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Case 18-2868, Document 276, 08/09/2019, 2628224, Page34 of 77 9920 sexually exploited by Epstein, Prince Andrew and Epstein’s “male peers,” plaintiff made 921 9922 virtually none of what Judge Marra found were “unnecessary” and “lurid details””~ about how Ms. Maxwell allegedly had subjected her to sexual abuse and trafficking. After plaintiff filed the CVRA motion, some thirty reporters contacted Ms. Maxwell’s press representative, Mr. Gow, for Ms. Maxwell’s response. As Ms. Maxwell’s lawyer, Mr. Barden undertook that task. Relying on his knowledge of the 2011 articles publishing plaintiffs allegations and drawing on his experience and training as a lawyer, Mr. Barden crafted a response with the goal of discrediting plaintiff and what the statement called plaintiff's “new” allegations. To that end Mr. Barden contrasted plaintiff’s “old” allegations from 2011 with the “new” 2014 allegations. The second paragraph of the statement is indicative of this strategy: “Each time the story is re told [sic] it changes with new salacious details about public figures and world leaders and now it is alleged by [Ms. Giuffre] that Alan Derschowitz [sic] is involved in having sexual relations with her, which he denies.” EXHIBIT F (emphasis supplied). Having established the dramatic difference between these sets of allegations suggesting plaintiff was fabricating more and more-salacious allegations as she had more time to manufacture them, Mr. Barden added the third paragraph: “[Ms. Giuffre’s] claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory.” /d. (emphasis supplied). Mr. Barden’s arguments constitute “pure opinion,” Steinhilber, 501 N.E.2d at 552. They take established and revealed facts—plaintiff’s modest 2011 allegations to a newspaper reporter and plaintiff's expansive, unnecessary and lurid 2014 allegations in a motion to open the door to 2 Id. *IEXHIBIT E, at 5. 21d. 27