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Case 18-2868, Document 287, 08/09/2019, 2628251, Page25 of 76 23. Barden intended the January 2015 statement to be “a shot across the bow” of the media, which he believed had been unduly eager to publish Giuffre’s allegations without conducting any inquiry of their own. Accordingly, in the statement he repeatedly noted that Giuffre’s allegations were “defamatory.” In this sense, the statement was intended as a cease and desist letter to the media-recipients, letting the media-recipients understand the seriousness with which Maxwell considered the publication of Giuffre’s obviously false allegations and the legal indefensibility of their own conduct. Giuffre has denied this statement and the statement that Barden repeatedly noted that Giuffre’s allegations were “defamatory” as he did not “note” anything in the statement, nor does Maxwell cite to any record evidence that he did. Giuffre further denies the sentence, “In this sense, the statement was intended as a cease and desist letter to the media-recipients, letting the media-recipients understand the seriousness with which Maxwell considered the publication of Giuffre’s obviously false allegations and the legal " indefensibility of their own conduct,” as there is no record 25