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Case 18-2868, Document 283, 08/09/2019, 2628241, Page125 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 16 1 was called in to protect Ms. Maxwell's reputation, and 8:37:29 2 to set the record straight. That was -- and that work 8:37:33 3 commenced on or around March of 2011. 8:37:42 4 Q. What do you mean by "set the record straight"? 8:37:46 5 A. Ms. Guiffre's allegations about Ms. Maxwell 8:37:51 6 were, we believe, and to this day continue to believe, 8:37:55 7 untrue, defamatory, and fantastical. And with 8:37:58 8 Devonshires' lawyers, we set about putting out -- 8:38:09 9 crafting a statement which would put Ms. Maxwell's point 8:38:15 10 of view across that Ms. Guiffre's allegations were untrue 8:38:19 Ll and, frankly, abhorrent. 8:38:25 12 Q. What advice did you give Miss Maxwell as part 8:38:28 13 of your retention? 8:38:31 14 A. It is standard procedure in cases where it's 8:38:32 15 understood that a party may be defaming one's client that 8:38:36 16 one puts out a statement correcting those allegations and 8:38:42 17 providing a clearer picture of where the truth lies. So 8:38:46 18 it was very much our counsel that Ms. Maxwell put out a 8:38:49 19 statement, vehemently denying the allegations. 8:38:55 20 Q. When you testified that Ms. Guiffre, I'm going 8:38:59 21 to refer to her by just her married name, came to your 8:39:03 22 attention at that March 2011 meeting at Devonshires with 8:39:06 23 Mr. Barden and Ms. Maxwell, correct, and you learned 8:39:12 24 about her at that meeting; is that correct? 8:39:16 25 A. Correct. 8:39:18 DTI Court Reporting Solutions New York 1 800 325 3376 www.deposition.com