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Case 18-2868, Document 287, 08/09/2019, 2628251, Page74 of 76 that the Press Release was anything near an attorney’s statement; Barden was not even copied on the email. The pre-litigation privilege is intended to protect attorneys from defamations claims “so that those discharging a public function may speak freely to zealously represent their clients without fear of reprisal or financial hazard.” Id. at 18. Where the statement cannot be attributed to an attorney, there is no justification for protecting it by privilege. In addition, as this Court concluded in denying Maxwell’s motion to dismiss, “[t]here is no qualified privilege under New York law when such statements are spoken with malice, knowledge of their falsity, or reckless disregard for their truth.” Giuffre, 165 F. Supp. 3d at 155 (internal quotation marks and citation omitted). It is Giuffre’s contention that Maxwell knew the statements were false because she engaged in and facilitated the sexual abuse of Giuffre. Therefore, according to Giuffre, they were not made in good faith anticipation of litigation, and instead were made for the inappropriate purpose of “bully[ing],” “harass]ment],” and “intimid[ation].” See Front, 28 N.E.3d at 19 (2015). According to Giuffre, there is ample record evidence that Maxwell acted 74