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Case 18-2868, Document 283, 08/09/2019, 2628241, Page124 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 15 1 Q. No, I'm not, I'm not. Please -- I am 2 withdrawing that question. 3 MR. DYER: Alright. 4 MS. SCHULTZ: I am withdrawing that question. 5 BY MS. SCHULTZ: 6 Q. You testified previously that you were retained 7 to handle matters relating to Virginia Roberts Guiffre; 8 is that correct? 9 A. Correct. 10 Q. Okay. So you are aware of who Ms. Roberts ll Guiffre is? 12 A. I am. 13 Q. Okay. Please tell me everything you know about 14 Virginia Roberts Guiffre, please. 15 MS. MENNINGER: Objection, foundation, form, 16 and may call for privileged materials. L7 BY MS. SCHULTZ: 18 Q. You can answer -- to the extent that anything 19 you testify to is not protected by a privilege. 20 A. Ms. Roberts first came to my attention on or 21 around March 2011 when I was called into a meeting with 22 Philip Barden and Ms. Maxwell at Devonshires law office, 23 that she had made -- Ms. Guiffre had made extremely 24 unpleasant allegations about Ms. Maxwell's private life. 25 We were -- Acuity Reputation, my firm 1 800 325 3376 DTI Court Reporting Solutions New York www.deposition.com 336: 336: 336: 336: 336: 336: 336: 336: 336: 336: 336: 336: 336: 336: 336: 336: 336: 336: 336: 336: 37: 37: 37: 37: 337: