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Case 18-2868, Document 281, 08/09/2019, 2628234, Page12 of 66 Chronologically, this email comes at the end of various other email exchanges between Defendant and Gow that discuss issuing a press release. The subject line of this email that Defendant wrote to Gow states “URGENT -— this is the statement,” thereby instructing Gow to release this statement to the press. Shortly after Defendant sent this email to Gow directing him to release the statement, Gow distributed the statement to multiple media outlets. Neither Defendant nor Gow have produced any email in which Barden directed Gow to issue this press release (nor can they). Despite sending it herself, and despite it being responsive to six court-ordered search terms, Defendant failed to produce this email. Her press agent, Gow, produced this the evening before his deposition on November 17, 2016. At the deposition, Mr. Gow authenticated this email and confirmed that Defendant authorized the statement: Q. When you sent that email were you acting pursuant to Ms. Maxwell's retention of your services? A. Yes, I was. eK (Exhibit 9 was marked for identification.) Q. This also appears to be an email chain with you and Ms. Maxwell; is that correct? A. It does appear to be so. Q. Did you send the top email of the chain that says "Okay, G, going with this"? A. 1 did. Q. And did you receive from Ms. Maxwell, the bottom email of that chain? A. [believe so. Well, I believe -- yes, yeah, it was forwarded from Ms. Maxwell, yes. MR. DYER: Sorry, I don't quite understand that answer. THE WITNESS: I misspoke that. I did receive it from Ms. Maxwell. MR. DYER: Okay. Q. The subject line does have “FW” which to me indicates it’s a forward. Do you know where the rest of this email chain is? A. My understanding of this is: It was a holiday in the UK, but Mr. Barden was not necessarily accessible at some point in time, so this had been sent to him originally by Ms. Maxwell, and because he was unavailable, she forwarded it to me for immediate action. I therefore respond, “Okay, Ghislaine, I’1l go with this.” It is my understanding that this is the agreed statement because the subject of the second one is “Urgent, this is the statement” so I take that as an instruction to send it out, as a positive command: “This is the statement.” 12