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Case 1:15-cv-07433-LAP Document 1325-1 Filed 01/04/24 Page 9 of 21 Sometime thereafter, Plaintiff did insert Mr. Dershowitz’s name in her book manuscript but she did not allege therein that she had any sexual relations with him, rather she simply referred to him as a business acquaintance of Mr. Epstein’s. It was not until the Joinder Motion in December 2014 that she claimed she engaged in sexual relations with Mr. Dershowitz, something he adamantly and publicly denied. At the heart of this case is the question of whether Ms. Maxwell defamed Plaintiff by calling her a liar. Of course, if Plaintiff is a liar, then there is no defamation. Churcher had direct and actual knowledge that Plaintiff is a liar and helped orchestrate specific and incredible public lies in concert with Plaintiff relating to Prince Andrew and Alan Dershowitz. In both of these instances, Churcher is not acting as a journalist — she is acting as a friend and advisor to Plaintiff on how to drop names — truth be damned — to try to sell Plaintiff's book. As Churcher puts it, the only incentives are “deadlines and/or cash”. Menninger Decl., Ex. A, p. 12. Churcher is not a journalist; she is a co-conspirator in Plaintiff's publication of false statements regarding numerous people including Prince Andrew, Alan Dershowitz and Ms. Maxwell. It is the denial of the defamatory claims Churcher helped create that is the basis of this defamation suit. There is no reporter shield over these factual matters that are not related to new gathering. D. Churcher’s communications with Plaintiff’s Counsel and Law Enforcement are not news-gathering activities Churcher also admits to communicating regularly with Bradley Edwards, now Plaintiff’s counsel, and other agents for Plaintiff, which communications continue through the present day. See Churcher Decl., {] 9-10. Churcher is the person who initially put Plaintiff in contact with Edwards. See Menninger Decl., Ex A, p. 7. Churcher coached Plaintiff on how to use Edwards to provide information to reporters in a manner that would best help her book sales. See Menninger Decl., Ex A, p. 51-58. According to Plaintiff, she regularly shared information from