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Case 18-2868, Document 281, 08/09/2019, 2628234, Page16 of 66 21. Mr. Barden, who prepared the January 2015 statement, did not intend it as a traditional press release solely to disseminate information to the media. So he intentionally did not pass it through a public relations firm, such as Mr. Gow’s firm, Acuity Reputation. MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS Defendant states: “Mr. Barden, who prepared the statement, did not intend it as a traditional press release solely to dissemination information to the media.” Ms. Giuffre contests this statement, and all statements regarding Mr. Barden’s beliefs and purposes, and the like. Further, as stated in detail in Ms. Giuffre’s Opposition Defendant’s Motion for Summary Judgment, this Court should not even consider the Barden Declaration. Additionally, there is absolutely no record evidence of Barden’s intent and the Court should not consider it. The next sentence states, “‘So he intentionally did not pass it [the press release] through a public relations firm, such as Mr. Gow’s firm, Acuity Reputation.” Again, there is zero record evidence to support any assertion of Barden’s intent. To the extent that this sentence claims that Barden did not give the statement to Gow, Ms. Giuffre does not dispute it; as described above, Defendant gave the statement to Gow with instructions to publish it. See McCawley Dec. at Exhibit 48, RG(UK)_000009, imaged in full at paragraph 81, supra. To the extent that this sentence claims that the statement did not pass “through a public relations firm, such as Mr. Gow’s firm, Acuity Reputation,” Ms. Giuffre disputes that statement. Record documentary evidence and testimony establish that this statement was disseminated through a public relations firm, namely, Ross Gow’s firm, Acuity Reputation. See McCawley Dec. at Exhibit 6, Gow Dep. Tr. at 109:4-6 (“Q. Approximately how long have you been providing such services? A. Acuity was set up in 2010.”). DEFENDANT’S PURPORTED FACTS 16