Lemma 1: Given four coplanar points, there cannot be two different pairs of disjoint circles whose diameter endpoints are the four points. Proof.
Lemma 2: Given three points $P,Q,R$, if $R$ is in $\text{C}_{PQ}$ (the circle with diameter $PQ$), then $Q$ is not in $\text{C}_{PR}$. Proof: If the lemma is false, then $\angle PRQ>90^\circ$ and $\angle PQR>90^\circ$, so the angles in triangle $PQR$ sum to more than $180^\circ$, which is impossible.
Any pair of circles is either intersecting, disjoint, or "enclosing" (one encloses the other).
Assume, for the sake of contradiction, that we have four points $A,B,C,D$, and among the three ways of drawing the pairs of circles, none of them result in "intersecting". Then by Lemma 1 we must have (at least) two ways of drawing the pair of circles, that each result in "enclosing".
Suppose $\text{C}_{AB}$ is in $\text{C}_{CD}$:
- $A$ is in $\text{C}_{CD}$, so by Lemma 2, $C$ is not in $\text{C}_{AD}$, so $\text{C}_{BC}$ is not in $\text{C}_{AD}$.
- $B$ is in $\text{C}_{CD}$, so by Lemma 2, $D$ is not in $\text{C}_{BC}$, so $\text{C}_{AD}$ is not in $\text{C}_{BC}$.
So $\text{C}_{AD}$ and $\text{C}_{BC}$ are not "enclosing". And by a similar argument, $\text{C}_{AC}$ and $\text{C}_{BD}$ are not "enclosing". Contradiction.
Therefore we can always draw a pair of intersecting circles.