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Case 18-2868, Document 283, 08/09/2019, 2628241, Page136 of 883 ROSS NEIL SUTHERLAND GOW 11/18/2016 Page 110 1 Q. Is it correct that public relations and 2 strategic communications are things that you personally 3 do as part of your professional activities? 4 A. I personally -- I'm involved in public 5 relations and strategic communications, yes. 6 Q. Is it correct that the media is the intended 7 recipient of this strategic communications. 8 A. It's -- the -- it's a larger ground than just 9 the media. There may be lobbyists, government think 10 tanks, focus groups, government departments. 11 Q. Would it be fair to say that the media is often L2 the intended recipient of strategic communications? 13 A. It is a frequent recipient. 14 Q. Referent recipient? 15 A. But not the sole recipient. 16 Q. Okay. Do you see where your website claims 17 that your company has "excellent relationships with the 18 media"? L9 A. I do. 20 Is that a true statement? 21 A. That is true, yeah. 22 MR. DYER: Except Mr. Syson. 23 THE WITNESS: Except Mr. Syson, sir. 24 MS. SCHULTZ: Of course. 25 THE WITNESS: And representatives of the Daily 1 800 325 3376 DTI Court Reporting Solutions New York www.deposition.com 124: 124: 124: 124: 124: 124: 124: 124: 124: 225: 225: 225: 225: 225: 225: 225: 225: 225: 225: 225: 225: 225: 225: 225: 225: