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Case 18-2868, Document 287, 08/09/2019, 2628251, Page3 of 76 Ir. The Facts The facts have been set forth in Maxwell’s Memorandum of Law in Support of Maxwell’s Motion for Summary Judgment, Southern District of New York, Local Rule 56.1; Giuffre’s Statement of Contested Facts and Giuffre’s Undisputed Facts; and Maxwell’s Reply to Giuffre’s Statement of Contested Facts and Giuffre’s Undisputed Facts pursuant to Local Civil Rule 56.1. They are not in dispute except as noted below. 1. In early 2011, Giuffre, in two British tabloid interviews, made numerous false and defamatory allegations against Maxwell. In the articles, Giuffre made no direct allegations that Maxwell was involved in any improper conduct with Jeffrey Epstein (“Epstein”), who had pleaded guilty in 2007 to procuring a minor for prostitution. Nonetheless, Giuffre suggested that Maxwell worked with Epstein and may have known about the crime for which he was convicted. Giuffre has denied that the allegations she made against Maxwell were false and defamatory. She noted that she did give an interview to journalist, Sharon Churcher (“Churcher”), in which she described Maxwell’s role as someone