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Case 18-2868, Document 276, 08/09/2019, 2628224, Page17 of 77 within the Southern District of New York,”” as plaintiff alleged in Paragraph 9 of Count I of her complaint. In response, plaintiff identified the January 2015 statement and nine instances in which various news media published portions of the January 2015 statement in news articles or broadcast stories. EXHIBIT H, at 7-8; EXHIBIT I, at 4. 33. Innone of the nine instances was there any publication of the entire January 2015 statement. See EXHIBIT H, at 7-8; EXHIBIT I, at 4. 34. Ms. Maxwell and her agents exercised no control or authority over any media organization, including the media identified in plaintiff's response to Interrogatory No. 6, in connection with the media’s publication of portions of the January 2015 statement. EXHIBIT J 4] 24; EXHIBIT K ff 2-3.. 35. Plaintiff's defamation action against Ms. Maxwell. Eight years after Epstein’s guilty plea, plaintiff brought this action, repeating many of the allegations she made in her CVRA joinder motion. See Doc.1 § 9. 36. The complaint alleged that the January 2015 statement “contained the following deliberate falsehoods”: (a) That Giuffre’s sworn allegations “against Ghislaine Maxwell are untrue.” (b) That the allegations have been “shown to be untrue.” (c) That Giuffre’s “claims are obvious lies.” Doc.1 § 30 (boldface and underscoring omitted). SUMMARY JUDGMENT STANDARD “{C]ourts should not be reluctant to grant summary judgment in appropriate cases. ‘One of the principal purposes of the summary judgment rule is to isolate and dispose of factually insupportable claims,’ thereby permitting courts to avoid ‘protracted, expensive and harassing trials.”” Don King Prods., Inc. v. Douglas, 742 F. Supp. 778, 780 (S.D.N.Y. 1990) (quoting 10