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Case 18-2868, Document 284, 08/09/2019, 2628244, Page16 of 38 time-only, comprehensive response—quoted in full—to plaintiff's December 30, 2014, allegations that would give the media Ms. Maxwell’s response. Jd. { 18. The purpose of the prefatory statement was to inform the media-recipients of this intent. Id. a. Reply: Plaintiff again “disputes” any statement related to Mr. Barden’s purpose or intent, but offers no evidence contradicting his purpose or intent. She simply points out that Ms. Maxwell retained Mr. Gow in early 2015, and that he works for a public relations firm, which is non-responsive to the fact at issue, i.e., Mr. Barden’s intent with respect to language included in the statement. No one has contested that it was Mr. Gow who actually forwarded the statement to select members of the media who had requested aresponse. The fact set forth should be deemed admitted. 25. Undisputed Fact 25: Plaintiff’s activities to bring light to the rights of victims of sexual abuse. Plaintiff has engaged in numerous activities to bring attention to herself, to the prosecution and punishment of wealthy individuals such as Epstein, and to her claimed interest of bringing light to the rights of victims of sexual abuse. a. Reply: Plaintiff offers no evidence to dispute the facts cited and so they should be deemed admitted. 26. Undisputed Fact 26: Plaintiff created an organization, Victims Refuse Silence, Inc., a Florida corporation, directly related to her alleged experience as a victim of sexual abuse. Doc. 1 (Complaint), {§ 24-25. a. Reply: Plaintiff does not dispute this statement. 27. Undisputed Fact 27: The “goal” of Victims Refuse Silence “‘was, and continues to be, to help survivors surmount the shame, silence, and intimidation typically experienced by 15