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Case 1:15-cv-07433-LAP Document 1330-8 Filed 01/05/24 Page 5 of 10 content of that email, a communication with a key witness, nor did she have the opportunity to use it to cross some of Defendant’s evasive answers. Additionally, due to the late production, Ms. Giuffre did not have the opportunity to include these facts in her briefing related to her Motion to Enforce the Court’s Order and Direct Defendant to Answer Deposition Questions Filed under Seal (DE 315). a. Gow Deposition Testimony Defendant refused to give a straight answer regarding Mr. Gow at her first deposition, making a line of questions related to the lately-produced email communication important and non-redundant. For example, when asked about Mr. Gow, Defendant gave evasive, and non- responsive answers: Q. Did you issue a statement to your press agent, Ross Gow in 2015, stating that Virginia Roberts' claims were, quote, obvious lies? Q. You can answer. A. You need to reask me the question. Q. Sure. Did you issue a press statement through your press agent, Ross Gow, in January of 2015, stating that Virginia Roberts' claims were, quote, obvious lies? A. Can you ask it a different way, please? Q. I will ask it again and you can listen carefully. Did you issue a press statement through your press agent, Ross Gow, in January of 2015, where you stated that Virginia Roberts' claims were, quote, obvious lies? A. So my lawyer, Philip Barden instructed Ross Gow to issue a statement. See McCawley Decl. at Sealed Composite Exhibit 2, Maxwell Depo. Tr. at 201:17-202:11. Q. Are you saying that it's an obvious lie that Jeffrey Epstein engaged in sexual conduct with Virginia while Virginia was underage? A. Again, I'm telling you, first of all, it was a statement that was issued by my lawyer and -- through my lawyer to Ross Gow. Q. Lunderstand that. I'm asking you, are you saying that it's an obvious lie that Jeffrey Epstein engaged in sexual conduct with Virginia while Virginia was underage. Is that a lie? Q. You can answer. A, So I cannot testify to what Ross Gow and Philip Barden decided to put -- | can testify to what Virginia's obvious lies are as regards to me. I cannot make representations about all the many lies she may or may not have told about Jeffrey.