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Case 1:15-cv-07433-LAP Document 1330-17 Filed 01/05/24 Page 6 of 12 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. Q. I want to turn your attention to the document I just handed you which is Bates No. 001044, from you to Philip Barden and Ross Gow. It says in the first sentence, I'm out of my depth to understand defamation, other legal hazards and I don't want to end up in a lawsuit aimed at me from anyone, if I can help it. Apparently, even saying Virginia is a liar has hazards. You knew at the time you called Virginia a liar in early January of 2015 that that was something that would result in a lawsuit, is that correct’? . [have legal advice that I took. . But you knew in early January by making a statement calling Virginia a liar that you were subjecting yourself to a legal dispute with her? 2 QD > . I took legal advice as to what should be said and not be said and the legal advice that came from the United Kingdom was — > . Sorry. Le) . So is it correct without telling me what you talked to your lawyers about that you knew because this is dated January 10 that when you made this statement in early January, January 2 of 2015 you knew that calling Virginia a liar would subject you to a legal action, isn't that correct? A. All I can say is I asked a question and received legal advice. Likewise, all the communications between Mr. Gow and Ms. Maxwell pre-dating the statement issued by Mr. Gow on January 2, 2015 that form the basis of this suit were produced in advance of both of Ms. Maxwell’s depositions. See Menninger Decl., Ex. B, [GM_01036- 01044]. Any questioning concerning Ms. Maxwell’s involvement or input into the content of the single statement was available for exploration. Yet, Plaintiff either neglected to or decided not to question Ms. Maxwell about the majority of these documents at their own option, which cannot form the basis for reopening a deposition. Dash, 2015 WL 4257329, at *6 (refusing to reopen deposition where party neglected to or affirmatively opted not to inquire about information available at prior deposition).