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Case 18-2868, Document 276, 08/09/2019, 2628224, Page32 of 77 Mr. Barden, who prepared the January 2015 statement, did not intend the January 2015 statement to be a traditional press release solely to disseminate information to the media. EXHIBIT K ¥ 15. So he did not request that Mr. Gow or any other public relations specialist prepare the statement. Id. Instead, Mr. Gow served only as Mr. Barden’s conduit to the media representatives who had requested a response to the joinder motion allegations and who Mr. Barden believed might republish those allegations. Jd. Mr. Barden intended the statement to mitigate the harm to Ms. Maxwell’s reputation from the press’s republication of plaintiffs false allegations. /d. { 16. He believed this could be accomplished by suggesting to the media that, among other things, they should subject plaintiffs allegations to inquiry and scrutiny. /d. For example, he noted that plaintiffs allegations changed dramatically over time, suggesting that they are “obvious lies” and therefore should not be “publicised as news.” Id. Mr. Barden also intended the January 2015 statement to be “a shot across the bow” of the media, which he believed had been unduly eager to publish plaintiffs allegations without conducting any inquiry of their own. Jd. § 17. So Mr. Barden stated repeatedly that plaintiff's allegations were “defamatory.” /d. In this sense, the statement was very much intended as a cease and desist letter to the media-recipients, letting the media-recipients understand the seriousness with which Ms. Maxwell considered the publication of plaintiff's obviously false allegations and the legal indefensibility of their own conduct. Jd. Consistent with Mr. Barden’s purposes for the statement, Mr. Gow’s emails prefaced the statement with the following language: “Please find attached a quotable statement on behalf of Ms Maxwell” (emphasis supplied). /d. § 19. The statement was intended to be a single, one- time-only, comprehensive response—quoted in full—to plaintiff's December 30, 2014, 25