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Case 18-2868, Document 278, 08/09/2019, 2628230, Page85 of 648 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ween eee eee eee eee eens xX VIRGINIA L. GIUFFRE, Plaintiff, : Vv. : 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. eceecccccnneeeeeeeeenceeeeeeeeeenueeeeeeeeed i" Declaration of Philip Barden I, Philip Barden, declare as follows: 1. Lama Solicitor of the Senior Courts of England & Wales based in London, England. 2. Iam submitting this Declaration in support of Ghislaine Maxwell’s motion for summary judgment in this action. 3. Iam not authorised to and do not waive Ms. Maxwell’s attorney-client privilege. 4. Ihave represented Ms. Maxwell since 2011 regarding the allegations made by Plaintiff Virginia Giuffre and as published in the United Kingdom. I continue to be retained in this regard. I am familiar generally with the subject matter of this action. 5. I first represented Ms. Maxwell in this matter over the weekend of 5™ and 6" March 2011, about the time when various UK national newspapers, in hard copy and on line, published numerous and provocative allegations made by the Plaintiff Virginia Giuffre against Ms. Maxwell. The articles by Sharon Churcher were among those published in this time frame. 6. Linstructed British press agent Ross Gow to assist me in representing Ms. Maxwell.