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Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 362 of 465 Page 361 G Maxwell - Confidential (Maxwell Exhibit 17, email, marked for identification.) Q. This is an email from you on January 10, 2015 to Philip Barden and Ross Gow. The statement you had before you earlier, that, if you can pull that in front of you, the one page press release that you gave. You might know from memory. Was the press release that you issued with the statement about Virginia issued in or around January 2, 2015? A. As best as I can recollect. Q. I want to turn your attention to the document I just handed you which is Bates No. 001044, from you to Philip Barden and Ross Gow. It says in the first sentence, I'm out of my depth to understand defamation, other legal hazards and I don't want to end up in a lawsuit aimed at me from anyone, if I can help it. Apparently, even saying Virginia is a liar has hazards. You knew at the time you called Virginia a liar in early January of 2015 that that was something that would result ina MAGNA® LEGAL SERVICES