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Case 18-2868, Document 281, 08/09/2019, 2628234, Page2 of 66 DEFENDANT’S PURPORTED FACTS 2. In the articles, Ms. Giuffre alleged she had sex with Prince Andrew, “a well-known businessman,” a “world-renowned scientist,” a “respected liberal politician,” and a “foreign head of state.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre does not contest this fact, but believes that it is irrelevant. DEFENDANT’S PURPORTED FACTS 3. In response to the allegations Ms. Maxwell’s British attorney, working with Mr. Gow, issued a statement on March 9, 2011, denying “the various allegations about [Ms. Maxwell] that have appeared recently in the media. These allegations are all entirely false.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre denies that Mr. Barden, “issued a statement.” Instead it appears to have the contact as Ross Gow and a reference to Devonshire Solicitors. DEFENDANT’S PURPORTED FACTS 4. The statement read in full: Statement on Behalf of Ghislaine Maxwell By Devonshires Solicitors, PRNE Wednesday, March 9, 2011 London, March 10, 2011 - Ghislaine Maxwell denies the various allegations about her that have appeared recently in the media. These allegations are all entirely false. It is unacceptable that letters sent by Ms. Maxwell’s legal representatives to certain newspapers pointing out the truth and asking for the allegations to be withdrawn have simply been ignored. In the circumstances, Ms. Maxwell is now proceeding to take legal action against those newspapers. “T understand newspapers need stories to sell copies. It is well known that certain newspapers live by the adage, “why let the truth get in the way of a good story.” However, the allegations made against me are abhorrent and entirely untrue and I ask that they stop,” said Ghislaine Maxwell. “A number of newspapers have shown a complete lack of accuracy in their reporting of this story and a failure to carry out the most elementary investigation or any real due diligence. I am now taking action to clear my name,” she said.