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10 fd. 12 [3 14 15 16 i) 18 wife) 20 21 22 23 24 25 51 H3VOGIU1 the internet anywhere quoted in whole. Also, Alan Dershowitz widely circulated his denials of plaintiff's claims. He was on Good Morning America, he was on CNN's Nancy Grace Show, he was on Fox News. All of those places he called Virginia Roberts a liar, and a serial liar, and other things. We ar ntitled, your Honor, both through cross examination of plaintiff as well as cross examination of her experts, to challenge whether or not anything said by Ms. Maxwell caused damage to her reputation or whether other people calling her a liar on national news and international news is, in fact, the cause of any damage to her reputation. She is the one, of course, who has put her reputation at issue. Having the Duke of York and Buckingham Palace issue denials is not hearsay, your Honor, it is offered for the fact that the denial was widely circulated and very likely contributed to people considering plaintiff to be a liar. Motion in limine number 6, plaintiff's sexual history and reputation. This salient point, your Honor, of course, again, under 405(b), is that once you have put your reputation for being a liar in question, then other specific instances of false claims become highly relevant and probative of your character for truthfulness, particularly with regard to sexual assault and sexual abuse. Furthermore, your Honor, plaintiff is the one who's SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011354