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20 Za 22 23 24 25 Case 1:15-cv-07433-LAP Document 1332-10 Filed 01/08/24 Page 59 of 64 58 H2G8GIUC Well, that's not true, Judge. That sentence from Mr. Gow tells us two things. One is that this is a statement written on behalf of Ms. Maxwell. This is not Ms. Maxwell's statement per se. It is written on behalf, by her agent. Now, the reporters may very well have thought that Mr. Gow prepared the statement, but it doesn't really matter because we have Mr. Barton's declaration saying that, I prepared the statement. But with regard to the issue of republication, Judge, it says, here is a quotable statement. It doesn't say, as Ms. McCawley recharacterizes it, please publish the statement. Actually, you won't see those words in that January 2015 statement. It doesn't say, please publish this statement. It says, here is a statement. And Ms. McCawley wants to put all of her eggs into the question whether this is a press release or whether it's not a press release. Judge, that seems like an irrelevant road to go down to try to characterize something as a press release or as not a press release. How about we look at it this way? It is a statement that was issued to 6 to 30 media. We should look at it that way because that's what the undisputed facts are. It wasn't issued to anyone else. What is also true is that the press were free to do with that statement as they wished because we, Ms. Maxwell and SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300