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Case 18-2868, Document 284, 08/09/2019, 2628244, Page4 of 38 “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. Media contact: Ross Gow Acuity Reputation Tel: +44-203-008-7790 Mob: +44-7778-755-25 | Email: ross @acuityreputation.com Media contact: Ross Gow, Acuity Reputation, Tel: +44-203- 008-7790, Mob: +44-7778-755-251, Email: ross at acuityreputation.com Ex.C. a. Reply: Plaintiff does dispute the contents of the 2011 statement and therefore it should be deemed admitted. 5. Undisputed Fact 5: Plaintiffs gratuitous and “lurid” accusations in an unrelated action. In 2008 two alleged victims of Epstein brought an action under the Crime Victims’ Rights Act against the United States government purporting to challenge Epstein’s plea agreement. They alleged the government violated their CVRA rights by entering into the agreement. Ex.D, at 2. a. Reply: Plaintiff “stipulates” to the facts contained in paragraph 5 and therefore they should be deemed admitted. 6. Undisputed Fact 6: Seven years later, on December 30, 2014, Ms. Giuffre moved to join the CVRA action, claiming she, too, had her CVRA rights violated by the government. On January 1, 2015, Ms. Giuffre filed a “corrected” joinder motion. Ex.D at 1, 9. a. Reply: Plaintiff “agreed” to this paragraph.