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Case 18-2868, Document 281, 08/09/2019, 2628234, Page22 of 66 Ms. Giuffre disputes that any part of Defendant’s press release is “consistent with those two [of Barden’s] purposes.” Indeed, Ms. Giuffre disputes this and any statement relating to Barden’s “purposes,” as explained above. Next, Ms. Giuffre disputes that, “The statement was intended to be a single, one-time- only, comprehensive response — quoted in full — to Ms. Giuffre’s December 30, 2014, allegations that would give the media Ms. Maxwell’s response.” First, Ms. Giuffre disputes this and any statement relating to Barden’s “intent” as explained above. Second, Ms. Giuffre disputes that anyone intended the press release to be a one-time-only, comprehensive response. The record evidence says otherwise: Gow repeatedly issued this statement via email and over the phone for months on end. Next, Defendant states, “The purpose of the prefatory statement was to inform the media- recipients of this intent.” First, Ms. Giuffre disputes this and any statement relating to Barden’s purpose as explained above. Second, Ms. Giuffre disputes that the press release was to inform the media of anything. Defendant issued a press release, instructed them to publish it (by telling them it was “quotable”), see McCawley Dec. at Exhibit 48, RG(UK)_000009 (supra), and hired a press agent to feed it to the press: Q. Did Ms. Maxwell retain the services of you or your firm? A. Yes, she did. RK Q. Is it your belief that that agreement was in effect on January 2nd, 2015? A. Yes. Q. Do you recall the terms of that agreement? A. Well, it was a re-establishment of an existing agreement so if we go back to the original agreement, it was to provide public relations services to Ms. Maxwell in the matter of Giuffre and her activities. 22