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Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 13 of 50 However, to make a good faith effort of a response, Ms. Giuffre compiled many examples of Defendant’s defamation, examples that were absent from Defendant’s brief, in contravention of Rule 37.1: Date Nature Publishing Entity Statement/URL January 2, 2015 Internet Ross Gow Jane Doe 3 is Virginia Roberts - so not a new individual. The allegations made by Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations are not new and have been fully responded to and shown to be untrue. Each time the story is re told it changes with new salacious details about public figures and world leaders and now: it is alleged by Ms. Roberts that Alan Dershowitz is involved in having sexual relations with her, which he denies. Ms. Roberts’s claims are obvious lies and should be treated as such and not publicized as news, as they are defamatory, Ghislaine Maxwell’s original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavoury nature, which have appeared in the British press and elsewhere and reserves her right to seek redress at the repetition of such old defamatory claims. January 3, 2015 Internet Telegraph http://www.telegraph.co.uk/news/uknews/theroyalfam ily/11323872/Prince-Andrew-denies-having-relations- with-sex-slave-girl.html January 4, 2015 Internet Express http://www.express.co.uk/news/world/550085/Ghislai ne-Maxwell-Jeffrey-Epstein-not-madam-paedophile- Florida-court-case-Prince-Andrew January 3, 2015 Internet Daily Mail http://www.dailymail.co.uk/news/article- 2895366/Prince-Andrew-lobbied-government-easy- Jeffrey-Epstein-Palace-denies-claims-royal-tried-use- influence-help-billionaire-paedophile-2008-police- probe.html January 3, 2015 Internet Huffington Post http://www. huffingtonpost.co.uk/2015/01/03/duk e-of-york-sex-abuse-claims_n_6409508.html January 4, 2015 Internet Jewish News Online http://www.jewishnews.co.uk/dershowitz-nothing- prince-andrews-sex-scandal/ January 2, 2015 Internet Bolton News http://www.theboltonnews.co.uk/news/na tional/11700192.Palace_denies_Andrew_sex _case_claim/ January 5, 2015 Internet/ Broadcast NY Daily News http:/www.nydailynews.com/news/world/alleged- madame-accused-supplying-prince-andrew-arti cle-1.2065505 7