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Case 18-2868, Document 284, 08/09/2019, 2628244, Page20 of 38 Interrogatory No. 6, in connection with the media’s publication of portions of the January 2015 statement. Ex.J J 24; Ex.K {{ 2-3. a. Reply: Plaintiff's proffered evidence, testimony from Mr. Gow, fails to support her argument and fails to controvert the Barden Declaration as cited by the defendant. Nothing in the testimony establishes, as Plaintiff argues, that “Defendant hired Gow because his position allowed him to influence the press to publish her defamatory statement.” The testimony is irrelevant to the factual point. The Gow testimony at most relates to why Ms. Maxwell engaged Mr. Gow. It does not bear on the factual point, i.e., that Ms. Maxwell, Mr. Gow or Mr. Barden did not exercise any control or authority over the media in the media’s republication of portions of the statement. On this point plaintiff has failed to introduce any contrary evidence. Accordingly, the fact should be deemed admitted. 35. Undisputed Fact 35: Plaintiff’s defamation action against Ms. Maxwell. Eight years after Epstein’s guilty plea, plaintiff brought this action, repeating many of the allegations she made in her CVRA joinder motion. Doc. 1, 9. a. Reply: Plaintiff “agrees.” 36. Undisputed Fact 36: The complaint alleged that the January 2015 statement “contained the following deliberate falsehoods”: (a) That Giuffre’s sworn allegations “against Ghislaine Maxwell are untrue.” (b) That the allegations have been “shown to be untrue.” (c) That Giuffre’s “claims are obvious lies.” Doc. 1 {30 (boldface and underscoring omitted). (a) Reply: Plaintiff “agreed.” 19