Lord Justice Leveson referred to such things earlier in the week.

Based on this identification, Paul might also be referring to James earlier in the same letter:

It took her a second to realize he must be referring to her whispered words earlier.

And I referred to one of their predictions earlier.

She was referring to the snapshot their son had mailed from Nepal earlier in the year.

King did not refer directly to the brutal attack by state and local law officers just 18 days earlier.

I referred earlier, during my reply to Mr Hatzidakis, to training.

Its far-reaching consequences and the many interests involved have meant that this proposal has spawned quite a reaction, to which the Commissioner referred earlier.

Then there is the free trade agreement, to which I referred earlier.

My second comment refers back to the procedural incident earlier.