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Case 1:15-cv-07433-LAP Document 1331-22 Filed 01/05/24 Page 3 of 9 7. Icaused to be prepared a statement to respond to the articles that appeared in the British Press over the weekend—March 5 and 6, 2011, and thereafter. I directed Mr. Gow to distribute the statements to various media outlets that had published articles. 8. On December 30, 2014, Ms. Giuffre made numerous salacious and improper allegations against Ms. Maxwell in a joinder motion publicly filed in a civil case involving Jeffrey Epstein. Shortly afterward, the British media gained access to the motion and began inquiring about Ms. Maxwell’s response. 9. Icontinued to represent Ms. Maxwell at that time and I coordinated the response to the media. I again instructed Mr. Gow to assist me. 10. In liaison with Mr. Gow and my client, on January 2, 2015, I prepared a further statement denying the allegations, and I instructed Mr. Gow to transmit it via email to members of the British media who had made inquiry about plaintiffs allegations about Ms. Maxwell. Attached as Exhibit Al is an email containing a true and correct copy of this statement. The statement was issued on my authority. Although it is possible others suggested or contributed content, I prepared the vast majority of the statement and ultimately approved and adopted all of the statement as my work. 11. As is evident from the timing and the typographical errors in the statement, I prepared the statement in haste. I was not in the office on an January 2015 as it was the Friday immediately after New Years day which is a public holiday. Most people took 2"4 January off and many business closed that day. I don’t now recall where I was that day but I was hard to reach and that indicates I was out with my family. I therefore would have prepared the statement in a hurry. I recall that I wanted to get a statement out as a matter of urgency. 12. [recall that immediately after Ms. Giuffre’s motion was filed, media representatives began contacting Mr. Gow and requesting Ms. Maxwell’s response to Ms. Giuffre’s allegations