HOUSE_OVERSIGHT_011389

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tell you that." So even the defense counsel when given an

opportunity to articulate the relevance failed to do so, in our

view.

She says then her next argument is, well, the

plaintiff's experts are using Dershowitz's statements. As you know from the 702 pleadings, no, we're using Maxwell's statements. We're only going to be proving a case about what

Maxwell's defamation did to Ms. Giuffre.

And then the last argument was that there was a

failure to mitigate damages by suing Dershowitz. Well, your

Honor knows, if a person A commits a defamation, you sue A and

you get your damages. Then if person B does something, you

sort that out in a separate proceeding in a separate way.

Sacks and others are very instructive on that.

The last point they made was that, well, look, these

statements were going on while Cassell and Edwards were

representing her. They've shown simultaneity in time, but not

simultaneity in the scope.

It is true that the lawsuit was settled, and I won't

refer to myself in the third person. Mr. Edwards and I settled

the lawsuit and made certain statements in connection with

that, but that was to take care of our own professional

reputation and the lawsuit associated with that, it had nothing to do with representing Ms. Giuffre.

I believe I have two left, your Honor, and you've been

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

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