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response an FBI 302 motion xcuse m statement of -- she claims is authentic, but she doesn't know how it was redacted, doesn't explain how it's redacted, but she wants to admit that

into evidence.

We are actually offering to put on the stand the

person who submitted the FOIA request to explain what was

requested and what was received. That is not expert testimony,

your Honor, that's chain of custody.

With regard to motion in limine number 5, evidence of

denials by Prince Andrew and Buckingham Palace. Again, your

Honor, in a defamation case -- and I'm now quoting from

plaintiff's treatise that they cited throughout their response

and their reply xcuse m "In defamation cases,

defendants can also prove that other liables and rumors about

the claimant are circulating, at least if they are widespread,

to demonstrate that it is not what the defendant said about the plaintiff that causes her reputation to suffer but what others said."

Plaintiff also cites Sack of Defamation. He supports

our position, your Honor. Here, we have a statement by

Buckingham Palace that was issued on the internet and widely

circulated. There is also a videotape of Prince Andrew denying

Virginia Roberts' claims. Both of those were far more circulated than anything Ms. Maxwell said, as evidenced by the

fact that plaintiff can't even find Ms. Maxwell's statement on

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

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