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Case 1:15-cv-07433-LAP Document 1331-22 Filed 01/05/24 Page 8 of 9 25. It is my understanding that some of the media-recipients of the January 2015 statement did not publish any part of the statement. I am unaware of any media-recipient publishing the statement in full. 26. The issuance of the statement fully complied with my ethical obligations as a lawyer. Indeed it was duty in representing my client’s interests to ensure that a denial was immediately issued. I would have been remiss if I had sat back and not issued a denial, and the press had published that Ms. Maxwell had not responded to enquiries and had not denied the new allegations; the public might have taken the silence as an admission there was some truth in the allegations. 27. The content of the statement was entirely based on information I acquired in connection with my role as counsel for Ms. Maxwell. 28. At the time I directed the issuance of the statement, I was contemplating litigation against the press-recipients as an additional means to mitigate and prevent harm to Ms. Maxwell. Whilst the limitation period for a pure defamation claim has now expired, claims are still being considered for example for publishing a deliberate falsehood, conspiracy to inure and other tortious acts. 29. In any such UK defamation, or other related, action Ms. Giuffre would be a defendant or a witness. 30. Idirected that the statement indicate Ms. Maxwell “strongly denie[d] the allegations of an unsavoury nature,” declare the allegations to be false, give the press-recipients notice that the publications of the allegations “are defamatory,” and inform them that Ms. Maxwell was “reserv[ing] her right to seek redress.”