DocumentCloud_Epstein_Docs_p01099.png

Case 18-2868, Document 283, 08/09/2019, 2628241, Page132 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 66 20 21 22 23 24 25 from John Swain? A. I believe I did. Q. That's all the questions I have about that document . A. Thank you. Q. Regarding communications you made after sending the email in Exhibit 2, I believe, and please correct me if I'm wrong, you testified that you received 30 or more calls that were -- that you would classify as press inquiries regarding Ms. Guiffre; is that correct? A. Yes. Q. Do you recall emailing the statement to other entities beyond what is on the list on Exhibit 2? A. Yes, I think I answered that previously. Yes, I mean there is a far -- I said inter alia, so there is a wider range of people that I would have emailed it to in response to incoming queries -- Q. Do you -- A But I -- Q. Sorry. A. I can't remember every single one. Q Do you recall ever reading the statement to the press or the media over the phone? A. It's very possible that I would have done so, yes. DTI Court Reporting Solutions New York 1 800 325 3376 www.deposition.com