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H3V0GIU1 1 these other things that are circulating about her that have 2 nothing to do with Ms. Maxwell. 3 Mr. Cassell referred to our expert Phillip Esplin, 4 Dr. Esplin, and saying that he agreed not to refer to 5 as a prostitute. Your Honor, that came up in the 6 context of a cross examination in
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
VOGIU1 53 1 these other things that are circulating about her that have 2 nothing to do with Ms. Maxwell. 3 Mr. Cassell referred to our expert Phillip Esplin, 4 Dr. Esplin, and saying that he agreed not to refer to 5 s a prostitute. Your Honor, that came up in the 6 context of a cross examination in
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
24 25 53 H3VOGIU1 these other things that are circulating about her that have nothing to do with Ms. Maxwell. Mr. Cassell referred to our expert Phillip Esplin, Dr. Esplin, and saying that he agreed not to refer to Virginia Roberts as a prostitute. Your Honor, that came up in the context of a cross examina
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 Phillip Esplin and Sack of Defamation

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Paul Cassell
PERSON
Alan Dershowitz
PERSON
Colorado
LOCATION
Bradley Edwards
PERSONKliman
PERSONEsplin
PERSON
Alfredo Rodriguez
PERSON
Bill Clinton
PERSON
David Boies
PERSONSigrid McCawley
PERSONJeffrey Pagliuca
PERSONMinemyer
PERSON
Prince Andrew
PERSONScott Rothstein
PERSON
George W. Bush
PERSON
Virginia Giuffre
PERSON
Kenneth Marra
PERSONJack Scarola
PERSON