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Case 1:15-cv-07433-LAP Document 1332-3 Filed 01/08/24 Page 6 of 21 ° In this sense, the statement was very much intended as a cease and desist letter to the media-recipients, letting the media-recipients understand the seriousness with which Ms. Maxwell considered the publication of plaintiff's obviously false allegations and the legal indefensibility of their own conduct. Jd. at 4 17; e Consistent with those two purposes, Mr. Gow’s emails prefaced the statement with the following language: “Please find attached a quotable statement on behalf of Ms. Maxwell” (italics supplied). The statement was intended to be a single, one-time-only, comprehensive response—quoted in full, if it was to be used—to plaintiff's December 30, 2014, allegations that would give the media Ms. Maxwell’s response. Id. at 5 4 19; ° I directed that the statement indicate Ms. Maxwell “strongly denief{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.” Id. at 7 § 30. Lest there be any doubt as to the source of this information, Barden specifically added that the source was “entirely” his client — the Defendant: “The content of the statement was entirely based on information I acquired in connection with my role as counsel for Ms. Maxwell.” Id. at 7 § 30. Defendant then doubled down on the waiver by relying very specifically on these communications in her (currently-pending) summary judgment motion. Here again, some highlight will serve to illustrate the point (internal citations to Barden Declaration omitted and emphasis added): ° Consistent with Mr. Barden’s purposes for the statement, Mr. Gow’s emails prefaced the statement with the following language: “Please find attached a quotable statement on behalf of Ms. Maxwell” (emphasis supplied). Summary Judgment Motion at 25; ° After plaintiff filed the CVRA motion, some thirty reporters contacted Ms. Maxwell’s press representative, Mr. Gow, for Ms. Maxwell’s response. As Ms. Maxwell’s lawyer, Mr. Barden undertook that task. Relying on his knowledge of the 2011 articles publishing plaintiffs allegations and drawing on his experience and training as a lawyer, Mr. Barden crafted a response with the goal of discrediting plaintiff and what the statement called plaintiff's new” allegations. Summary Judgment Motion at 27; ° By January 2015 Ms. Maxwell had retained British Solicitor Philip Barden to represent and advise her in connection with plaintiffs publication in the British press of