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Case 18-2868, Document 284, 08/09/2019, 2628244, Page34 of 38 Dershowitz. After plaintiff publicly alleged Mr. Dershowitz of sexual misconduct, Mr. Dershowitz vigorously defended himself in the media. He called plaintiff a liar and accused her lawyers of unethical conduct. In response, attorneys Edwards and Cassell sued Dershowitz who counterclaimed. This litigation, in turn, caused additional media attention by national and international media organizations. Doc. 363 at 363-1 through 363-14. a. Reply: Plaintiff offers no contrary facts and so they should be deemed admitted. 54. Undisputed Fact 54: Plaintiff formed non-profit Victims Refuse Silence to attract publicity and speak out on a public controversy. In 2014, plaintiff, with the assistance of the same counsel, formed a non-profit organization, Victims Refuse Silence. According to plaintiff, the purpose of the organization is to promote plaintiffs professed cause against sex slavery. The stated goal of her organization is to help survivors surmount the shame, silence, and intimidation typically experienced by victims of sexual abuse. Ex.LL. Plaintiff attempts to promote Victims Refuse Silence at every opportunity. Ex.MM at 17-18. For example, plaintiff participated in an interview in New York with ABC to promote the charity and to get her mission out to the public. Jd. at 28. a. Reply: Plaintiff offers no contrary evidence and the facts should be deemed admitted. Il. The Court should strike plaintiff’s statement of “undisputed facts.” The summary-judgment procedure is well established. When the summary-judgment non- movant bears the burden of proof at trial, as in the case at bar, the movant may show a prima facie entitlement to summary judgment in one of two ways: (1) the movant may point to evidence that negates the non-movant’s claims, or (2) the movant may identify those portions of its opponent’s evidence that demonstrate the absence of a genuine issue of material fact. 33