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Case 18-2868, Document 276, 08/09/2019, 2628224, Page31 of 77 Jane Doe 3 is Virginia Roberts—so not a new individual. The allegations made by Victoria Roberts [sic] against Ghislaine Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be untrue. 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 Roberts [sic] that Alan Derschowitz [sic] is involved in having sexual relations with her, which he denies. Ms Roberts claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory. Ghislaine Maxwell’s original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavoury nature, which have appeared in the British press and elsewhere and reserves her right to seek redress at the repetition of such old defamatory claims. EXHIBIT F (italics and underscoring supplied). Plaintiff listed the underscored clauses/phrases in the Complaint as the “deliberate falsehoods,” Doc.1 | 30, and “false and defamatory statements,” id. 32, plaintiff is suing on.'° As discussed above, it is improper to remove from their context and isolate allegedly defamatory words, phrases and clauses of sentences from an allegedly defamatory publication. Instead, the allegedly defamatory words, phrases and clauses must be (a) “construed in the context of the entire statement or publication as a whole”;'® (b) considered “from the whole scope and apparent object of the writer”;'” and (c) “viewed from the perspective of the audience to whom it is addressed.”'® The statement was directed at a discrete number of—some 30—members of the media in reply to their request for a response from Ms. Maxwell to Ms. Giuffre’s CVRA joinder motion. Plaintiff also alleges that Ms. Maxwell slandered her on January 4, 2015, when responding to a question posed to her while she was on a Manhattan street. Doc.1 § 37. This allegedly defamatory statement is addressed in Argument IV, below. 16 Aronson, 483 N.E.2d at 1139. "James, 353 N.E.2d at 838. '8Nibella, 2002 WL 31427362, at *2. 24