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Case 18-2868, Document 276, 08/09/2019, 2628224, Page8 of 77 Defendant Ghislaine Maxwell moves under Federal Rule of Civil Procedure 56 for summary judgment. PRELIMINARY STATEMENT FACTS The following facts are undisputed. Additional undisputed facts are set forth in specific argument sections. All paragraphs containing undisputed facts will be sequentially numbered. 1. Ms. Maxwell’s response to publications of plaintiff’s false allegations: the March 2011 statement. In early 2011 plaintiff in two British tabloid interviews made numerous false and defamatory allegations against Ms. Maxwell. ExHiBiTs A-B.! In the articles, plaintiff made no direct allegations that Ms. Maxwell was involved in any improper conduct with Jeffrey Epstein, who had pleaded guilty in 2007 to procuring a minor for prostitution.” Nonetheless, plaintiff suggested that Ms. Maxwell worked with Epstein and may have known about the crime for which he was convicted. See generally EXHIBITS A-B. 2. In the articles, plaintiff alleged she had sex with Prince Andrew, “a well-known businessman,” a “world-renowned scientist,” a “respected liberal politician,” and a “foreign head of state.” Jd. at 5. 3. In response to the allegations Ms. Maxwell’s British attorney, working with Mr. Gow, issued a statement on March 9, 2011, denying “the various allegations about [Ms. Maxwell] that have appeared recently in the media. These allegations are all entirely false.” EXHIBIT C. 4. The statement read in full: 'The articles were attached as exhibits to the author Sharon Churcher’s declaration in support of her motion to quash an SDT issued to her. See Doc.216-2 & 216-3. Doc. 4§ 11, 14.