51 H3VOGIU1 ih the internet anywhere quoted in whole. 2 Also, Alan Dershowitz widely circulated his denials of 3 plaintiff's claims. He was on Good Morning America, he was on 4 CNN's Nancy Grace Show, he was on Fox News. All of those 5 places he called Virginia Roberts a liar, and a serial liar, 6 and other things. 7 We are entitled, your Honor, both through cross 8 examination of plaintiff as well as cross examination of her 9 experts, to challenge whether or not anything said by 10 Ms. Maxwell caused damage to her reputation or whether other 1a people calling her a liar on national news and international 12 news is, in fact, the cause of any damage to her reputation. 13 She is the one, of course, who has put her reputation 14 at issue. Having the Duke of York and Buckingham Palace issue 15 denials is not hearsay, your Honor, it is offered for the fact 16 that the denial was widely circulated and very likely de contributed to people considering plaintiff to be a liar. 18 Motion in limine number 6, plaintiff's sexual history 19 and reputation. This salient point, your Honor, of course, 20 again, under 405(b), is that once you have put your reputation 21 for being a liar in question, then other specific instances of 22 false claims become highly relevant and probative of your 23 character for truthfulness, particularly with regard to sexual 24 assault and sexual abuse. 25 Furthermore, your Honor, plaintiff is the one who's SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011354