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10 fd. 12 [3 14 15 16 i) 18 wife) 20 21 22 23 24 25 H3VOGIU1 alleged to have defamed someone based on facts, not opinions. THE COURT: Agreed. Agreed. MS. MENNINGER: And so she can -- the Davis v. Boeheim case is a perfect example of that, your Honor. She can only speak to facts about which she has personal knowledge. If plaintiff goes and proves that plaintiff went and had sex with Jeffrey Epstein at some point in time and our client wasn't there, our client's statement about that would be opinion, it would not be a fact based on personal knowledge. THE COURT: I mean, okay. But that's an issue of knowledge. That's a different -- MS. MENNINGER: You just said -- THE COURT: That's a different -- MS. MENNINGER: The hypothetical was if our client wasn't involved. If our client wasn't involved then it would be an opinion. THE COURT: Thanks very much. I'm glad for this clarity, which frankly, at the moment, alludes me. Okay, let's move on. Yes, I'll hear from the movant. MS. McCAWLEY: Thank you, your Honor. The first order of business we'd like to address, if it's okay with the Court, is our filing, which was 691, which is our omnibus motion in limine. And if it's okay with the Court, we've split that up a bit. I'm going to start with respect to that motion in limine. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011309