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the internet anywhere quoted in whole.

Also, Alan Dershowitz widely circulated his denials of plaintiff's claims. He was on Good Morning America, he was on CNN's Nancy Grace Show, he was on Fox News. All of those places he called Virginia Roberts a liar, and a serial liar,

and other things.

We ar ntitled, your Honor, both through cross

examination of plaintiff as well as cross examination of her

experts, to challenge whether or not anything said by

Ms. Maxwell caused damage to her reputation or whether other people calling her a liar on national news and international news is, in fact, the cause of any damage to her reputation.

She is the one, of course, who has put her reputation

at issue. Having the Duke of York and Buckingham Palace issue denials is not hearsay, your Honor, it is offered for the fact

that the denial was widely circulated and very likely

contributed to people considering plaintiff to be a liar. Motion in limine number 6, plaintiff's sexual history and reputation. This salient point, your Honor, of course,

again, under 405(b), is that once you have put your reputation

for being a liar in question, then other specific instances of false claims become highly relevant and probative of your

character for truthfulness, particularly with regard to sexual

assault and sexual abuse.

Furthermore, your Honor, plaintiff is the one who's

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

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