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Case 1:15-cv-07433-LAP Document 1331-19 Filed 01/05/24 Page 4 of 12 Significantly, Defendant attempts to blame the defamatory press release entirely on Barden. Giving false testimony at her deposition, in an evasive manner, Defendant said Barden was the one who actually released the defamatory statement, pretending that she had nothing to do with it at all: Q. Did you issue a statement to your press agent, Ross Gow in 2015, stating that Virginia Roberts' claims were, quote, obvious lies? 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. 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 Schultz Dec., Exhibit 3, Maxwell Depo. Tr. at 201:8-202:11. Because of this denial in her sworn testimony (which was plainly untrue), Ms. Giuffre sought to depose her press agent to establish that Defendant (not her attorney or anyone else) authorized the release of the defamatory statement. Months later, on the eve of his deposition, Ross Gow produced the “smoking gun” email in which Defendant explicitly “command[ed]” him to publish the defamatory statement. See Schultz Dec. at Exhibit 4, Defendant’s Email to Gow Authorizing Press Release. (As the Court is aware, Defendant defied this Court’s Order in her refusal to produce this email she sent Gow, despite it being responsive to multiple requests for production, and containing six court-ordered search terms.)