-
parties to media attention, and could result in some unfortunate association between the non-parties
and Jeffrey Epstein or Ghislaine Maxwell. But as the Court has previously recognized, such
generalized concerns about…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.43
4 pg
…the allegations.
But, as Europe correspondent Philip Williams reports, the claims have blown apart
the always uneasy calm between the Palace and the British press.
PHILIP WILLIAMS, REPORTER: As fifth in line to the throne, whatever Prince Andrew
does or…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.25
4 pg
…of 4
ROSS NEIL· SUTHERLAND GOW - 11/18/2016 ·
·1· · · · · · · · ·IN THE HIGH COURT OF JUSTICE
· · · · · · · · · · · QUEEN'S BENCH DIVISION
·2
·3· · · · · · · · · · ·Claim No. CR 2016-624
·4· ·BETWEEN:
·5· · · · · · · · · · · VIRGINIA L. GIUFFRE
· · · · · · · · · · · · · · · · · · · · · …
giuffre-maxwell
gov.uscourts.nysd.447706.1218.13
15 pg
…TO SHOW THAT CHURCHER WAS NOT
ENGAGED IN PROTECTED NEWSGATHERING ACTIVITY ........................ 3
A. The “Primary Relationship” Between Churcher and Plaintiff Was
Reporter and Source ...................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.590.1
4 pg
…the allegations.
But, as Europe correspondent Philip Williams reports, the claims have blown apart
the always uneasy calm between the Palace and the British press.
PHILIP WILLIAMS, REPORTER: As fifth in line to the throne, whatever Prince Andrew
does or…
giuffre-maxwell
gov.uscourts.nysd.447706.263.0
14 pg
…TO SHOW THAT CHURCHER WAS NOT
ENGAGED IN PROTECTED NEWSGATHERING ACTIVITY ........................ 3
A. The “Primary Relationship” Between Churcher and Plaintiff Was
Reporter and Source ...................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.751.9
3 pg
…denial comes after two Sunday papers in Britain published interviews with the woman in which she
claimed that she was forced by American financier Jeffrey Epstein to have sex with Prince Andrew at least three
times between 1999 and 2002…
giuffre-maxwell
gov.uscourts.nysd.447706.57.2
30 pg
…WC2A 2LL
Date: 1 March 2004
Before :
THE HONOURABLE MR JUSTICE MANN
---------------------
Between :
…
giuffre-maxwell
gov.uscourts.nysd.447706.57.1
26 pg
…to privilege to succeed—
Whether form of wording of report conclusive as to purpose
for which prepared
The plaintiff's husband was employed by the defendant
railways board. In a collision between locomotives, he
received injuries from which he died…
giuffre-maxwell
gov.uscourts.nysd.447706.988.0_2
6 pg
… Ex. A (correspondence between Chambers and Plaintiff’s
counsel stating: “I just want to make sure that there is nothing MISSING from the Binder that the
Judge needs to rule on”). The Court’s review of these materials makes clear…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.12
4 pg
…deposition of Sarah Ransome on February 17, 2017, designated Confidential under the
Protective Order.
4. Attached as as Exhibit C (filed under seal) is a true and correct copy of the
engagement letter between Ms. Ransome and Farmer, Jaffe, Weissing…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.26_1
4 pg
…CONFIDENTIAL
2 as part of this case, right?
3 A. Correct, because it was between two
4 consenting adults.
5 Q. Exactly.
6 And so that's Ms. Sjoberg, and then the
7 other individual, I think you said Bolero…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.14_1
11 pg
…6 Q. You are not sure --
7 A. I know they know either other. I
8 can't testify to a meeting between them.
9 Q. Do you know where in New Jersey she
10 lives?
11 A. No
12…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…TO INTERVENE
UNDER FEDERAL RULE OF CIVIL PROCEDURE 24(B) ..............................11
A. There Is Significant Overlap Between the Subject Matter
of the Original Action and This Motion ....................................................12
…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.10_1
27 pg
…lawsuit presents one relatively simple question: is Plaintiff’s claim that she was
sexually abused, sexually trafficked and held as a “sex slave” by Jeffrey Epstein between 1999
and 2002 “with the assistance and participation of” Ms. Maxwell substantially true…
giuffre-maxwell
gov.uscourts.nysd.447706.751.10
4 pg
…prince
under oath.
In her sworn affidavit, the woman described Buckingham Palace's denial that sexual contact ever took place
between the pair as "false and hurtful to me."
Interview request
The woman, identified by Buckingham Palace as Virginia Roberts…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.19
15 pg
…in that statement?
7 MR. PAGLIUCA: I'm going to object
8 and instruct you to the extent this
9 calls for any privileged communications
10 between yourself and Mr. Barden or
11 another lawyer representing you, we're
12…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.9
12 pg
…from
2 Ms. Maxwell on about
July 18th, 2009
3
Plaintiff's Exhibit JE6 E-mail string between 185
4 Jeffrey Epstein and
Ms. Maxwell on about
5 …
giuffre-maxwell
gov.uscourts.nysd.447706.1106.1_1
7 pg
…piece by
11 piece who -- I know Glenn Dubin was first.
12 Q Okay.
13 A And I know Stephen Kaufmann was one of the
14 first I was sent to. Alan Dershowitz could have been
15 between there. Between…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.24
4 pg
…sexually abused by Jeffrey Epstein," said Norman.
"That is a different issue," said Dershowitz. "That is between her and Jeffrey Epstein."
http://www.local10.com/news/alan-dershowitz-sex-slave-accuser-is-serial-liar-prostitute/3... 2/19/2015
…
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