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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
ork street 20 that, "I am referring to the statement that we made." As we 21 set forth in our summary judgment brief, this Court's ruling in 22 Adelson v. Harris is directly on point, that a mere reference 23 to another writing that contains defamatory statements does not 24 constitute an actiona
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
t on a New York street that, "I am referring to the statement that we made." As we set forth in our summary judgment brief, this Court's ruling in Adelson v. Harris is directly on point, that a mere reference to another writing that contains defamatory statements does not constitute an actionable repe
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
t on a New York street that, "I am referring to the statement that we made." As we set forth in our summary judgment brief, this Court's ruling in Adelson v. Harris is directly on point, that a mere reference to another writing that contains defamatory statements does not constitute an actionable repe
Entities connected to both Phillip Esplin and Peter Mandelson

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Bill Clinton
PERSON
Alan Dershowitz
PERSON
Bradley Edwards
PERSON
George W. Bush
PERSON
David Boies
PERSON
Paul Cassell
PERSON
Al Gore
PERSON
Virginia Giuffre
PERSONSigrid McCawley
PERSON
Wilbur Ross
PERSONSharon Churcher
PERSON
Colorado
LOCATION
Bernie Sanders
PERSON
Conan
PERSONEmmy Taylor
PERSON
Kenneth Marra
PERSON
David Rodgers
PERSON