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Case 18-2868, Document 283, 08/09/2019, 2628241, Page417 of 883 37. However, I was not interested in news articles that just discussed the story in general or other aspects of the story. Also, I was not interested in those articles where Ms. Maxwell or those acting on her behalf, such as Mr. Gow, would just generally deny the allegations in the complaint'®. I was specifically interested in only those articles that referenced directly or quoted the statements made against Ms. Giuffre in the 2 January 2015 email message from Mr. Gow, Ms. Maxwell’s subsequent confirmation of the statements, or similar statements as those in the message from Mr. Gow. Naturally, this narrow focus is a smaller subset of news articles than are the articles addressing the overall story. 38. To isolate these articles of interest, I generated a series of 10 queries!” that specifically targeted news articles from the case that addressed the statements made against Ms. Maxwell (e.g., Ghislaine Maxwell obvious lies) to retrieve a set of articles that directly related to the statements made against Ms. Giuffre'*. I employed a modified snowball technique’, starting with one seed query, adding and modifying terms, until I was not retrieving new results. I also located some articles via navigating from the set of retrieved articles. 39, I set the search range date from 2 January 2015 onward, so articles prior to that date were not included in the search results. For each article used in my analysis, I also verified the date that the article was published to ensure it was published on or after 2 January 2015 and that the articles directly referenced in some way the statements made against Ms. Giuffre. 40. An example of a search engine results page in response to one of these queries is shown in Figure 3. '© Complaint, VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. CASE NO. 1:15-cv-07433. '’ Ghislaine Maxwell obvious lies, Ghislaine Maxwell Roberts obvious lies cnn, Ghislaine Maxwell Virginia Roberts, Giuffre Maxwell obvious lies, new york daily news alleged madam andrews, Prince Andrew Maxwell Roberts, Prince Andrew obvious lies, prince andrew's sex slave scandal who is maxwell, Ross Gow obvious lies, sex slave obvious lies. '8 Tn addition to the queries, I located some articles via direction navigation. !° https://en.wikipedia.org/wiki/Snowball_sampling 16