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Case 1:15-cv-07433-LAP Document 1325-1 Filed 01/04/24 Page 8 of 21 C. Churcher prompted Plaintiff to invent stories regarding Alan Dershowitz Churcher’s direct involvement in creating the allegations in the Joinder Motion regarding Plaintiffs alleged sexual interactions with Alan Dershowitz — or even the knowledge of Alan Dershowitz’ name — is even more apparent. Prior to the December 2014 joinder Motion, there is not a single mention of Mr. Dershowitz in any pleading related to Plaintiff. In Churcher’s March 2011 publications, directly after she interviewed Plaintiff, there was not a single mention of Mr. Dershowitz. It is quite apparent that Plaintiff had never met Mr. Dershowitz or reported that he was a person with whom she had had sexual relations. In the May/June 2011 timeframe, Plaintiff and Churcher’s communications relate primarily to Plaintiff's draft of her novel, hiring a ghostwriter, and requests for advice on how to manage agent and book publication deals. Menninger Decl. Ex. A. As a part of those communications, on May 10, 2011, Plaintiff writes Churcher: “Hello gorgeous, I hope this message comes to you on a bright, sunny day!!! I took your advice about what to offer Sandra [a ghostwriter] and she accepted. We’re drawing up a contract through her agent right now and getting busy to meet my deadline. Just wondering if you have any information on you from when you and I were doing interviews about the J.E. story. I wanted to put the names of these assholes, oops I meant to say, pedo’s, that J.E. sent me to. With everything going on my brain feels like mush and it would be a great deal of help!...”* In an e-mail dated May 11, 2011, Churcher replies to Plaintiff: “Don't forget Alan Dershowitz... JE's buddy and lawyer -good name for your pitch as he repped Claus von Bulow and a movie was made about that case ... title was Reversal of Fortune. We all suspect Alan is a pedo and tho no proof of that, you probably met him when he was hanging put w JE” Menninger Decl. Ex. A, p. 26-28. 4 This email raises its own issues. If Plaintiff was providing her own personal information regarding what allegedly happened to her, why would she require information from Churcher from their interviews about whom she had been “trafficked” to. What information did Churcher provide to Plaintiff that was the basis for Plaintiffs various allegations, as opposed to being factual information based on events that happened to Plaintiff? 6