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Extracted Text (OCR)
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
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Extracted Information
Dates
Document Details
| 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 |