gov.uscourts.nysd.447706.1330.21.pdf

Case 1:15-cv-07433-LAP Document 1330-21 Filed 01/05/24 Page 1 of 11 EXHIBIT C  Case 1:15-cv-07433-LAP Document 1330-21 Filed 01/05/24 Page 2 of 11 From: [email protected] Sent: Saturday, January 10, 2015 9:00 AM To: Philip Barden; Ross Gow I am out of my depth to understanding defamation and other legal hazards and don't 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 can't 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 can't even see what life after press he'll even looks like - statements that don't address all just lead to more questions .. what is my relationship to clinton ? Andrew on and on. Let's rest till monday. I need head space THE TERRAMAR PROJECT FACEBOOK TWITTER G+ PINTEREST INSTAGRAM PLEDGE THE DAILY CATCH PRIVILEGED GM_001044 GM_01060 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1330-21 Filed 01/05/24 Page 3 of 11 G+<https:[[plus.google.com/104195649525707945586/posts> Pl NTEREST<http ://pinterest.com/terra ma rpro ject/> INSTAGRAM<http://instagram.com/theterramarproject> PLEDGE<http://www.theterramarproject.org/pledge> THE DAILY CATCH<http://theterramarproject.org/thedailycatch/> From: Philip Barden Date: Friday, January 9, 2015 at 17:05 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 silence 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 9 Jan 2015, at 21:53, "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 R On 9 January 2015 at 20:02, Philip Barden I am heading home now and will call when get there Let's not waste this moment please 3 PRIVILEGED GM_001047 GM_01061 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1330-21 Filed 01/05/24 Page 4 of 11 Sent from my iPhone On 9 Jan 2015, at 18:11, "Ross Gow" Ghislainr further reason for us to put our side of the story out ... best Ross ---------- Forwarded message---------- Date : 9 January 2015 at 18:09 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 - bringing advertisers and newsbrands together www.newsworks.org.uk<http://www.newsworks.org.uk/><http://www.newsworks.org.uk<http://www.news works.org. u k/» This e-mail and any attachments are confidential, may be 4 PRIVILEGED GM_001048 GM_01062 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1330-21 Filed 01/05/24 Page 5 of 11 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 81701, has its registered office at 1 London Bridge Street, London, SEl 9GF and is registered with VAT number GB 243 8054 69 . 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 IPSO's regulations and the Editors' Code of Practice that IPSO enforces. Ross Gow Managing Partner ACUITY Reputation 23 Berkeley Square London WlJ 6HE www.acuityreputation.com< http://www.acuityreputation .com/><http://www .acuityreputation.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(s). 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Ross Gow Managing Partner ACUITY Reputation 23 Berkeley Square London WlJ 6HE 6 PRIVILEGED GM_001050 GM_01064 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1330-21 Filed 01/05/24 Page 7 of 11 www.acuityreputation.com<http://www.acuityreputatio n.com/><http://www.acuityreputation.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(s). 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. 7 PRIVILEGED GM_001051 GM_01065 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1330-21 Filed 01/05/24 Page 8 of 11 From: Ross Gow Sent: Friday, January 09, 2015 2:54 PM To: Philip Barden Cc: G Max Subject: Re: The Times - Ghislaine Maxwell Ghislaine I believe the next l 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 R On 9 January 20 I 5 at 20:02, Philip Barden rote: I am heading home now and will call when get there Let's not waste this moment please Sent from my iPhone On 9 Jan 2015 , at 18:11, "Ross Gow" wrote: Ghislainr further reason for us to put our side of the story out... best Ross ---------- Forwarded messa e ---------- From: Brown, David Date: 9 January 2015 at 1 :0 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 PRIVILEGED GM_001052 GM_01066 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1330-21 Filed 01/05/24 Page 9 of 11 "Please consider the environment before printing this e-mail" Newsworks - bringing advertisers and newsbrands together www .newsworks.org.uk<http://www.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 81701, has its registered office at 1 London Bridge Street, London, SE 1 9GF and is registered with VAT number GB 243 8054 69. 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. 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Complaints may be made direct to the barriste ( / their Chambers. P!ease note that tr1ere rnay be a tirne iirnit for bringing your cornplaint You may also f1ave ti'le right lo ask the Legal Ornbuds rnan to consider your complaint at the end of thG complaints process, lnforrnaUon or1 cornpls1ints to the L.egal Ornbudn rrian, includi ng tt·ie details of strict tirn(?. limits to bring a cornplaint. may be fo und at http://www.legalombudsman.org.uk rho Devonsh ires F:ou ndation is proud to mJppor-t Action for Kids (reg. charity 106f384 ·1), \JVidG horizons {reg. charity i 105847), and Theatre Royal Stratford East (req. charity 233B0'!) durin g 2013/20 14. Please consider the environment before printin~1 this email. Please consider the environment before printing this email. Ross Gow Managing Partner ACUITY Reputation 23 Berkeley Square London WI J 6HE www.acuityreputation.com The information contained in this e-mai l 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(s). 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. 3 PRIVILEGED GM_001054 GM_01068 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1330-21 Filed 01/05/24 Page 11 of 11 From: Ross Gow Sent: Monday, September 21, 2015 2:22 PM To: Gmax; Philip Barden Subject: Fwd: Question from NY Daily News Attachments: Maxwell.pdf G Here we go again. YR on our case again. Joyous to hear I'm not a co-defendant ... Best R ---------- Forwarded messa From : "Brown, Stephen" Date: 21 Sep 2015 20:28 Subject: Question from NY Daily News To: Cc: Hi Ross, I'm 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, you're not named as a defendant.) I'm 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 unauthorize d and prohibited. If you have received this communication in error, please notify the sender immediately and delete this messa ge. Thank you. ************(NJ) CONFIDENTIAL GM_00594