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Case 1:15-cv-07433-LAP Document 1325-1 Filed 01/04/24 Page 7 of 21 The December 2014 Joinder Motion is the first publication of alleged sexual interaction between Plaintiff and Prince Andrew. At some point between March 2011 and January 2015, Churcher requested that Plaintiff handwrite a diary describing her alleged sexual encounters with Prince Andrew. Attached to the Churcher Declaration at Exhibit 7 is an Article subtitled “Diary Entries Of ‘Teen Sex Slave’ Detail Sorted Hook-Up With Prince Andrew — In Her Own Handwriting.” The article claims to print excerpts of a contemporaneous journal kept by Plaintiff when she was 17, stating “In a bombshell world exclusive, RadarOnline.com has exclusively obtained the secret journal of the then 17-year-old employed to have sex with billionaire pedophile Jeffrey Epstein and his rich and powerful pals — and it’s packed with scandalous claims about her illicit trysts, including with Andrew, the fifth in line to the British throne.” Churcher Decl. Ex. 7. This alleged 24 page “diary” or “journal” was a completely fabricated document handwritten by Plaintiff at the request and direction of Churcher. See Menninger Decl. Ex. B, p. 207-208; 226-231° Plaintiff maintains she did not keep a copy of this handwritten “diary,” leaving the only source of the complete document and information about its creation with the person who asked for the document’s fabrication — Churcher.’ If there was no suggestion of sexual contact with Prince Andrew as of March 2, 2011, how and when was this story first created? From the email correspondence, it appears that Churcher was directly involved in inventing this story during the course of creating stories for a book — stories that would generate the interest of publishers. Churcher’s testimony on how the Prince Andrew allegation was first created is direct evidence in this case. ? In actuality, the only journal Plaintiff ever maintained that might contain relevant information was purposefully destroyed by Plaintiff in a bonfire in 2013, at a time when she was represented by counsel and actively trying to insert herself as a Plaintiff in the CVRA case. Menninger Decl., Ex. B, p. 205-209. > To the extent Churcher argues that the creation of this “diary” was somehow part of the news “gathering” process, it was clearly not confidential, and the test requiring production of the non-published potions, discussed below, is met — the information is highly relevant, critical to the defense, and available form no other source. 5