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20 Za 22 23 24 25 Case 1:15-cv-07433-LAP Document 1332-10 Filed 01/08/24 Page 38 of 64 37 H2G8GIUC didn't make any sense to issue to the general public because he is talking about threatening to sue the media. So he sends it to the reporters, the reporters who had contacted Mr. Gow and asked for a response from Ms. Maxwell. You want a response? I will give you a response. Here is the response. The response is this woman is telling falsehoods. Her original allegation had proven to be false. She is doing it again. This time they are more salacious, yes. The claims are obvious lies. If you're not careful about republishing, we will sue you. That's the message. So, Judge, the New York Constitution would require that the jury be instructed, if it gets that far, that this has to be looked at, not as a member of the general public, the January 2015 statement must be viewed from the viewpoint of these journalists who are the recipients, the exclusive recipients of the 2015 statement. The last argument that we made I can be fairly short with, Judge. This is the argument that discusses the plaintiff's heavy burden. Plaintiff has to prove two things by clear and convincing evidence. One is it has to prove falsity of the three sentences that are the subject of this lawsuit: The allegations are false, the original allegations have proven to be false, and the claims are obvious lies. By the way, on the "obvious lies" question, Judge, just to step back for a second, on the question of opinion, I SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300