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Case 18-2868, Document 283, 08/09/2019, 2628241, Page131 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 64 1 Q. Okay. Have you ever communicated anything 2 regarding Ms. Guiffre's criminal allegations to the press 3 or the media? 4 A. As part of a wider conversation about her 5 unsavory allegations about Ms. Maxwell, it's possible 6 that I might have done, but I can't recall the detail, 7 I'm afraid. 8 Q. Do you -- do you remember discussing that with 9 The Guardian? 10 A. No, I don't. I'm not saying I didn't but I Ll can't recall. You have to bear in mind, if you'd be so 12 kind, that I've been speaking to over 30 journalists and 13 media outlets about this, and I can't recall every single 14 -- the detail of every single conversation. 15 Q. Earlier you testified with regard to Exhibit 2 16 that in the days following sending that email, you also 17 communicated with other press and media outlets. Do you 18 recall today any of the other press and media outlets you 19 communicated with, in addition to those listed at the top 20 of that email? 21 A. The Guardian, The Sun, from the top of my 22 memory, but in addition to -- in addition to emails there 23 would have been telephone calls and I'm -- there may not 24 be a transcript of those calls, these are emails inter 25 alia, others, and I can't recall every single email that 1 800 325 3376 DTI Court Reporting Solutions New York www.deposition.com 9:54: 9:54: 9:54: 9:54: 9:55: 9:55: 9:55: 9:55: