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Case 1:15-cv-07433-LAP Document 1327-19 Filed 01/05/24 Page 7 of 21 documents containing the search terms and remarkably states that none — not a single one of the documents are responsive or relevant to the issues in this matter. Defendant’s representation is simply implausible, as a review of Defendant’s interactions with several of the important players in this case makes clear. i. Ross Gow The Court will recall that Ross Gow is Defendant’s London-based press agent, who shares Defendant’s attorney, Philip Barden, and who was connected with Defendant’s statements about Ms. Giuffre in both 2011 and 2015. Defendant admitted that she used Mr. Gow in 2011 in relation to Ms. Giuffre’s claims: Q. And then below there is an email from Philip Barden to you and cc'ing Ross Gow on January 11, 2015. Do you see that? A. Uh-huh. Q. It says, Dear Ghislaine, as you know I have been working behind the scenes and this article comes from that. It helps but doesn't answer the VR claims. I will get the criminal allegations out. This shows the MOS will print truth, not just a VR voice piece. We can only make the truth by making a statement. What did he mean when he said, I will get the criminal allegations out, what was he referring to? A. [have no idea. Maxwell Dep. Tr. at 405:13-406:7 (April 22, 2016) (McCawley Decl. at Exhibit 2). Defendant has admitted that she again used Mr. Gow in 2015 to issue a statement relating to Ms. Giuffre: Q. This is an email from you on January 10, 2015 to Philip Barden and Ross Gow. The statement you had before you earlier, that, if you can pull that in front of you, the one page press release that you gave. You might know from memory. Was the press release that you issued with the statement about Virginia issued in or around January 2, 2015? A. As best as I can recollect. Maxwell Dep. Tr. at 361:4-13 (April 22, 2016) (McCawley Decl. at Exhibit 2).