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Case 18-2868, Document 284, 08/09/2019, 2628244, Page2 of 38 Pursuant to Rule 56.1 of the Local Civil Rules of this Court, defendant Ghislaine Maxwell submits this Reply to Plaintiffs Statement of Contested Facts and Plaintiff's Undisputed Facts (“Response”), Doc. 586-1. INTRODUCTION Plaintiff's Response fails under both the Federal Rules of Evidence and the Local Civil Rules of Procedure. First, Plaintiff largely failed to provide any “‘citation to evidence which would be admissible” to challenge Defendant’s Statement of Material Undisputed Facts and therefore Ms. Maxwell’s undisputed facts should be deemed admitted. Second, rather than set forth “‘additional material facts as to which it is contended that there exists a genuine issue to be tried” (Local Civil Rule 56.1(b)), Plaintiff instead set forth her own purportedly “undisputed facts.” Because Plaintiff did not cross-move for summary judgment, her supposedly “undisputed facts” are not permitted by the Rules and should be stricken. I. Ms. Maxwell’s reply in support of statement of undisputed facts. 1. Undisputed Fact 1: In early 2011 plaintiff in two British tabloid interviews made numerous false and defamatory allegations against Ms. Maxwell. In the articles, plaintiff made no direct allegations that Ms. Maxwell was involved in any improper conduct with Jeffrey Epstein, who had pleaded guilty in 2007 to procuring a minor for prostitution. Nonetheless, plaintiff suggested that Ms. Maxwell worked with Epstein and may have known about the crime for which he was convicted. Exs. A and B. a. Reply: Plaintiff cites no admissible evidence to contest these undisputed facts. McCawley Ex.34 (GIUFFRE368) is an email from Sharon Churcher to Plaintiff. It is Ms. Churcher’s hearsay and therefore inadmissible. In any event, it does not speak to the 1