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Case 18-2868, Document 281, 08/09/2019, 2628234, Page29 of 66 position allowed him to influence the press to publish her defamatory statement. A sampling of Gow’s testimony establishes just that: Q. Did Ms. Maxwell retain the services of you or your firm? A. Yes, she did. eK 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. eK Q. You can answer -- to the extent that anything you testify to is not protected by a privilege. A. Ms. Roberts first came to my attention on or around March 2011 when I was called into a meeting with Philip Barden and Ms. Maxwell at Devonshires law office, that she had made -- Ms. Giuffre had made extremely unpleasant allegations about Ms. Maxwell's private life. We were -- Acuity Reputation, my firm was called in to protect Ms. Maxwell's reputation, and to set the record straight. That was -- and that | work commenced on or around March of 2011. eK Does this document fairly depict pages from your -- from Acuity Reputation's website? A. It does. Q. Do you see where it says "We manage reputation and forge opinion through public relations, strategic communications and high level networking"? A. Ido. Q. Is that a true statement? A. Say it again. Sorry. Q. Is that a true statement? A. It is, yes. I wrote that statement. eK Q. Okay. Do you see where your website claims that your company has "excellent relationships with the media"? A. Ido. Q. Is that a true statement? 29