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1 
that? 
2 
MR. PAGLIUCA: If we're limiting it to minors, which I 
3 
understand this to be limited to, I think that's fine. I mean, 
4 
we are talking about -- the allegation in this case is, 
5 
according to Ms. IM 
is that she was an underaged minor, 
6 
trafficked individual, and my client has vehemently denied that 
7 
in the press and here. And so that's the issue. And I think 
8 
if that's what we are talking about, we are fine with that. 
9 
MS. McCAWLEY: Your Honor, can I just clarify really 
10 
quickly? 
11 
There was trafficking of both underaged and women that 
12 
were over 18. So I wouldn't feel comfortable limiting it to 
13 
just the minors, under 18. 
14 
MR. PAGLIUCA: You can't traffic somebody --
15 
MS. McCAWLEY: You can prosecute someone over 
16 
international lines, and that is a federal offense if they 
17 
are --
18 
THE COURT: Let's --
19 
MR. PAGLIUCA: That's not the definition. 
20 
THE COURT: Let me -- if we skip the minors, what 
21 
would it be? It would be any 
yes, it would be any 
22 
MS. McCAWLEY: Females. 
23 
THE COURT: The documents relating to trafficking, 
24 
what for? 
25 
MS. McCAWLEY: Sexual trafficking or sexual abuse of 
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1 
any female. 
2 
THE COURT: That is OK. 
3 
MR. PAGLIUCA: To be clear, we talking about something 
4 
that is illegal, right? 
5 
THE COURT: Are we? I don't think it has to be 
6 
illegal in the context of the defamation. 
7 
MR. PAGLIUCA: Let me sort of recap, your Honor. 
8 
Because the defamation is that Ms. 
was a minor and from 
9 
1999 to 2002 somehow was, quote-unquote, sexually trafficked. 
10 
THE COURT: Your client's statement is that she was a 
11 
liar and -- I mean, I don't mean to prejudge that, but I mean 
12 
that's the issue as I understand it. 
13 
MR. PAGLIUCA: Well, and the Court narrowed this down 
14 
in the Court's order on the motion to dismiss, which is that 
15 
the statements relating to Ms. Maxwell's participation in the 
16 
trafficking of the plaintiff were untrue or unfounded. Those 
17 
are the statements. 
18 
THE COURT: OK. 
19 
MS. McCAWLEY: Yes. 
20 
THE COURT: Then I think it is conceivable that it 
21 
wouldn't be limited to minors. What I'm trying to say is if 
22 
there were trafficking other than with minors, that might also 
23 
be relevant to the existence of the practice. 
24 
MS. McCAWLEY: Exactly. 
25 
THE COURT: OK. So it isn't limited to minors. 
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MS. McCAWLEY: Thank you, your Honor. 
2 
THE COURT: Anything else? 
3 
MS. McCAWLEY: No, your Honor. I just wanted to have 
4 
an understanding, because maybe I'm not a quick study, but as 
5 
to what your ruling is with respect to the deposition? I 
6 
understand that I agreed to waive any --
7 
THE COURT: Where we are is the deposition is going 
8 
forward. If they want to come forward and seek to adjourn it, 
9 
I will hear it next Thursday. 
10 
MS. McCAWLEY: OK. So it is set for Friday. If they 
11 
come to you on Thursday, we argue about that? 
12 
THE COURT: Yes. 
13 
MS. McCAWLEY: But it is going forward on Friday? 
14 
THE COURT: Yes. 
15 
MS. McCAWLEY: Thank you, your Honor. 
16 
MS. MENNINGER: Your Honor, with respect to the 
17 
document responses and production that we received last night, 
18 
I would ask the Court for an expedited briefing schedule so 
19 
that can be heard next Thursday as well. 
20 
THE COURT: Sure. 
21 
MS. MENNINGER: Because I have looked at them and I 
22 
think that there are some very facially invalid 
23 
THE COURT: Sure. That is fine. 
24 
MS. MENNINGER: 
responses. 
25 
THE COURT: That is OK. 
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MS. MENNINGER: So I would ask your Honor -- it is 
2 
Thursday now -- I would ask, if I could, to file the motion --
3 
I mean, we're not going to have--
4 
THE COURT: By noon Wednesday? 
5 
MS. MENNINGER: By noon on Wednesday, and then we'll 
6 
be back to your Honor on Thursday. 
7 
THE COURT: Yes. 
8 
MS. McCAWLEY: Can I have it on Tuesday so I can 
9 
respond, or no? 
10 
THE COURT: Well, it's a short fuse. All right. I 
11 
would say by close of business -- if you make whatever you want 
12 
to do with that by the close of business on Tuesday instead of 
13 
noon Wednesday, that gives you -- I just cheated you out of --
14 
I did a good thing. I did a good thing. I permitted you to 
15 
have a nice night's sleep on Tuesday. 
16 
MS. MENNINGER: And, your Honor, I think if I heard 
17 
your Honor correctly, that if we had other issues with respect 
18 
to our client's deposition, we could raise those and have that 
19 
for next Thursday as well? 
20 
THE COURT: Yeah, but it's going to be -- yes. Sure. 
21 
Listen, I can't prevent lawyers from making mistakes -- or, 
22 
excuse me, making motions. So do whatever you --
23 
MS. MENNINGER: As much as you might like to. 
24 
THE COURT: So do whatever you want to do. 
25 
MS. MENNINGER: All right. Thank you, your Honor. 
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1 
THE COURT: Anything else? 
2 
MS. McCAWLEY: That's it, your Honor. Thank you. 
3 
THE COURT: Do you think the four of us are going to 
4 
survive this experience? 
5 
MS. McCAWLEY: I think so, your Honor. 
6 
THE COURT: Yeah? OK. Let's hope so. 
7 
8 
MS. McCAWLEY: Thank you, your Honor. 
THE COURT: Anything else? 
9 
MS. McCAWLEY: In a period of time. 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
MR. PAGLIUCA: Nothing further, your Honor. 
THE COURT: OK. Thanks. 
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