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Case 18-2868, Document 280, 08/09/2019, 2628232, Page34 of 74 Additionally, 2011 correspondence with Sharon Churcher shows that Ms. Giuffre disclosed her sexual encounters with Prince Andrew, but Churcher had to check with the publisher’s lawyers “on how much can be published,” From: Sharon.Churcher@mailonsunday.co.uk Sent: Friday, 18 February 2011 7:25 AM To: Virginia Giuffre Hi there Have been up all night writing. Won't have an opinion from our lawyer on how much can be published until London wakes up. The lawyers wanted internal FBI documents but | think the Justice Dept letter is all you have from the feds??? Anyway can | give you a call early afternoon? Maybe have a late lunch? s See McCawley Dec. at Exhibit 34, GIUFFRE003678. Accordingly, there is documentary evidence that refutes Defendant’s meritless argument that Ms. Giuffre did not allege she had sex with Prince Andrew until 2014. To the contrary, two sources, including the FBI, show Ms. Giuffre made these claims in 2011. (On Defendant Has Produced No Documents Whatsoever That Tend to Show That She Did Not Procure Underage Girls For Jeffrey Epstein. Defendant has produced no documents that even tend to show that she did not procure underage girls for sex with Epstein, and no documents that tend to show that she did not participate in the abuse. Indeed, Defendant refused to produce any documents dated prior to 2009, which includes the 2000-2002 period during which she abused Ms. Giuffre. Against this backdrop of an avalanche of evidence showing the Defendant sexually trafficked Ms. Giuffre, summary judgment on any of the issues advanced by Defen dant is inappropriate. While we discuss the particulars of the individual claims below, the larger picture is important too. Ms. Giuffre will prove at trial that Epstein and Defendant sexually trafficked her. And yet, when Ms. Giuffre had the courage to come forward and expose what Defendant had done to world — in a Court pleading trying to hold Epstein accountable — Defendant 26