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Case 1:15-cv-07433-LAP Document 1325-1 Filed 01/04/24 Page 15 of 21
records from the Mar-A-Lago, they have no records of Plaintiff's dates of employment to
establish the timeframe. Churcher is a witness with information fixing the month when Plaintiff
claims to have met Epstein, i.e. soon after her birthday in August. In light of the now admitting
year — 2000 — Plaintiff would have been 17 at the time.
Other highly relevant information in Churcher’s sole possession is the identification of
what documents and information Plaintiff was shown by Churcher, including flight logs,
pictures, or other witness statements. For instance, based on email correspondence, it appears
that Churcher was in possession of Epstein’s flight logs. There is no indication that Plaintiff had
seen those flight logs prior to meeting Churcher. Plaintiff never mentions certain names that
appear in the flight logs prior to Churcher’s meeting with her in February 2011. By way of
example, Bill Clinton is referenced in the flight logs. Before 2011, Plaintiff never mentioned or
references President Clinton. Yet, suddenly and out of thin air, Plaintiff allegedly reports to
Churcher in 2011 that she met Bill Clinton twice, and that Ms. Maxwell flew President Clinton
on a helicopter to Mr. Epstein’s Island — a story which has since been fully discredited as a lie.
This is simply one example of names and stories that were mysteriously added to Plaintiffs
story, likely through Churcher’s suggestive questioning and presentation of documents to
Plaintiff. The only person who can testify on this highly relevant matter, including what
documents were shown to Plaintiff, is Churcher.
Churcher also reported that Plaintiff was sent by Epstein (and Epstein alone) to meet with
men including “a well-known businessman (whose pregnant wife was asleep in the next room), a
world-renowned scientist, a respected liberal politician and a foreign head of state.” Churcher
Decl., Ex. 2, p. 5/34. By contrast, the Joinder Motion alleges “Epstein also trafficked Jane Doe
#3 [Plaintiff] for sexual purposes to many other powerful men, including numerous prominent
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Dates
Document Details
| Filename | Giuffre_Maxwell_Batch2_p00016.png |
| File Size | 305.9 KB |
| OCR Confidence | 95.2% |
| Has Readable Text | Yes |
| Text Length | 2,143 characters |
| Indexed | 2026-02-04 12:37:01.577886 |