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Case 1:15-cv-07433-LAP Document 1330-17 Filed 01/05/24 Page 5 of 12 of British law. This is evidenced by the deposition testimony cited by Plaintiff (McCawley Decl., Ex. 2), as well as multiple additional pages of testimony that Plaintiff conveniently ignores. Ms. Maxwell clearly testified on this issue during her deposition (Menninger Decl., Ex. A at 272-274): Q. I provided you with and I'm sorry, I don't know all the numbers, but the statement that was issued by Ross Gow that should be a single page still in your stack 4 of exhibits there. MR. PAGLIUCA: Exhibit 10. Q. Did you authorize Ross Gow to issue that statement on your behalf in January of 2015? A. Lalready testified that that was done by my lawyers. Q. So did you authorize your lawyers to issue a statement on your behalf through Ross Gow in January of 2015? A. It was determined that I had to make a statement in the United Kingdom because of the appalling lies and I just thought of some new ones. Virginia's statement that I celebrated her 16 birthday with her. We can all agree that that's entirely impossible. I didn't meet her until she was 17 and other lies she perpetrated that she had a diary and we all know is a complete fake. That's not a diary. It was just a book she was writing that you helped sell to the press, as if it was a diary, when it was just a story that she is writing of fiction, fictional story for money. Q. How did you arrive at the words that were put in that statement? MR. PAGLIUCA: I'm going to object and instruct you to the extent this calls for any privileged communications between yourself and Mr. Barden or another lawyer representing you, we're asserting privilege. If you can answer that without that, feel free to answer. Q. So what your counsel is saying, and I will exclude any privileged communications you had with your lawyers. The question is, how did you arrive at the words that were put in that statement, if you can tell me without disclosing privileged communications? A. I'm not sure that I can. She was questioned for a third time on the same subject, again answering fully to all non- privileged information (Menninger Decl., Ex. A at 360-363). I will mark this as Maxwell 17.