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Case 18-2868, Document 284, 08/09/2019, 2628244, Page32 of 38 a. Reply: Plaintiff offers no evidence to contradict the facts asserted and they should therefore be deemed admitted. Plaintiff's unsupported spin of those facts should be stricken. 52. Undisputed Fact 52: Plaintiff drafted a 144-page purportedly autobiographical book manuscript in 2011 which she actively sought to publish. In 2011, contemporaneous with her Churcher interviews, plaintiff drafted a book manuscript which purported to document plaintiff's experiences as a teenager in Florida, including her interactions with Epstein and Maxwell. Ex.KK. Plaintiff communicated with literary agents, ghost writers and potential independent publishers in an effort to get her book published. She generated marketing materials and circulated those along with book chapters to numerous individuals associated with publishing and the media. a. Reply: Plaintiff cites inadmissible evidence, and attorney argument, in contradiction of these facts. They should be ignored. The “Victim Notification Letter” is inadmissible hearsay. The psychologist records likewise are inadmissible hearsay. The FBI interview is inadmissible hearsay. Plaintiff's counsel then flatly misrepresents to the Court her own client’s characterization of the book manuscript, calling it a “fictionalized account.” Plaintiff, contradicting her counsel, testified that the book manuscript is “99% true.” Q Is there anything -- well, first of all, did you author that entire manuscript? A Yes, I did. Q Did anyone else author part of that manuscript? A Do you mean did anyone else write this with me? Q Right. A No. Q That's all your writing? 31