tell you that." So even the defense counsel when given an

10 id. 12 13 14 L5 16 ne) 18 life) 20 21 22 23 24 25 86 H3VOGIU1 tell you that." So even the defense counsel when given an opportunity to articulate the relevance failed to do so, in our view. She says then her next argument is, well, the plaintiff's experts are using Dershowitz's statements. As you know from the 702 pleadings, no, we're using Maxwell's statements. We're only going to be proving a case about what Maxwell's defamation did to Ms. Giuffre. And then the last argument was that there was a failure to mitigate damages by suing Dershowitz. Well, your Honor knows, if a person A commits a defamation, you sue A and you get your damages. Then if person B does something, you sort that out in a separate proceeding in a separate way. Sacks and others are very instructive on that. The last point they made was that, well, look, these statements were going on while Cassell and Edwards were representing her. They've shown simultaneity in time, but not simultaneity in the scope. It is true that the lawsuit was settled, and I won't refer to myself in the third person. Mr. Edwards and I settled the lawsuit and made certain statements in connection with that, but that was to take care of our own professional reputation and the lawsuit associated with that, it had nothing to do with representing Ms. Giuffre. I believe I have two left, your Honor, and you've been SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011389