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Case 1:15-cv-07433-LAP Document 1328-35 Filed 01/05/24 Page 8 of 10 independent reports of Plaintiff's false allegations of sexual assault and sent that information to Ms. Maxwell. There is nothing in Mr. Gow’s email then or afterwards which suggests he or Ms. Maxwell or anyone else they know “leaked” the story. Indeed, there is nothing to suggest that Ms. Maxwell had access to Plaintiff's police reports in February 2015. The police reports were obtained, by Plaintiff's admission, in April 2016. This is pure unsupported speculation and slander on the part of Plaintiff's counsel, ironically, the very people who misrepresented to the press the contents of the police reports and hid from production all of the other instances of Plaintiff's contact with law enforcement. ARGUMENT None of these factual assertions bear on the issue before the Court -- whether Plaintiffs publicly available criminal files should be deemed “confidential” under the Protective Order. None of the witnesses has anything to do with Plaintiff's false claims of sexual assault as a child, nor her domestic violence. Indeed, in what is an almost daily occurrence in this case, Plaintiff has selectively misquoted portions of deposition transcript testimony in an effort to mislead the Court into believing there is evidence of Ms. Maxwell’s guilt, a topic in the exclusive province of the jury, so as to improperly influence the Court’s discovery rulings. Ms. Maxwell cannot stand idly by while Plaintiff misrepresents to the Court and says, for example, that she confessed to participating in threesomes with “girls.” Reply at 4. No such admission occurred. It is a violation of candor to the Court to claim otherwise. Likewise, Detective Recarey never concluded in his investigation that Ms. Maxwell “procured underage girls for Epstein.” In fact, quite the opposite, Detective Recarey found no evidence that Ms. Maxwell ever even met any of the underage girls he interviewed.