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in to show reputation." Let me explain why I believe that argument is fundamentally flawed, and that will, of course,

carry over to other illustrations, as well.

The statement to which defense counsel was referring

was a statement that Ms. Giuffre's mother made during a

deposition as a witness in this case where the only people in

the room were the court reporter and the attorneys. The fact that when asked, "What did you think of your daughter 17 years

ago? Well, I thought at the time that she was a liar," wasn't

something that goes to Ms. Giuffre's reputation because there's

no evidence anybody knew about it other than, you know, the mother who is now being deposed in 2016.

Moreover, the question was, "What did you think about

the fact that your then 17-year-old child was running away from

school? Well, I thought she was lying to me about that." That

would go, I guess, to her reputation back in, what, 1999, 2000,

2001, that time period, but of course the damages that are at

issue in this case are damages around 2016 and thereabouts when

the defamatory statement is released.

So it's hard to see even an argument for the statement

of the mom in a deposition going to reputation. I don't know,

maybe I'm missing something, maybe there's some marginal

relevance that can be distilled out of all of that. But of

course then your Honor has to weigh whatever marginal value

that has as to reputational issues against the very significant

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

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