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Case 1:15-cv-07433-LAP Document 1331-27 Filed 01/05/24 Page 5 of 11
judgment. On her third try, plaintiff makes no further headway. We address here each piece of
“documentary and testimonial evidence” plaintiff alleges supports her argument.
a. As plaintiff acknowledges, Ms. Maxwell’s testimony is completely consistent
with Mr. Barden’s testimony; “So my lawyer, Philip Barden|,] instructed Ross Gow to
issue a statement.” Mot. 4 (emphasis omitted).
b. Plaintiff argues Mr. Gow produced a “smoking gun” email chain in which
Ms. Maxwell personally directed him to distribute the January 2015 statement. Mot. 4.
The “smoking gun” is a dud. It too is consistent with—corroborates—Mr. Barden’s
testimony. The earlier email is from Ms. Maxwell to Mr. Gow with Mr. Barden copied on
the email. See Doc.638-4. There is no instruction in the email. It merely contains the
January 2015 statement. In the subject line is this text: “FW: URGENT - this is the
statement.” The “FW” is important—it is the abbreviation for “Forward,” indicating an
email has been forwarded by the sender, in this case Ms. Maxwell. The email does not
disclose who originally sent the email to Ms. Maxwell that she then forwarded to
Mr. Gow. The later, reply email—from Mr. Gow to Ms. Maxwell, copying Mr. Barden, is
notable. Its text reads: “OK G going with this, thanks Philip.” (Emphasis supplied.) This
suggests Mr. Barden was intimately involved with Mr. Gow’s action of sending the
January 2015 statement to journalists.” It also suggests (“going with this, thanks Philip”)
that, notwithstanding the absence of any direction in the earlier email from Ms. Maxwell,
Mr. Gow knew what to do, which itself suggests prior direction from someone.
*plaintiff asserts that Mr. Barden is “nowhere to be found on any of these communications” between
Ms. Maxwell and Mr. Gow. Mot. 3. That is incorrect. Mr. Barden was copied on both the email from Ms. Maxwell
to Mr. Gow and on the email from Mr. Gow to Ms. Maxwell. See Doc.638-4.
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Document Details
| Filename | Giuffre_Maxwell_Batch6_p00285.png |
| File Size | 315.5 KB |
| OCR Confidence | 94.5% |
| Has Readable Text | Yes |
| Text Length | 2,002 characters |
| Indexed | 2026-02-04 12:46:36.350122 |