Lawyers for author E. Jean Carroll have asked a Manhattan federal judge to grant summary judgment on the merits ahead of her defamation trial against former President Donald Trump, arguing that “no reasonable juror” could find in Trump’s favor.

Carroll’s attorney Roberta Kaplan of Kaplan Hecker & Fink argued on Wednesday that because the first jury found that Trump was liable for sexually abusing Carroll and for defaming her in the course of denying her allegations, the doctrine of issue preclusion applies.