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20 Za 22 23 24 25 Case 1:15-cv-07433-LAP Document 1332-10 Filed 01/08/24 Page 34 of 64 33 H2G8GIUC says in the article that she interviewed the plaintiff "at length." In the article it says -- I think it was on page 3 of the article; Exhibit A to our motion for summary judgment -—- for a week or better she interviewed the plaintiff. This was plaintiff's coming-out story, first time that she had publicly disclosed who she was and what has happened to her, supposedly, to Ms. Churcher. Ms. Churcher then writes a very lengthy article, Exhibit A to our memorandum, and the second column, Judge, discusses the plaintiff's allegations on the very same subjects. The first encounter with Mr. Epstein and then the second encounter with Prince Andrew. As the Court can see from this very simple comparison, anyone with half a brain in January of 2015 could take a look at column 1 and look at column 2 and decide that the original allegations are either true or they are false; the new allegations are either true or false. Now, here is a situation where we are not talking about opinion; we are talking about remembered fact or, alternatively, manufactured fact. Now, either the plaintiff had these encounters as she described in 2011, or she had the encounters as described in her CVRA joinder motion in December 2014. As the Court says in its 12(b)(6) order, one of these must be true. This is a binary question, Judge. You can't have both of these being true. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300