Ours had 38 when we took her for a test drive the evening she was delivered; 42 when we took delivery (1 mile was from our salesperson taking her out to fill up the tank.
The delivery paperwork had the same mileage, so no problem there.)
She was a special order, but sat at the fairgrounds for about 2 weeks before they got her on a rail car. Then she sat at the Jessup railyard for about a week before they put her on a truck. Guess some of the mileage was incurred while they shuffled her about as well.
She did have a small ding on the back above the Jeep logo chrome piece on the liftgate and the chrome piece had a broken clip, so maybe that mileage was from some offroad quality testing
Dealer ordered new part and is going to repair/replace. At just a tad over 1K now and haven't had any problems otherwise with her.