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10 fd. 12 [3 14 15 16 i) 18 wife) 20 21 22 23 24 25 68 H3VOGIU1 THE COURT: But how is that going to figure into damages in our case? MS. MENNINGER: Your Honor, I think the jury would be instructed here not to hold Ms. Maxwell responsible for any harm to plaintiff's reputation caused by third parties or alternate sources, including stories that were generated by statements made by her own counsel, by Alan Dershowitz, by Prince Andrew, by anyone else. THE COURT: Well, yes. But what I'm trying to figure out, what about that case was damaging to Giuffre? MS. MENNINGER: I can't tell you that, your Honor. It's actually plaintiffs who are asking for $1.9 million in reputational cleanup costs, and when you ask them what reputational cleanup costs are you trying to clean up, they point to stories having to do with the Dershowitz litigation. They say her reputation was damaged by that litigation and by the stories related to it, and they want to push all of those stories down on the internet searches. Not stories that relate to Ms. Maxwell, stories that relate to her litigation with -- her lawyer's litigation with Alan Dershowitz. THE COURT: Okay. MS. MENNINGER: I don't think that evidence should come in because I don't think it's based on science, but I realize that's not for today. Likewise, your Honor, her failure to sue Alan SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011371