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helicopter with him by plaintiff in her Sharon Churcher published articles.

And here, in January of 2015, Ms. Maxwell is saying he was never on the island. It doesn't depend on Louie Freeh or anybody else. That's obviously -- in this particular email,

your Honor, she's cataloged all of the changed stories of

Virginia Roberts, all of the lies Virginia Roberts has told,

all of the different news articles in which those lies were

told, and said that this is going to be the basis of her press complaint in the UK.

Likewise, on the next page, your Honor, GM009, at the

bottom, again, she specifically refutes the claims about Bill Clinton being on the island and says, "He was never there."

Right after that, she says, "Virginia discussed that Al Gore

and his wife Tipper were also guests on the island." And

Ms. Maxwell writes, "They have also never been on the island,

and I don't believe they even know Jeffrey Epstein." So when the jury is asked to consider what Ms. Maxwell

meant when she issued, through her attorney and her press

agent, the January 2nd, 2015 statement, we have a

contemporaneous document drafted by her that was produced in

discovery a year ago. None of it refers to the Jane Doe 102 complaint, none of it refers to the CVRA joinder motion. None of it. It refers simply to press allegations that have been

floating around about her and about her involvement with

SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

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