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10 Ail Le 13 14 15: 16 17 18 19 20 21 22 23 24 25 Case 1:15-cv-07433-LAP Document 1325-18 Filed 01/04/24 Page 11 of 23 10 G1ETGIUA Now in the papers -- and I will just touch on this briefly because my colleague did not touch on it significantly here and I don't want to waste the Court's time, but she alleged a number of privileges that she believes Ms. Maxwell should be able to hide behind in order to preserve these defamatory statements. I impart on your Honor that a determination as to whether any of those privileges apply would be premature at this stage. That's your case, which is Block v. First Blood, 691 F.Supp. 685. In that case you dealt with one of the privileges she is asserting here, the prelitigation privilege, and you found that it would be premature, even at the summary judgment stage, to be analyzing whether or not that was applicable. So what we have here is qualified privileges being asserted as to defamatory statements. The two qualified privileges she asserts are the self-defense privilege and the prelitigation privilege. So in other words, if the defamatory statements survive, she says, nevertheless the privileges preclude the case from going forward. The self-defense privilege has been addressed by the highest court of New York just as recent as this year, and that's in the case of Davis v. Boeheim. And that was case where the Syracuse basketball coach was accused by two victims that were childhood victims who later as adults came forward SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300