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Case 18-2868, Document 279, 08/09/2019, 2628231, Page22 of 37 Mr. Barden’s approach provides critical context to explaining how the statement builds a logical argument that the new allegations are false. It first notes plaintiff's “original allegations”; then it points out how the story changed and was embellished over time, “now” with allegations that plaintiff had sex with a prominent and highly respected Harvard law professor (“Each time the story is re told [sic] it changes with new salacious details about public figures and world leaders . . . .”). The argument builds up to the opinion in the third paragraph: “[Plaintiff’s] claims are obvious lies and should be treated as such. . . .” Doc.542-6, Ex.F. See generally id., Ex.K (| 13-22. This third paragraph—and the threat in the fourth paragraph to sue the media for republication of plaintiff's falsehoods—confirms what is plain from the statement itself: it was not a traditional press release. Three, the statement was intended to respond (via denial) to the media-recipients’ requests for a reply to the new CVRA joinder-motion allegations. Jd. {J 8, 10, 16. But more than that, it was intended to be “‘a shot across the bow” of the media. Jd. { 17. The logical argument was created to (a) persuade the media-recipients that they needed to “subject plaintiff's allegations to inquiry and scrutiny”; (b) explain to the media-recipients how it was “obvious” that plaintiff “had no credibility” because of her shifting story and increasingly lurid and salacious allegations as time went on, many of which (e.g., the allegations of sex with Prince Andrew and Professor Dershowitz) on their face appear far-fetched,'* and (c) warn the media- Since the CVRA joinder motion, there has emerged a substantial amount of evidence— some from plaintiff's own pen—that plaintiff's allegations about having been “forced” to have sex with prominent individuals are falsehoods. A telling example is a series of emails between plaintiff and reporter Churcher when plaintiff was working on negotiating a book deal about her alleged experiences and Churcher was trying to help her. On May 10, 2011, plaintiff tells Churcher she cannot remember whom she had told Churcher she had had sex with. Churcher responds responds, “Don’t forget Alan Dershowitz,” which Churcher says is a “good name for [plaintiffs] pitch” to her literary agent. It is clear neither Churcher nor plaintiff believed plaintiff (footnote cont’d on next page) 17