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Case 18-2868, Document 281, 08/09/2019, 2628234, Page11 of 66 CVRA action could strike the “lurid details” of Ms. Giuffre’s allegations in the joinder motion, members of the media obtained copies of the motion. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT?’S FACTS See Ms. Giuffre’s Response to Point #7, above. DEFENDANT’S PURPORTED FACTS 18. At Mr. Barden’s direction, on January 3, 2015, Mr. Gow sent to numerous representatives of British media organizations an email containing “a quotable statement on behalf of Ms. Maxwell.” The email was sent to more than 6 and probably less than 30 media representatives. It was not sent to non-media representatives. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Defendant falsely claims that “[a]t Mr. Barden’s direction, on January 3, 2015, Mr. Gow sent to numerous representatives of British media organizations an email containing ‘a quotable statement on behalf of Ms. Maxwell.’” This is a blatant falsehood about the document that is at the heart of this litigation. Record evidence shows that Gow sent that email at Defendant’s direction, not at Mr. Barden’s direction. Indeed, on the evening before his deposition, Mr. Gow produced an email exchange he had with Defendant in which Defendant directs Mr. Gow to send the press statement. It is as follows: From: G Maxwell <GMax1@elimax.com> Date: Fri, 2 Jan 2015 20:14:53 +0000 To: Ross Gow<ross@acuityreputation.com> Ce: Philip Barden<philip.barden@devonshires.co.uk> Subject: FW: URGENT - this is the statement 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 Derschwitz is involved in having sexual relations with her, which he denies Ms Roberts claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory. 11