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Case 18-2868, Document 284, 08/09/2019, 2628244, Page12 of 38 Ex.K { 10. Mr. Gow’s surmise as to how the statement was “forwarded to him” and by whom does not controvert the sworn testimony of Mr. Barden himself. Again, without admissible evidence to the contrary, the facts must be deemed admitted. With regard to the number of media representatives to whom he sent the email, Mr. Gow testified it was between 6 and 30. Ex.G at 33-34. His further testimony, offered by Plaintiff, that he spoke to “‘over 30 journalists” does not contradict that statement. Nowhere does Plaintiff offer testimony that he read the statement to over 30 journalists. Instead, Mr. Gow acknowledged it was “very possible” that he had “ever read[] the statement to press or media over the phone,” not that he read it to “over 30 journalists.” Plaintiff's selective cutting and pasting undercuts her so called evidence that the facts in Paragraph 18 are “false,” and thus they ought be deemed admissible. 19. Undisputed Fact 19: Among the media representatives were Martin Robinson of the Daily Mail; P. Peachey of The Independent; Nick Sommerlad of The Mirror; David Brown of The Times; and Nick Always and Jo-Anne Pugh of the BBC; and David Mercer of the Press Association. These representatives were selected based on their request—after the joinder motion was filed—for a response from Ms. Maxwell to plaintiff's allegations in the motion. See, e.g., EXx.G, at 30:23-35:21 & Depo.Ex.3. a. Reply: While Plaintiff decries the second sentence as “false,” her cited evidence contradicts her conclusion. Mr. Gow testified that “‘any time there was an incoming query it was either dealt with on the telephone by referring them back to the two statements...or someone would email them the statement. So no one was left unanswered.” McCawley Decl., Ex.6 at 67. As his testimony makes clear, Mr. Gow sent 11

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Filename DocumentCloud_Epstein_Docs_p01863.png
File Size 282.3 KB
OCR Confidence 94.5%
Has Readable Text Yes
Text Length 1,884 characters
Indexed 2026-02-04 12:31:15.493724