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list, we're not able to cross examine him, so what they want to

do is introduce triple hearsay of Buckingham Palace saying what Prince Andrews said in a news article without the reporter against my client without our ability to cross examine him on that.

So your Honor, they've tried to argue a little bit of

a securitous way, I think that it's a verbal act on behalf of

Prince Andrew, it doesn't meet that criteria, there's been no

statement by there's been no action by my client against him, and what's at issue in this case is, again, Maxwell's

statements against my client.

The case that they cite actually, the Minemyer case,

goes against them. It actually talks about how you would have

to call the reporter, that that couldn't come into evidence.

And so, your Honor, for those reasons, we believe that, again,

that's a distraction, it's highly prejudicial to allow a triple

hearsay document like that to come in without our ability to be

able to cross examine that individual. So for those reasons, your Honor, we believe that that should not come in.

They also made an argument that it's somehow an intervening cause or that, you know, it goes to the issue of

she should be seeking damages from Prince Andrew, things of

that nature. But as we know, because your Honor reviewed the case law with respect to the summary judgment, each individual

is responsible for their own defamation, so it doesn't come

SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

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