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Case 1:15-cv-07433-LAP Document 1325-1 Filed 01/04/24 Page 14 of 21
He started to interview Virginia. This was unconventional, but Virginia had no
suspicions. Presumably, she thought, this was how the wealthy conducted their
business.
Epstein elicited the information that Virginia had been a runaway, and was no
longer a virgin. Virginia was then told to start massaging Epstein, under the
instructions of the woman who had shown her in. The massage quickly
developed into a sexual encounter.
Churcher Decl., Ex. 2, p. 4/34; See also Churcher Decl., Ex. 5, p. 3/13.
Churcher later reports that Ms. Maxwell hired girls for Epstein. In this story, she alleges
Ms. Maxwell escorted Plaintiff to meet Mr. Epstein, but nowhere claims that Ms. Maxwell
engaged in any sexual interaction with Plaintiff at any time. See Churcher Decl., Ex. 4, p.1-6.
The Joinder Motion alleges that it was Ms. Maxwell that took Plaintiff to Mr. Epstein’s
room on her first visit to the mansion, and allegedly participated in a sexual interaction — a claim
never before made. Ex. C. Obviously, Churcher’s notes, interviews and recordings are directly
relevant to Plaintiff's original story about Ms. Maxwell, and how it has changed and morphed
over time, as well as the motivation for those changes.
The next allegation that has mutated with time in Churcher’s stories and in the Joinder
Motion relates to Plaintiff's age when she first met Epstein and the amount of time she spent
working for him. In Churcher’s first story, she published that Plaintiff first met Epstein in 1998,
soon after her 15" birthday, and worked for him for four years. Churcher Decl., Ex. 1, p. 3/34;
Ex. 5, p. 2/31. The Joinder Motion alleges that Plaintiff met Epstein in 1999, when she was 15.
Both the year and the time of year are material to this case.
Plaintiff now admits that she did not meet Epstein in 1999, but rather met him in 2000
which was the year she worked at the Mar-A-Lago. Plaintiffs claims about meeting Epstein in
1998 or 1999, and her claim of being 15, are lies. Plaintiff still claims, however, that she was 16
years old at the time she met Epstein. Menninger Decl., Ex. B, p. 104. Despite efforts to obtain
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Dates
Document Details
| Filename | Giuffre_Maxwell_Batch2_p00015.png |
| File Size | 316.4 KB |
| OCR Confidence | 94.9% |
| Has Readable Text | Yes |
| Text Length | 2,202 characters |
| Indexed | 2026-02-04 12:37:01.367452 |