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Case 18-2868, Document 279, 08/09/2019, 2628231, Page31 of 37 “untrue”; in the same paragraph, the “original allegations” have been “shown to be untrue”; and in the third paragraph, plaintiffs “claims are obvious lies.”*! Doc.1 { 30. Plaintiff cannot prove the falsity of the three sentences, let alone actual malice. If the Rule 56 record establishes that two of plaintiff's CVRA joinder-motion allegations are false and two of her “original” allegations are false, this defamation action collapses on itself. This is because the statement does not specify how many of plaintiffs allegations are false; it certainly does not say “all” plaintiffs allegations are false. It uses the plural of “allegation.” The plural of allegation literally means “more than one.” See Memo. of Law 21. Sentence No. 1. Since the sentence does not specify any particular allegation and since plaintiff made a plethora of allegations against Ms. Maxwell, plaintiff would be required to prove the truth of every one of the plethora of allegations and that Ms. Maxwell knew each one of the allegations was true. Conversely, if there are at least two allegations that plaintiff cannot prove to be true or if there was good reason for Ms. Maxwell to believe at least two of the allegations to be false, then summary judgment should enter against plaintiff. There are at least two allegations by plaintiff against Ms. Maxwell that are untrue. In the CVRA joinder motion, plaintiff alleged that in plaintiffs first encounter with Mr. Epstein, Ms. Maxwell took her to Mr. Epstein’s bedroom for a massage that Mr. Epstein and Ms. Maxwell “turned . . . into a sexual encounter,” Doc.542-4, Ex.D, at 3. This allegation contradicted her allegation in the Sharon Churcher article that a woman other than Ms. Maxwell 2IM{s. Maxwell said in her deposition she “know[s]” plaintiff is a “liar.” This testimony, plaintiff argues, “contradict[s]” our contention that the three sentences in the January 2015 statement are opinion. Resp. 39-40. Plaintiff's argument is a non-sequitur. Ms. Maxwell’s 2016 deposition testimony in which she disclosed all the reasons she believes plaintiff has uttered a plethora of false allegations is wholly irrelevant to whether the three sentences in the January 2015 statement, prepared by Mr. Barden to respond to the joint-motion allegations, are opinions. 26