EXHIBIT Case Document Filed Page of CONFIDENTIAL Case Document Filed Page of From Sent To gmaxl ellmax.com Saturday January AM Philip Barden Ross Gow I am out of my depth to understanding defamation and other legal hazards and dont want to end up in a law suit aimed at me from anyone if I can help it Apparently even saying Virginia is a lier has hazard I have never been in a suit criminal or civil and want it to stay that way The US lawyers for the Jane Does are filling additional discovery motions and if I speak I open my self to being part of discovery apparently I am trying to stay out of litigation and not have to employ lawyers for years as I get lost in US legal nightmare I stand no legal risk currently on these old charges and civil suits against Jeffrey We need to consult with US lawyers on any statement I make and the complaints too Perhaps we make a statement of the legal risk of saying anything for potential defamation or something that prevents a full and frank detailed rebuttal the press not being the place for that Regardless Philip plse call jeffrey lawyer and see what you can under stand from him and pehaps craft something in conjunction with him Either way I think you need to speak to him to understand my risk so you can help me understand it too may cooks in the kitchen and I cant make good decisions Plse reach out to him today I have already suffered such a terrible and painful loss over the last few days that I cant even see what life after press hell even looks like statements that dont address all just lead to more questions what is my relationship to clinton Andrew on and on Lets rest till monday I need head space THE TERRAMAR PROJECT FACEBOOK TWITTER PINTEREST INST AGRAM PLEDGE THE DAILY CATCH PRIVILEGED CONFIDENTIAL Case Document Filed Page of Pl NTEREST http pinterest.com/terra ma rpro ject INSTAGRAM http://instagram.com/theterramarproject PLEDGE http://w.theterramarproject.org/pledge THE DAILY CATCH http://theterramarproject.org/thedailycatch From Philip Barden Date Friday January at PM To Ross Gow Cc gmax Subject Re The Times Ghislaine Maxwell Agreed We agreed to release a statement We should support our friends and deny the allegations as Dershowitz urges and Prince Andrew has We run the real risk of guilt by si ence and that is likely to feed false claims and false suits as we saw with the BBC I advised the soldiers in Bloody Sunday not to give interviews so I am cautious and this is the time to speak I can say no more I hope our advice is followed Philip Sent from my iPhone On Jan at Ross Gow wrote Ghislaine I believe the next 18hrs is the best chance we have to leverage some transparency advantage on this MoS first then Sunday Times Otherwise we lose any chance of ownership of the narrative Please give it some serious thought Dershowitz is out on Monday with a big push in The Times and we run the risk of looking less than gripped best On January at Philip Barden I am heading home now and will call when get there Lets not waste this moment please PR IVILEGED GM CONFIDENTIAL Case Document Filed Page of Sent from my iPhone On Jan at Ross Gow Ghislainr further reason for us to put our side of the story out best Ross Forwarded message Date January at Subject The Times Ghislaine Maxwell To Ross Gow Hi Ross Do keep in touch I think were running a piece written by Professor Dershowitz on Monday If Miss Maxwell wants to make a comment do let me know All the best David Brown Reporter The Times Please consider the environment before printing this e-mail Newsworks bring i ng advertisers and newsbrands together w.newsworks.org uk http://w newsworks.org uk http://w.newsworks.org uk http://w news works.org This e-mail and any attachments are confidential may be IVIL EG ED GM_ CONFIDENTIAL Case Document Filed Page of legally privileged and are the property of News Corp UK Ireland Limited on whose systems they were generated News Corp UK Ireland Limited is the holding company for the News UK group i registered in England Wales under number has its registered office at London Bridge Street London SEl 9GF and is registered with VAT number GB If you have received this e-mail in error please notify the sender immediately and do not use distribute store or copy it in any way Statements or opinions in this e-mail or any attachment are those of the author and are not necessarily agreed or authorised by News Corp UK Ireland Limited or any member of its group News Corp UK Ireland Limited may monitor outgoing or incoming emails as permitted by law It accepts no liability for viruses introduced by this e-mail or attachments News Corp UK Ireland Limited and its