Giuffre_Maxwell_Batch7_p00241.png

20 Za 22 23 24 25 Case 1:15-cv-07433-LAP Document 1332-10 Filed 01/08/24 Page 44 of 64 43 H2G8GIUC because I think that is an issue that they focused on tremendously, and I want to be very clear on that. First of all, Maxwell issued this press release, not her lawyer Barton. They can file as many self-serving declarations as they want, but the documents don't lie. If you look in your binder, your Honor, you will see the smoking gun e-mail. And I will tell you, we didn't get that e-mail from Maxwell. You will remember that we had to fight tooth and nail to get the deposition of Ross Gow, her press agent. We spent close to $100,000 getting all the way over to London, fighting in those courts, to get the deposition of her agent. They wouldn't produce him. And now they are submitting this affidavit on behalf of Barton. Your Honor, that document is critical, because what it shows very clearly is it was Maxwell who sent the press release to her press agent, Ross Gow, for publication. That press release goes out from Ross Gow, not from a lawyer. His Web site says he is a reputation manager. He is a press agent who issued a press release. This is not a cease and desist letter. This was a press release. In fact, a press release that said, "Please find the attached quotable statement by Ms. Maxwell." It's a press release telling the press, please quote these defamatory statements. They have admitted at least 30 different international press folks to defame my client in the international press. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300