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Case 18-2868, Document 276, 08/09/2019, 2628224, Page16 of 77 28. Plaintiff repeatedly has sought out media organizations to discuss her alleged experience as a victim of sexual abuse. See This Motion at J] 51-54. 29. As discussed above, on December 30, 2014, plaintiff publicly filed an “entirely unnecessary”’ joinder motion laden with what Judge Marra described as “unnecessary,” “lurid details”* about being “sexually abused” as a “minor victim[]” by wealthy and famous men and being “trafficked” all around the world as a “sex slave.” EXHIBIT D, at 1 n.1, 3-6. 30. The plaintiffs alleged purpose in filing the joinder motion was to “vindicate” her rights under the CVRA, expose the government’s “secretly negotiated” “non-prosecution agreement” with Epstein, “shed tremendous public light” on Epstein and “other powerful individuals” that would undermine the agreement, and support the CVRA plaintiffs’ request for documents that would show how Epstein “used his powerful political and social connections to “6, secure a favorable plea deal” and the government’s “motive” to aid Epstein and his “co- conspirators.” See EXHIBIT D, at 1, 6-7, 10 (emphasis supplied). 31. Plaintiff has written the manuscript of a book she has been trying to publish detailing her alleged experience as a victim of sexual abuse and of sex trafficking in Epstein’s alleged “sex scheme.” EXHIBIT KK. 32. Republication alleged by plaintiff. Plaintiff* was required by Interrogatory No. 6 to identify any false statements attributed to Ms. Maxwell that were “‘published globally, including EXHIBIT E, at 7. 47d. at 5. *Id. The undisputed facts relevant to this Motion are contained in the Facts section, above, and within each argument as appropriate. The undisputed facts will be sequentially numbered throughout this Motion.