Every indexed document

holding that those were not relevant. So we're in

you did have -- in your February 2nd order

and we have a few points there to raise. I mean

who is on the defendant's witness list for

and reputation to show the truthfulness of that

but we don't have him with respect to this

what we know is he flew with Jeffrey Epstein at

you did not allow us to depose him because

just that she was there. And they are seeking to

my client is a liar or is lying about that.

we've split that up a bit. I'm going to start with

our client's statement about that would be opinion

and we say that that's not what's at issue

this may help -- we were trying to streamline the

there are a whole series of other things

and some of that abuse did occur when she was

the defendant came out and said she was lying

obviously. So is it you are restricting your claim to

we were discussing the redactions of the

” Roberts had said in her statement. “I got