Case 1:15-cv-07433-LAP Document 443 Filed 09/22/16 Page 1 of 4 United States District Court Southern District of New York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAINTIFF'S NOTICE OF RELATED ACTION IN THE UNITED KINGDOM TO OBTAIN THE DEPOSITION OF DEFENDANT'S PRESS AGENT, by and through her undersigned counsel hereby gives this Court notice of a related action, and states as follows. For many months, agent, has attempted to serve process on Defendant's press Gow, who is a key witness in this case because he issued, on Defendant's behalf, one of the defamatory statements at issue to multiple media outlets. Defendant's counsel, Philip Barden, is also counsel for Mr. Gow. Mr. Barden refused to accept service of process of Rule 45 subpoena on Mr. Gow's behalf, despite extensive correspondence with counsel, and her offer to take the deposition at a place and date convenient for Mr. Gow. has expended considerable time and money in an effort to serve process upon Mr. Gow. served process on Mr. Gow through The Hague Convention, causing United Kingdom government agency to serve the subpoena at Mr. Gow's place of employment. Additionally, hired process servers in the United Kingdom who made multiple attempts to effect personal service upon Mr. Gow at both his business and residential 1 EFTA02801051