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Case 18-2868, Document 276, 08/09/2019, 2628224, Page13 of 77 15. Notably, the other “Jane Doe” who joined plaintiffs motion who alleged she was sexually abused “many occasions” by Epstein was unable to corroborate any of plaintiff's allegations. See id. at 7-8. 16. Also notably, in her multiple and lengthy consensual interviews with Ms. Churcher three years earlier, plaintiff told Ms. Churcher virtually none of the details she described in the joinder motion. See EXHIBIT A-B. 17. Ms. Maxwell’s response to plaintiff’s “lurid” accusations: the January 2015 statement. As plaintiff and her lawyers expected, before District Judge Marra in the CVRA action could strike the “lurid details” of plaintiff's allegations in the joinder motion, members of the media obtained copies of the motion. See EXHIBIT G, at 31:2-36:4 & Depo.Exs.3-4. 18. At Mr. Barden’s direction, on January 2, 2015, Mr. Gow sent to numerous representatives of British media organizations an email containing “a quotable statement on behalf of Ms Maxwell.” EXHIBIT F; EXHIBIT G, at 33:8-23. The email was sent to more than 6 and probably less than 30 media representatives. See EXHIBIT G, at 33:8-34:3. It was not sent to non-media representatives. See id. at 31:2-35:21. 19. Among the media representatives were Martin Robinson of the Daily Mail; P. Peachey of The Independent; Nick Sommerlad of The Mirror; David Brown of The Times; and Nick Always and Jo-Anne Pugh of the BBC; and David Mercer of the Press Association. See, e.g., EXHIBIT F. These representatives were selected based on their request—after the joinder motion was filed—for a response from Ms. Maxwell to plaintiff's allegations in the motion. See, e.g., EXHIBIT G, at 30:23-35:21 & Depo.Ex.3. 20. The email to the media members read: To Whom It May Concern, Please find attached a quotable statement on behalf of Ms Maxwell.