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20 Za 22 23 24 25 Case 1:15-cv-07433-LAP Document 1332-10 Filed 01/08/24 Page 43 of 64 42 H2G8GIUC you; she has produced nothing. From the early 2000s, the first documents we get, after pulling tooth and nail, is 2011. So there is nothing from her for the early years 2000. But we have pictures, hard copy pictures. We have hospital records from when my client was a minor here in New York with them. We have time and travel records saying call Maxwell. We have message pads. We have the FBI 302, which was taken in 2011, mentions Prince Andrew in it, in the unredacted part, so you can see it there. The victim notification letter, the black book, which we have talked about, and you said with respect to Alfredo Rodriguez, which has a Florida massage section that has a 14-year-old girl's name in it. So this information is all relevant to the factual issue of whether defendant's defamatory statement that my client lied about sexual abuse that's at issue here. Your Honor, they have been careful about trying to carve around your February 27th order, and I am mindful of the fact that that was an order that was issued at the motion to dismiss stage, but to be clear, that order has well-reasoned language because it talks about sexual abuse being a clear-cut issue. You either were abused or you were not. You said either Maxwell is telling the truth and she was involved or the plaintiff is telling the truth. It's a factual issue that can be determined by the finder of fact, as you said. So, your Honor, let's look at this republication issue SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300