  One of the recent no-go theorems on \Psi-epistemic interpretations of quantum
proves that there are no 'maximally epistemic' interpretations of quantum
theory. The proof utilises similar arrangements to Clifton's quantum
contextuality proof and has parallels to Harrigan and Rudolph's quantum
deficiency no-go theorem, itself based on the Kochen-Specker quantum
contextuality proof. This paper shows how the Kochen-Specker theorem can also
be turned into a no 'maximally epistemic' theorem, but of a more limited kind.
