EXHIBIT Case Document Filed Page of CONFIDENTIAL Case Document Filed Page of From Sent To Subject THE TERRAMAR PROJECT FACEBOOK TWITTER PINTEREST INST AGRAM PLEDGE THE DAILY CATCH From Philip Barden Maxwell GMaxl ellmax.com Sunday January AM JJep Fw Sent Sunday January To Cc Maxwell Subject Re Saying nothing is reputational suicide Even if AR is discredited by AD people will know JE paid her off and believe was complicate absent a credible denial Now it is reported that engaged in direct abuse as I feared would happen Next reports to the authorities will be made It is necessary from a litigation investigatory and reputational reason to issue a cogent denial I can see why JE doesnt want this as it may not suit him but he is already toast Philip Sent from my iPhone Had Geordie on the phone half a dozen times today He would have give us a better hearing than most I figure Strongly believe saying nothing is the wrong thing especially as Dershowitz has a big piece coming in The Times on Monday PRIVILEGED CONFIDENTIAL Case Document Filed Page of Rest up and speak Monday Best Ross Sent from my BlackBerry wireless device From Philip Barden Date Sat Jan To Maxwell GMax ellmax.com mailto:GMax ellmax.com Cc Ross Go Subject Re All I am back on i ne now I see the statement didnt go Monday Maybe tomorrow I will speak to Jeffery Epsteins lawyer but has a conflict with you and will want your silence as whilst you are being attacked there is less heat on him Either Virginia Roberts is lying or not If we let her lie without challenge then the lies become the reality and that may lead to you facing investigation These are serious allegations and In the UK prosecuting people who face allegations of sex abuse is now common place and a lot of resources are focused on this We cant sit back and let you be a conspirator by silence Your are not guilty and must follow Dershowtiz line He is a leading lawyer and he hasnt followed the dont say anything for fear of litigation He has rightly called YR bluff and shouted his innocence You have to stand up and deny the allegations or be branded guilty by association and that may lead to other investigations and worse I feel I am going around in circles I know what is right to do and that is to shout your innocence Try and get some rest Call me tomorrow if you want anytime Speak to Deshowit Dont alla yourself to JE as that is not the way to go Best Philip Sent from my iPhone PRIVIL EG ED GM CONFIDENTIAL Case Document Filed Page of On Jan at Maxwell GMax ellmax.com mailto:GMax ellmax.com mailto:GMax ellmax.com wrote 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 understand 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 INSTAGRAM PLEDGE THE DAILY CATCH 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 circumstances make use of the information therein If you have read this email and it is not addressed to you please notify and confirm that it has been deleted from your system and no copies made This Firm is authorised and regulated by the Solicitors Regulation Authority under the name of Devonshires Solicitors and registration number This Firm does not accept service by electronic mail or facsimile A list of partners together with further legal statements is available upon request or at devonshires.co uk rms-and conditions legal-notices.html http w.devonshires co.uk terms-and conditions legal notices.html Devonshires Solicitors Finsbury Circus London EC2M 7DT tel fax PRIVILEGED GM CONFIDENTIAL Case Document Filed Page of Where instructions have been given by Devonshires Solicitors to a barrister to work on a clients matter we notify you on behalf of that barrister that you have the right to make a complaint about the service provided by that barrister or about the conduct of their Chamb rs A copy of the barrister and or their Chambers complaints procedure may be obtained by contacting the Senior Clerk of that Chambers whose contact details can be found online or from us Complaints may be made direct to the barrister their Chambers Please note that there may be a time limit for bringing your complaint You may also have the right to ask the Legal Ombudsman to consider your complaint at the end of the complaints process Information on complaints to the Legal Ombudsman including the details of strict time limits to bring a complaint may be found at http w.legalombudsman.org.uk The Devonshires Foundation is proud to support Action for Kids reg charity Wide horizons reg charity and Theatre Royal Stratford East reg charity during Please consider the environment before printing this email Please consider the environment before printing this email PRIVILEGED GM CONFIDENTIAL Case Document Filed Page of From Sent To what did you decide to do please note jeffrey jeevacation gmail.com Sunday January PM Gmax The information contained in this communication is confidential may be attorney-client privileged may constitute inside information and is intended only for the use of the addressee It is the property of JEE Unauthorized use disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful If you