HOUSE_OVERSIGHT_011398

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its entirety. Accordingly it should be summarily denied as

moot.

This motion should also be denied because it advances

the exact same arguments defendant advanced in her summary

judgment motion. She is seeking rehearing on her summary judgment motion, dressed up as a motion in limine. Many courts in this district have summarily denied motions in limine that

seek to relitigate arguments from summary judgment, and I have

listed six such cases on pages 7 and 8 of our response in

opposition. You ordered nine defendant's motions for summary

judgment. This Court rejects the argument that she should have

partial summary judgment on the January 4th statement. The

last sentence of that order states, "Because of the existence

of triable issues of material fact rather than opinion and

because the prelitigation privilege is inapplicable, the motion

for summary judgment is denied." Defendant's reiteration of

her defamatory press release confirming it two days later is

something that this Court did not rule that that is not actionable. So she's seeking rehearing. Also importantly, your Honor, Ms. Giuffre opposed

summary judgment on defendant's defamation in its entirety.

She opposed the motion for summary judgment in its entirety,

and this statement, as part and parcel of defendant's defamation and part and parcel of defendant's motion for

summary judgment.

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

HOUSE_OVERSIGHT_011398