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Case 1:15-cv-07433-LAP Document 1325-1 Filed 01/04/24 Page 6 of 21 Plaintiff, setting up their initial meeting where Churcher planned to be present at that meeting “for support,” not in her capacity as a journalist. Menninger Decl. Ex. A, p. 3. Plaintiff did begin writing her book and sent versions of her manuscript to Churcher for her review and comment — again, in her capacity as a friend, not as a journalist. Menninger Decl. Ex. A, p. 59. Churcher also had extensive discussion with Plaintiff on the best strategies for getting interest in her book, including determining when to “name names” Menninger Decl. Ex. A, p. 63. She strategized with Plaintiff and Plaintiff's counsel, Brad Edwards, on how to use a potential Vanity Fair article as book publicity by dropping names of famous politicians, claiming she was sex trafficked, but refusing to provide additional information because she was writing a book. Menninger Decl. Ex. A, p. 51-58. Through some of these communications between Plaintiff and Churcher, it is obvious that stories in the book — later to become allegation in the Joinder Motion — were created and supported based on the suggestions of Churcher. They were not reported by Plaintiff in her initial interview, or in Churcher’s initial publications, because they did not occur. B. Churcher prompted Plaintiff to fabricate stories regarding Prince Andrew In 2011, when Churcher first reported on Plaintiff's story after having just spent weeks interviewing Plaintiff in Australia, and with a particular focus on reporting Plaintiff's meeting Prince Andrew, Churcher specifically reported: “[t]here is no suggestion that there was any sexual contact between Virginia and Andrew, or that Andrew knew that Epstein paid her to have sex with his friends.” Churcher Decl., Ex. 2, p, 6/34. Shortly thereafter, on March 20, 2011, Churcher emailed Plaintiff explaining to her how she can corroborate a story to tell the FBI — that she was “given to” Prince Andrew. Menninger Decl., Ex. A, p. 8. Churcher provided an explanation for how Plaintiff can substantiate the claim — a claim not previously made by Plaintiff.