have received this communication in error please notify us immediately by return e-mail or by e-mail to jeevacation gmail.com and destroy this communication and all copies thereof including all attachments copyright all rights reserved PRIVILEGED CONFIDENTIAL Case Document Filed Page of From Sent To jeffrey jeevacation gmail.com Wednesday January PM Gmax Ask press to investigate whether Clinton was ever there Challenge the press please note The information contained in this communication is confidential may be attorney-client privileged may constitute inside information and is intended only for the use of the addressee It is the property of JEE Unauthorized use disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful If you have received this communication in error please notify us immediately by return e-mail or by e-mail to jeevacation gmail.com and destroy this communication and all copies thereof including all attachments copyright all rights reserved PRIVILEGED GM CONFIDENTIAL Case Document Filed Page of From Sent To jeffrey jeevacation gmail.com Wednesday January PM Gmax Since JE was charged in for solicitation of a prostitute I have been the target of outright lies innuendo slander defamation and salacious gossip and harrasment headlines made up of quotes I have never given statements I have never made trips with people to places I have never been ho lidays with people I hav never met false allegations of impropriety and offensive behavior that I abh or and have never ever been party to witness to events that I have never seen living off trust funds that I have never ever had party to stories that have changed materially both in time place and event depending on what paper you read and the list goes on I have never been a party in any criminal action pertaining to JE For the record At the time of Jeffreys plea I was in a very long-term committed relationship with another man and no longer working with Jeffrey Whilst I remained on friendly terms with him up until his plea I have had limited contact since Every story in the press innuendo and comment has been taken from civil depositions against JE which were settled many years ago None of the depositions were ever subject to cross examination not one any PRIVILEGED GM CONFIDENTIAL Case Document Filed Page of standard of truth and were used for those who claimed they were victims to receive financial payment to be shared between them and their lawyers One firm created and sold fake cases against Mr Epstein the firm subsequently imploded and the Rothstein the owner of the firm was sent to jail for years for his crime The lawyer who is currently representing Virgina was his partner need I say morel These so called new revelations stem from an alleged diary from VR that reads like the memoirs she is purporting to be sellin Also perhaps pertinent in a previous complaint against others her claims were rejected by the police due to VR lack of credibility The new interest in this old set tled case results from lawyers representing some of JE victims filed a suit against the US government not JE They contend that the Us govt violated their rights The document and deal that JE negotiated with the government was given to the lawyers years ago and is a public document I am not part of nor did you have anything to do with JE plea bargain I have never even seen the proceedings nor any of the depositions PRIVILEGED CONFIDENTIAL Case Document Filed Page of I reserve my right to file com laint and sue for defamati and a nder please note The information contained in this communication is confidential may be attorney-client privileged may constitute inside information and is intended only for the use of the addressee It is the property of EE Unauthorized use disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful I you have received this communication in error please notify us immediately by return e-mail or by e-mail to jeevacation gmail.com and destroy this communication and all copies thereof including all attachments copyright all rights reserved PRIVILEGED GM CONFIDENTIAL Case Document Filed Page of From Sent To Subject jeffrey jeevacation gmail.com Wednesday January PM Maxwell Re FW Guardian This will now end but I think a dismissive statement is ok On Wednesday January Maxwell GMaxl ellmax com wrote See bellow THE TERRAMAR PROJECT FACEBOOK TWITTER PINTEREST INST AGRAM PLEDGE THE DAILY CATCH From Ross Gow Date Wednesday January at PM To Phi ip Barden gmax Subject Fwd Guardian So this isnt getting better latest from our chums at The Guardian Forwarded message From Jon Swaine Date Wednesday January Subject Guardian To Ross As discussed here is the new affidavit from Virginia Roberts She claims to have had sex with Ms Maxwell when Roberts was years old She alleges that Ms Maxwell was heavily involved in the illegal sex and she had sex with underage girls virtually every day when I was around her Roberts also says that Ms Maxwell had large amounts of child pornography that she personally made Please do pass on any comment or response Ms Maxwell would like to make