titles are committed to abiding by IPSOs regulations and the Editors Code of Practice that IPSO enforces Ross Gow Managing Partner ACUITY Reputation Berkeley Square London WlJ 6HE w.acuityreputation.com http://w.acuityreputation com http://w acuityreputation.com http://w ww acuityreputation.com The information contained in this e-mail and any attachments is conf i dential and may be privileged or otherwise protected from disclosure It is intended solely for the attention and use of the named addressee If you are not the intended recipient dissemination copying or use of this e-mail and any attachments in whole or in part is prohibited If you have received the e-mail in error please notify the sender and delete the PRIVIL M_ CONFIDENTIAL Case Document Filed Page of e-mail and any attachments from your computer system Whilst any attachments may have been checked for viruses you should rely on your own virus checker and procedures No responsibility is accepted by ACUITY Reputation Limited for loss or damage arising from the receipt or use of this e-mail This email is intended for the addressee named within only It may contain legally privileged or confidential information If you are not the named individual you should not read this email and if you do so you must not under any 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uityreputation.com http://w ww.acuityreputation.com The information contained in this e-mail and any attachments is confidential and may be privileged or otherwise protected from disclosure It is intended solely for the attention and use of the named addressee If you are not the intended recipient dissemination copying or use of this e-mail and any attachments in whole or in part is prohibited If you have received the e-mail in error please notify the sender and delete the e-mail and any attachments from your computer system Whilst any attachments may have been checked for viruses you should rely on your own virus checker and procedures No responsibility is accepted by ACUITY Reputation Limited for loss or damage arising from the receipt or use of this e-mail PRIVILEGED CONFIDENTIAL Case Document Filed Page of From Sent To Cc Subject Ghislaine Ross Gow Friday January PM Philip Barden Max Re The Times Ghislaine Maxwell I believe the next 8hrs is the best chance we have to leverage some transparency advantage on this MoS first then Sunday Times Otherwise we lose any chance of ownership of the narrative Please give it some serious thought Dershowitz is out on Monday with a big push in The Times and we run the risk of looking less than gripped best On January I at Philip Barden I am heading home now and will call when get there Lets not waste this moment please Sent from my iPhone On Jan at Ross Gow wrote Ghislainr further reason for us to put our side of the story out best Ross Forwarded messa From Brown David Date January at Subject The Times Ghislaine Maxwell To Ross Gow Hi Ross rote Do keep in touch I think were running a piece written by Professor Dershowitz on Monday If Miss Maxwell wants to make a comment do let me know All the best David Brown PRIVILEGED CONFIDENTIAL Case Document Filed Page of Please consider the environment before printing this e-mail Newsworks bringing advertisers and newsbrands together newsworks.org.uk http w.newsworks.org uk This e-mail and any attachments are confidential may be legally privileged and are the property of News Corp UK Ireland Limited on whose systems they were generated News Corp UK Ireland Limited is the holding company for the News UK group is registered in England Wales under number has its registered office at London Bridge Street London SE 9GF and is registered with VAT number GB If you have received this e-mail in error please notify the sender immediately and do not use distribute store or copy it in any way Statements or opinions in this e-mail or any attachment are those of the author and are not necessarily agreed or authorised by News Corp UK Ireland Limited or any member of its group News Corp UK Ireland Limited may monitor outgoing or incoming emails as permitted by law It accepts no liability for viruses introduced by this e-mail or attachments News Corp UK Ireland Limited and its titles are committed to abiding by IPSOs regulations and the Editors Code of Practice that IPSO enforces Ross Gow Managing Partner ACUITY Reputation Berkeley Square London IJ 6HE PRIVILEG CONFIDENTIAL Case Document Filed Page of w.acuityreputation.com http://w.acuityreputation.com The information contained in this e-mail and any attachments is confidential and may be privileged or otherwise protected from