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Case 18-2868, Document 279, 08/09/2019, 2628231, Page21 of 37 allegations contained in media stories, including the Churcher articles. See Doc.542-3, Ex.C. Whether the 2011 statement “fully” responded to the original allegations and whether it “showed” the original allegations to be untrue are pure (argumentative) opinion. “[O]bvious lies” on its face is an opinion. The “obviousness” of a lie simply cannot be proven true or false. Factor 3: The full context of the statement. Three contextual facts are revealed by the Rule 56 record. One, the email transmitting the statement to the media-representatives—along with the third-person references to Ms. Maxwell—told them Ms. Maxwell did not prepare the statement: “Please find attached a quotable statement on behalf of Ms. Maxwell.” Doc.542-6, Ex.F (emphasis supplied). It is undisputed that in fact Mr. Barden prepared the bulk of it and ultimately approved and adopted as his work all of it. Doc.542-7, Ex.K {[ 10. Two, Mr. Barden’s statement issued on behalf of his client would not be a traditional press release solely to disseminate information to the media; this is why he did not request Mr. Gow or any other public relations specialist to prepare or participate in preparing the statement. /d., Ex.K J 15. The statement was a broad-brush communique to the media about plaintiff and her new allegations; it was not to be a “point by point” rebuttal of each new allegation. Id., Ex.K J 13. The logic and approach to preparing the statement were simple: compare plaintiff's prior allegations and conduct in telling her story with her current allegations and conduct. See generally id., Ex.K J 13. When he wrote the statement, he knew of plaintiffs 2011 allegation that she had not had sex with Prince Andrew and he knew of her CVRA allegation that she did have sex with him. /d., Ex.K J 14. Also within his knowledge was the story she had told Churcher before March 2011—a story that was far less provocative and salacious than the one she included in the joinder motion. See id., Ex.K | 5; compare Docs.542-1 & 542-2, Exs.A & B (Churcher articles published March 2011) with Doc.542-4, Ex.D (plaintiff's joinder motion containing dramatically different and more lurid and salacious allegations). 16