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Case 18-2868, Document 283, 08/09/2019, 2628241, Page133 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 67 1 MR. DYER: Do you mean Exhibit 2? 9:59:58 2 MS. SCHULTZ: Yes. Exhibit 2. 0:00:00 3 THE WITNESS: To be clear, Exhibit 2 was the 0:00:02 4 base document. 0:00:03 5 MS. SCHULTZ: Uh-hmm. 0:00:05 6 THE WITNESS: In addition to the 2011 March 0:00:05 7 statement. Those were the two working documents that 0:00:10 8 were always referred to, both of which -- well, the first 0:00:15 9 one was in a public domain and was on record on the 0:00:17 10 Devonshires -- on -- with Devonshires name at the top on 0:00:21 11 PR Newswire which is a global delivery service. So that 0:00:24 12 was easily accessible by people. And the second one was 0:00:28 13 the -- further to the 2nd of January 2015. 0:00:31 L4 BY MS. SCHULTZ: 0:00:38 15 Q. To the extent you can recall or could estimate, 0:00:37 16 how many other emails do you believe you sent bearing 0:00:40 17 that statement that's in Exhibit 2? 0:00:43 18 A. I really can't remember but certainly more than 0:00:47 19 six and probably less than 30, somewhere in between. 0:00:48 20 Any time there was an incoming query 0:00:52 21 it was either dealt with on the telephone by referring 0:00:54 22 them back to the two statements of March 2011 and 0:00:57 23 January 2015 or someone would email them the 0:01:00 24 statement. So no one was left unanswered, broadly, is 0:01:06 25 the -- is where we were. But I can't remember every 0:01:09 DTI Court Reporting Solutions New York 1 800 325 3376 www.deposition.com