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Case 18-2868, Document 281, 08/09/2019, 2628234, Page17 of 66 22. The January 2015 statement served two purposes. First, Mr. Barden intended that it mitigate the harm to Ms. Maxwell’s reputation from the press’s republication of Ms. Giuffre’s false allegations. He believed these ends could be accomplished by suggesting to the media that, among other things, they should subject Ms. Giuffre’s allegations to inquiry and scrutiny. For example, he noted in the statement that Ms. Giuffre’s allegations changed dramatically over time, suggesting that they are “obvious lies” and therefore should not be “publicized as news.” MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Ms. Giuffre objects to this paragraph in its entirety. She disputes that the January 2015 statement “served two purposes,” as this statement is wholly unsupported by the record, which Defendant again neglects to cite. Ms. Giuffre also contests the second sentence in which Defendant claims that “Mr. Barden intended that it mitigate the harm to Ms. Maxwell’s reputation from the press’s republication of Ms. Giuffre’s false allegations.” First, Ms. Giuffre disputes any statement of Barden’s intent as explained above. Second, Ms. Giuffre disputes that there was any “republication” by the press as a matter of law, as explained in her memorandum of law opposing summary judgment, as the press did not “republish” the press statement under New York law. Third, Ms. Giuffre disputes that her allegations are “false,” and cites to the following non-exhaustive sampling of evidence to corroborate her allegations against Defendant: e See McCawley Dec. at Exhibit 16, Sjoberg’s May 18, 2016 Dep. Tr. at 8-9, 13, 33-35, 142-143 e See McCawley Dec. at Exhibit 4, Figueroa June 24, 2016 Dep. Tr. Vol. 1 at 96-97 and 103 e See McCawley Dec. at Exhibit 14, Rinaldo Rizzo’s June 10, 2016 Dep. Tr. at 52-60 e See McCawley Dec. at Exhibit 12, Lynn Miller’s May 24, 2016 Dep. Tr. at 115 e See McCawley Dec. at Exhibit 13, Joseph Recarey’s June 21, 2016 Dep. Tr. at 29-30 e See McCawley Dec. at Exhibit 15, David Rodgers’ June 3, 2016 Dep. Tr. at 18, 34-36 17