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Case 18-2868, Document 276, 08/09/2019, 2628224, Page23 of 77 lies.” As noted, her claims not to have slept with Prince Andrew and to have slept with Prince Andrew are a classic example of an obvious lie. One or other account is on the face of it a lie. EXHIBIT J § 20. That Mr. Barden on behalf of Ms. Maxwell was expressing his opinion—in the form of a legal argument—as a lawyer would be lost if words and phrases are extracted from and used outside the context of the January 2015 statement. Yet, this is precisely what the media did in their articles on the statement and what plaintiff did in her complaint (see Doc.1 § 30). Finally, the statement was intended to be a “shot across the bow” of the media-recipients so that they understood the seriousness with which Ms. Maxwell considered the publication of plaintiffs obviously false allegations and the legal indefensibility of their own conduct. See id. 4] 17. Selectively excerpting from the statement would seriously undermine this purpose by changing the force of the message to the media-recipients. Under these circumstances, selective, partial and out-of-context republication of Mr. Barden’s deliberate and carefully crafted message to the media-representatives, as a matter of law, cannot result in defamation liability for Ms. Maxwell. Accordingly, the Court should enter partial summary judgment. B. Because plaintiff is a limited public figure, imposing liability upon Ms. Maxwell for republication of the January 2015 statement would violate the First Amendment. As this Court recognized in Davis, New York Times v. Sullivan"” and its progeny “preclude states from imposing liability without fault in actions for defamation, especially by public figures.” 580 F. Supp. at 1097 (citing, inter alia, Gertz v. Robert Welch, Inc., 418 U.S. 323 (1974)). This principle precludes the imposition of liability for republication of an allegedly 376 U.S. 254 (1964). 16