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14 Let me turn then to point number 19. Here again, we 15 have a narrow issue presented to your Honor. We are asking 16 that you exclude Judge Marra's ruling on the joinder motion. 17 As your Honor is well aware, the triggering event in this case 18 was when Ms. then known as Jane Doe Number
o your Honor. We are asking 16 that you exclude Judge Marra's ruling on the joinder motion. 17 As your Hono
it is not what the defendant said about the 17 plaintiff that causes her reputation to suffer but what others 18 said." 19 Plaintiff also cites Sack of Defamation. He supports 20 our position, your Honor. Here, we have a statement by 21 Buckingham Palace that was issued on the internet and widely 22 circu
14 Let me turn then to point number 19. Here again, we 15 have a narrow issue presented to your Honor. We are asking 16 that you exclude Judge Marra's ruling on the joinder motion. 17 As your Honor is well aware, the triggering event in this case 18 was when Ms. , then known as Jane Doe Numbe
o your Honor. We are asking 16 that you exclude Judge Marra's ruling on the joinder motion. 17 As your Hono
strate that it is not what the defendant said about the plaintiff that causes her reputation to suffer but what others said." Plaintiff also cites Sack of Defamation. He supports our position, your Honor. Here, we have a statement by Buckingham Palace that was issued on the internet and widely circulated. There
you already. Let me turn then to point number 19. Here again, we have a narrow issue presented to your Honor. We are asking that you exclude Judge Marra's ruling on the joinder motion. As your Honor is well aware, the triggering event in this case was when Ms. Giuffre, then known as Jane Doe Number 3,
ed to your Honor. We are asking that you exclude Judge Marra's ruling on the joinder motion. As your Honor is
onstrate that it is not what the defendant said about the plaintiff that causes her reputation to suffer but what others said." Plaintiff also cites Sack of Defamation. He supports our position, your Honor. Here, we have a statement by Buckingham Palace that was issued on the internet and widely circulated. There
Entities connected to both Kenneth Marra and Sack of Defamation

Jeffrey Epstein
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Paul Cassell
PERSON
Alan Dershowitz
PERSONthe Southern District
LOCATION
George W. Bush
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Virginia Giuffre
PERSON
Bill Clinton
PERSONScott Rothstein
PERSONJack Scarola
PERSON
Alfredo Rodriguez
PERSON
Al Gore
PERSON
David Boies
PERSON
Bernie Sanders
PERSON
Colorado
LOCATIONSigrid McCawley
PERSONEleventh Circuit
ORGANIZATION