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Case 1:15-cv-07433-LAP Document 1330-17 Filed 01/05/24 Page 4 of 12 The Motion is untimely and no special circumstance exists, nor have any been claimed, requiring denial of the motion. B. November 2015 Communication from Mr. Gow Concerning a Press Inquiry is Cumulative and Duplicative of Prior Discovery and Irrelevant to the Claimed Questions Plaintiffs claim regarding the relevance of the Gow email is perplexing. It is a single line email from Gow to Ms. Maxwell to which Ms. Maxwell never responded. Plaintiff correctly points out that Ms. Maxwell’s response is not included precisely because she did not respond. The email does not, as Plaintiff suggests, demonstrate that Ms. Maxwell was “in fact, involved in, and consulted about, what her press agent says on her behalf.” Rather, it shows she did not respond to an inquiry for comment. Plaintiff's Motion itself proves that Ms. Maxwell has already fully submitted to numerous discovery requests concerning whether she was “involved in, and consulted about” press communications issued by Mr. Gow, including Mr. Gow’s January 2, 2015 email to the press that forms the basis of this lawsuit. Indeed, the question has been asked and answered in every conceivable form of discovery under the Federal Rules. She has answered a specific Request for Admissions on the issue, stating: Maxwell admits that she has worked with Mr. Gow on occasion for several years and that she has corresponded with Mr. Gow regarding communications to members of the British press to reserve her right to seek redress for their repetition of defamatory statements about Ms. Maxwell. See McCawley Decl., Ex. 3, Defendant’s Responses to Plaintiff's Requests for Admission at 3. Likewise, Plaintiff extensively questioned Ms. Maxwell in her depositions about her involvement and communications with Mr. Gow regarding press inquiries, all of which makes clear that the alleged “defamatory” statement at issue was composed by Mr. Gow and Ms. Maxwell’s counsel Philip Barden and issued at the advice of counsel based on the requirements