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50 H3VOGIU1 1 response an FBI 302 motion -- excuse me -- statement of -- she 2 claims is authentic, but she doesn't know how it was redacted, 3 doesn't explain how it's redacted, but she wants to admit that 4 into evidence. 5 We are actually offering to put on the stand the 6 person who submitted the FOIA request to explain what was 7 requested and what was received. That is not expert testimony 8 your Honor, that's chain of custody. 9 With regard to motion in limine number 5, evidence of 10 denials by Prince Andrew and Buckingham Palace. Again, your ide Honor, in a defamation case -- and I'm now quoting from 12 plaintiff's treatise that they cited throughout their response 13 and their reply -- excuse me -- "In defamation cases, 14 defendants can also prove that other liables and rumors about 5 the claimant are circulating, at least if they are widespread, 16 to demonstrate that it is not what the defendant said about the a plaintiff that causes her reputation to suffer but what others 18 said." 18 Plaintiff also cites Sack of Defamation. He supports 20 our position, your Honor. Here, we have a statement by Pal Buckingham Palace that was issued on the internet and widely 22 circulated. There is also a videotape of Prince Andrew denying 23 Virginia Roberts' claims. Both of those were far more 24 circulated than anything Ms. Maxwell said, as evidenced by the 25 fact that plaintiff can't even find Ms. Maxwell's statement on SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011353
February 7, 2026 at 1:02 AM