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20 Za 22 23 24 25 Case 1:15-cv-07433-LAP Document 1332-10 Filed 01/08/24 Page 40 of 64 39 H2G8GIUC lead Ms. Maxwell or Mr. Barton on her behalf to believe in good faith that she has told a falsehood, this case ends, Judge, the plaintiff loses. In our papers, we actually identified for the Court some of those facts. I won't go into them now because we are on the record and the court hasn't been sealed, but I submit to the Court, Judge, that there is no dispute that at least two, and we know of many more of course, but at least two of plaintiff's original allegations are false. We know that at least two of her new allegations are false. And any way you cut it, this plaintiff has lied, and she has lied in statements to the public. The only way that Ms. Maxwell would know about the statements are the ones that she made to the public. In her own deposition, she has admitted that parts of the Sharon Churcher article, Exhibit A to our memorandum, at least 11 statements that she made are not true. That's it. The case is over, Judge. We have shown more than one allegation made by this plaintiff is false. Or we don't even have to prove that it's false. We can simply show that we had a good faith basis for believing that it was false, and under New York Times v. Sullivan, that's good enough. The case is over, Judge. I anticipate that what is going to happen as soon as I leave this podium, Judge, is that the plaintiff is going to trot out about a hundred pages of facts and spend most of the SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300