Giuffre_Maxwell_Batch7_p00219.png

20 Za 22 23 24 25 Case 1:15-cv-07433-LAP Document 1332-10 Filed 01/08/24 Page 22 of 64 21 H2G8GIUC To mitigate the damage caused by the plaintiff's salacious statements to the media, in the form of that joinder motion in the CVRA case, and the second purpose was to prevent further damage to Ms. Maxwell by issuing this quotable statement. Now, the quotable statement is unique, as I pointed out earlier, because it threatens to sue the very people to whom it is sent. And Mr. Barton says that that was intentional. This quotable statement was intended to be a cease and desist. If you republish this plaintiff's allegations in that CVRA joinder motion, you do so at your own legal peril. That was the message that Mr. Barton was delivering in that January 2015 statement. Mr. Barton also testifies -- and this is actually shown in the statement itself, January 2015 statement -- that he was building, in effect, a syllogism. The syllogism went something like this, Judge: Premise number one is that this woman has made false statements in the past, referring to the original allegations from as far back as 2011 and the Sharon Churcher articles. Premise number two was she is doing it again. These allegations, these new allegations in the CVRA joinder motion are different from, and more salacious than, and contradictory of the March 2011 statements that were made to the press, for example, the two Churcher articles attached as Exhibit A and B to our motion. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300