PRIVILEGED GM CONFIDENTIAL Case Document Filed Page of Thanks and all best Jon Visit theguardian com On your mobile and tablet download the Guardian iPhone and Android apps theguardian com/guardianapp and our tablet editions theguardian com/editions Save up to by subscribing to the Guardian and Observer choose the papers you want and get full digital access Visit subscribe.theguardian com This e-mail and all attachments are confidential and may also be privileged If you are not the named recipient please notify the sender and delete the e-mail and all attachments immediately Do not disclose the contents to another person You may not use the information for any purpose or store or copy it in any way Guardian News Media Limited is not liable for any computer viruses or other material transmitted with or as part of this e-mail You should employ virus checking software Guardian News Media Limited is a member of Guardian Media Group pie Registered Office PO Box Kings Place York Way London N1 2AP Registered in England Number Ross Gow Managing Partner ACUITY Reputation Berkeley Square London WlJ 6HE 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 th i mail RIVI EG GM CONFIDENTIAL Case Document Filed Page of please note The information contained in this communication is confidential may be attorney-client privileged may constitute inside information and is intended only for the use of the addressee It is the property of JEE Unauthorized use disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful If you have received this communication in error please notify us immediately by return e-mail or by e-mail to jeevacation gmail.com and destroy this communication and all copies thereof including all attachments copyright all rights reserved PRIVILEGED GM CONFIDENTIAL Case Document Filed Page of From Sent To jeffrey jeevacation gmail.com Thursday January PM Gmax ive tried to call what have you decided please note The information contained in this communication is confidential may be attorney-client privileged may constitute inside information and is intended only for the use of the addressee It is the property of JEE Unauthorized use disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful If you have received this communication in error please notify us immediately by return e-mail or by e-mail to jeevacation gmail.com and destroy this communication and all copies thereof including all attachments copyright all rights reserved PRIVILEGED GM CONFIDENTIAL Case Document Filed Page of From Sent To Subject should not be legal jeffrey jeevacation gmail.com Friday January PM Maxwell Re FW Hi On Fri Jan at PM Maxwell GMaxl ellmax.com wrote gawker have printed the entire address book albeit redacted Sent from my iPad please note The information contained in this communication is confidential may be attorney-client privileged may constitute inside information and is intended only for the use of the addressee It is the property of JEE Unauthorized use disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful If you have received this communication in error please notify us immediately by return e-mail or by e-mail to jeevacation gmail.com and destroy this communication and all copies thereof including all attachments copyright all rights reserved PRIVILEGED CONFIDENTIAL Case Document Filed Page of From Sent To Subject jeffrey jeevacation gmail.com Friday January PM Maxwell Re Hi I am convinced your statement hould be be about the clinton story being easily dsiporived On Fri Jan at PM Maxwell GM ax llmax.com wrote My friends are apoplectic Do you know what edwards et al want from all this shit What are they looking for What is the end game THE TERRAMAR PROJECT FACEBOOK TWITTER PINTEREST INST AGRAM PLEDGE THE DAILY CATCH From jeffrey Sent Friday January To Ma well Subject Re FW Hi should not be legal On Fri Jan at PM Maxwell GMax ellmax.com wrote gawker have printed the entire address book albeit redacted Sent from my iPad please note The information contained in this communication is confidential may be attorney client privileged may constitute inside information and is intended only for the use of the addressee It i the property of JEE Unauthorized use disclosure or copying of this communication or any part thereof is strictly prohibited a nd may be unlawful If you have received this communication in error plea notify us immediately by PRIVILEGED CONFIDENTIAL Case Document Filed Page of return e-mail or by e-mail to jeevacation gmail.com and destroy this communication and all copies thereof including all attachments copyright all rights reserved please note The information contained in this communication is confidential may be attorney-client privileged may constitute inside information and is intended only for the use of the addressee It is the property of JEE Unauthorized use disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful If you have received this communication in error please notify us immediately by return e-mail or by e-mail to jeevacation gmail.com and destroy this communication and all copies thereof