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Case 18-2868, Document 276, 08/09/2019, 2628224, Page75 of 77 March 29 and returning on March 31, 2001.°* The other passengers included world-renowned philanthropist Dr. Henry Jarecki, now aged 83, also a long-time husband, famed academic and scholar, and famous philanthropist.°” Plaintiff produced no evidence substantiating any of her fantastical claims that she had been trafficked by Epstein, or by Maxwell, to any of these men or any others. No witnesses vouched for seeing plaintiff in the company of politicians George Mitchell or Bill Richardson to whom plaintiff claims she was sent. She produced no photographs of herself with them. She had a journal where she claims she documented their names, but she claims she burned that journal in 2013. In May 2011, plaintiff inquired by email to journalist Sharon Churcher to “remind” her of the famous people to whom she was trafficked. Plaintiff has not supported her claims with clear and convincing evidence and thus, Ms. Maxwell’s denials and characterizations of these claims as “obvious lies” is not defamatory as a matter of law. CONCLUSION For the foregoing reasons, the Court should grant summary judgment in favor of Ms. Maxwell. *8 Plaintiff claims, however, that she was trafficked to Dr. Minsky in the U.S. Virgin Islands. * https://en.wikipedia.org/wiki/Henry_Jarecki 68