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Case 1:15-cv-07433-LAP Document 1328-6 Filed 01/05/24 Page 16 of 32 Id. § 43. even though she had accused other prominent people of abusing her and had plenty of opportunity to do so. In an exchange of emails in 2011, Ms. Churcher, who was advising Ms. Giuffre about how to maximize her payments for selling her story, first raised the idea of mentioning Professor Dershowitz in connection with the alleged abuse, despite the fact that there was “no proof” that he was involved. After receiving this email, Ms. Giuffre did in fact put Mr. Dershowitz in her book draft, but she conspicuously did not accuse him of sexual abuse or even any sexual contact, even though she explicitly named others who she claimed had abused her. In a subsequent email exchange between Ms. Churcher, Ms. Giuffre, and Mr. Weisfeld, Ms. Churcher described several categories of prominent individuals with whom Ms. Giuffre claimed to have had sexual encounters. Professor Dershowitz’s name, along with that of Kenneth Starr, is mentioned in the email, but on/y as one of the lawyers who negotiated Mr. Epstein’s plea agreement, not as one the “amazing names” of those who allegedly abused Ms. Giuffre. Ms. Giuffre lied during her deposition in the defamation case brought by her lawyers against Professor Dershowitz, testifying that there were no emails between herself and Ms. Churcher that mentioned Professor Dershowitz by name. Her lawyers did not correct this testimony. In her Reply Brief, Ms. Churcher has confirmed that Professor Dershowitz was not among the prominent individuals that Ms. Giuffre was accusing of sexual misconduct. The Reply Brief affirmatively argues that Ms. Churcher was “not suggesting” that Professor Dershowitz had sex with Ms. Giuffre, but merely mentioned him to remind Ms. Giuffre that Epstein and Professor Dershowitz knew each other. The Requested Documents strongly corroborate Professor Dershowitz’s denials of Ms. Giuffre’s malicious and false allegations against him, and undermine her credibility by showing that she has lied under oath about him before. /d. §] 44. Because Ms. Giuffre and her lawyers continue to publicly stand by Ms. Giuffre’s accusations against Professor Dershowitz, he has a compelling need to use the Requested Documents in defending his reputation. Jd. § 47. 10