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20 Za 22 23 24 25 Case 1:15-cv-07433-LAP Document 1332-10 Filed 01/08/24 Page 31 of 64 30 H2G8GIUC unquote, claims Mr. Barton is referring to. He just says claims. That is another area of indefiniteness and ambiguity, Judge. The Court doesn't know, the plaintiff doesn't know, and none of the reporters would know what is meant by the words allegations, original allegations, and claims. As Mr. Barton tells it, he is not trying to go blow by blow to try to rebut plaintiff's allegations. He is going after something bigger. He is going after the plaintiff's credibility. And that comes out in the January 2015 statement itself. It talks in generalities about how her claims have proven to be untrue. Well, how are they proven to be untrue? Well, you don't need Mr. Barton for this. Take a look at the March 2011 statement issued by Ms. Maxwell, and that also was drafted by Mr. Barton, but it doesn't really matter. The point is that in the March 2011 statement, and this answers your question with regard to that statement, Judge, the March 2011 statement, in the very first paragraph of the March 2011 statement, Ms. Maxwell says that the allegations by the plaintiff are "all entirely false." That is to be distinguished from the January 2015 statement when she does not say "all entirely false." She says simply that the allegations are false. Now, the distinction between the March 2011 statement and the January 2015 statement bear on this question of indefiniteness and ambiguity. It's certainly not indefinite SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300