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Case 1:15-cv-07433-LAP Document 1325-1 Filed 01/04/24 Page 3 of 21 Defendant Ghislaine Maxwell files this Response to Non-Party Sharon Churcher’s Motion to Quash Subpoena, and states as follows: INTRODUCTION Ms. Maxwell seeks documents and testimony from Sharon Churcher (“Churcher”) that are critical to the defense of this single count defamation case. Churcher is the only person with much of the information that will prove the truth defense. The alleged defamatory press release at issue in this case states: “Each time the story is re told it changes with new salacious details about public figures and world leaders and now it is alleged by Ms. Roberts that Alan Dershowitz is involved in having sexual relations with her, which he denies. Ms. Roberts claims are obvious lies and should be treated as such and not publicized as news, as they are defamatory.” Churcher is the sole source of information regarding the original story told by Plaintiff, and was the author of the first articles publishing Plaintiff's claims. She was actively and personally involved in changing those stories over time and in the creation and addition of new salacious details about public figures, including the fabrication of Alan Dershowitz’s alleged sexual relations with Plaintiff. Sharon Churcher’s attempt to avoid the subpoena for deposition and production of documents based on the journalist Shield Law must fail for three reasons. First, much of the discovery sought is unrelated to any news gathering activities. Rather, Churcher was acting as a friend and advisor to Plaintiff in Plaintiff efforts to write and publish a book, sensationalizing her story in a manner that would best boost the publicity, publication and sales of that work of fiction. In that role, she helped manufacture some of the stories that have been denied and that are the central issues in this case.