disclosure It is intended solely for the attention and use of the named addressee If you are not the intended recipient dissemination copying or use of this e-mail and any attachments in whole or in part is prohibited If you have received the e-mail in error please notify the sender and delete the e-mail and any attachments from your computer system Whilst any attachments may have been checked for viruses you should rely on your own virus checker and procedures No responsibility is accepted by ACUITY Reputation Limited for loss or damage arising from the receipt or use of this e-mail fhi ernaii is intend for the ad rer.;see a rned it on!y It ay onta i iegally pr i vile ged or confidential lnformaHon if you are not the named individual you should no rea this ernail an if you yo rn ust not der any cir curn:;tan ces rn ke use of the inforrnatlon therein if you have read this emaii and it is not addressed to you ea 3e otify IT devonshires co uk and confirm 1at it has been deleted from your system and no capies made This Firm is auttlorised and regulated by the Soi i citors gu ation Auth or ity undc the na De onshi rn So iicitors and reg is tration urnbe This Fir doe not a ccept servi ctronic mail or fr csirn iie_ iist of artners oqeH1er wi th furthe ieQai st 1tr me ts is a vailable upo requ st or at w.devonshires.co.ul Jterms-and conditions/legal-notices.html Devoruhires So icit rs Finsbu ry Circu London C2 lDT fa JVhere i str ctions r1 a bee i ven by Dev hires Soiicitors to a barrister to work on a ciieni?s matter we notify you on behalf of a barrister th a ou a the rig ht to make a complaint about the service provided by that barrister or about the conduct of their Chambers A cop of the barrister and I or he i Chambe comp la i proc dure rna be obtained by contacting the Senior rl of that Chambers Nho conlact det aiis c:a be found on!in from us Com lain may made direct to the a rist heir Chamb er P!e a se note that tr1 ere rna be a tirne i irnit for ringing your co rnp a i You may a a ve tile right lo as th Legal Ornbuds rn an consider your com plaint at the end of mplaints proces rrnaUon or1 cor pls1 i ts to the L.egal rnbud nrrian includi tt etails of stric i rn i its to bring a cornp la int may be und at http://w.legalombudsman.org.uk rho Devonsh i es ndation is pro ud to A io for Kids a ri ty JVidG horizons reg charity i and Theatre Royal Stratford as req ch a rity duri as conside th environment before printin this email Please consider the environment before printing this email Ross Gow Managing Partner ACUITY Reputation Berkeley Square London WI 6HE w.acuityreputation.com The information contained in this e-mai and any attachments is confidential and may be privileged or otherwise protected from disclosure It is intended solely for the attention and use of the named addressee If you are not the intended recipient dissemination copying or use of this e-mail and any attachments in whole or in part is prohibited If you have received the e-mail in error please notify the sender and delete the e-mail and any attachments from your computer system Whilst any attachments may have been checked for viruses you should rely on your own virus checker and procedures No responsibility is accepted by ACUITY Reputation Limited for loss or damage arising from the receipt or use of this e-mail PRIVILEGED GM CONFIDENTIAL Case Document Filed Page of From Sent To Subject Attachments Ross Gow Monday September PM Gmax Philip Barden Fwd Question from NY Daily News Maxwell.pdf Here we go again YR on our case again Joyous to hear Im not a co-defendant Best Forwarded messa From Brown Stephen Date Sep Subject Question from NY Daily News To Cc Hi Ross Im working on a story about a defamation suit filed by Virginia Roberts against Ghislaine Maxwell Virginia alleges that Ghislaine defamed her by calling her claims obvious lies among other denials Those denials were released through you To be clear youre not named as a defendant Im wondering if Ghislaine has a response to the suit which is attached Thank you Stephen Brown Manhattan Federal Court Reporter NY Dail News This transmission is intended only for the use of the addressee and may contain information that is confidential privileged and or exempt from disclosure under applicable law If you are not the intended recipient you are hereby notified that any dissemination distribution or copying of the information contained herein is strictly unauthorized and prohibited If you have received this communication in error please notify the sender immediately and delete this message Thank you NJ
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