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Case 18-2868, Document 284, 08/09/2019, 2628244, Page10 of 38 Doe’ (who was represented by Plaintiff's counsel, and therefore had the ability to furnish such an affidavit). Indeed, Plaintiff acknowledges that the “other Jane Doe” “does not know Ms. Giuffre.” These facts must be deemed admitted. J. who is NOT the other Jane Doe, is irrelevant to the undisputed fact asserted. She also offers no corroboration of the ‘same pattern of abuse,’ and in fact does not “remember” any such facts, as already briefed. See Doc. 567 at 12-14. 16. Undisputed Fact 16: Also notably, in her multiple and lengthy consensual interviews with Ms. Churcher three years earlier, plaintiff told Ms. Churcher of virtually none of the details she described in the joinder motion. Exs. A-B. a. Reply: Plaintiffs protestation aside, the Churcher articles (attached to Ms. Churcher’s sworn affidavit filed in this case at Doc. 216 and 216-1 through 216-8) fail to include the vast majority of details included in Plaintiff's CVRA joinder motion, as any side-by-side comparison will reveal. Plaintiff's simple facile response is that she “did reveal details in 2011 consistent with those in the joinder motion.” She offers no admissible evidence of these details she “revealed” to Ms. Churcher, instead citing to a heavily redacted interview she purportedly gave to the FBI, not Ms. Churcher. The purported FBI report is itself hearsay, not to mention, redacted and prepared years after any supposed interview of Plaintiff. McCawley Decl. Ex.31. Because Plaintiff offers no admissible evidence to contradict the discrepancies between the Churcher articles and the joinder motion, these facts should be deemed admitted. 17. Undisputed Fact 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