including all attachments copyright all rights reserved PRIVILEGED GM __ CONFIDENTIAL Case Document Filed Page of From Sent To Subject publiclity jeffrey jeevacation gmail.com Friday January PM Maxwell Re Hi On Fri Jan at PM Maxwell GMaxl ellmax.com wrote My friends are apoplectic Do you know what edwards et al want from all this shit What are they looking for What is the end game THE TERRAMAR PROJECT FACEBOOK TWITTER PINTEREST INST AGRAM PLEDGE THE DAILY CATCH From jeffrey Sent Friday January To Maxwell Subject Re FW Hi should not be legal On Fri Jan at PM Maxwell GMaxI ellmax.com wrote gawker have printed the entire address book albeit redacted Sent from my iPad please note The information contained in this communication is confidential may be attorney-client privileged may constitute inside information and is intended only for the use of the addressee It is the property of JEE Unauthorized use disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful If you have received this communication in error please notify us immediately by PRIVILEGED GM CONFIDENTIAL Case Document Filed Page of return e-mail or by e-mail to jeevacation gmail.com and destroy this communication and all copies thereof including all attachments copyright all rights reserved please note The information contained in this communication is confidential may be attorney-client privileged may constitute inside information and is intended only for the use of the addressee It is the property of JEE Unauthorized use disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful If you have received this communication in error please notify us immediately by return e-mail or by e-mail to jeevacation gmail.com and destroy this communication and all copies thereof including all attachments copyright all rights reserved RIVILEGED GM __ CONFIDENTIAL Case Document Filed Page of From Sent To Subject thnaks jeffrey jeevacation gmail.com Sunday January PM Maxwell Re Update FYI On Sun Jan at PM Maxwell GMaxI llmax.com wrote All had quietened down over here in last hours but just googled you all again and under JE the daily mail printed a story hours ago that they picked up from the daily beast which is jane doe ls testimony and video interview about how Haley robson recruited her to give je one massage when she was and goes into detail about what happened Sent from my iPad please note The information contained in this communication is confidential may be attorney-client privileged may constitute inside information and is intended only for the use of the addressee It is the property of JEE Unauthorized use disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful If you have received this communication in error please notify us immediately by return e-mail or by e-mail to jeevacation gmail.com and destroy this communication and all copies thereof including all attachments copyright all rights reserved PRIVILEGED GM __ CONFIDENTIAL Case Document Filed Page of From Sent To Subject jeffrey jeevacation gmail.com Sunday January AM Maxwell Re ok with me You have done nothing wrong and i woudl urge you to start acting like it go outside head high not as an esacping convict go to parties deal with it i had Iisa svenson the swedish ocean ambassador yesteady she said no one on her ocean panel takes this stuff seriously and you would be welcoe to the ocean conferenec water conference etc On Sat Jan at PM Maxwell GMaxl ellmax.com wrote I would appreciate it if would come out and say she was your gfriend I think she was from end to THE TERRAMAR PROJECT FACEBOOK TWITTER PINTEREST INST AGRAM PLEDGE THE DAILY CATCH please note The information contained in this communication is confidential may be attorney-client privileged may constitute inside information and is intended only for the use of the addressee It is the property of JEE Unauthorized use disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful If you have received this communication in error please notify us immediately by return e-mail or by e-mail to jeevacation gmail.com and destroy this communication and all copies thereof including all attachments copyright all rights reserved PRIVILEG GM CONFIDENTIAL Case Document Filed Page of From Sent To Subject I have not decided what to do THE TERRAMAR PROJECT FACEBOOK TWITTER PINTEREST INST AGRAM PLEDGE THE DAILY CATCH From jeffrey Maxwell GMaxl ellmax.com Tuesday January AM jeffrey Re Sent Tuesday January To Maxwell Subject what has happned to you and your statmenet please note The information contained in this communication is confidential may be attorney-client privileged may constitute inside information and is intended only for the use of the addressee It is the property of JEE Unauthorized use disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful If you have received this communication in error please notify us immediately by return e-mail or by e-mail to jeevacation gmail.com and destroy this communication and all copies thereof including all attachments copyright all rights reserved PRIVILEGED GM
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