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xt of the entire article, [defendant's] remarks, calling [plaintiff] and others `liars' can only be understood as a denial of their accusations.")4; Porter v. Saar, 688 N.Y.S. 2d 137, 139 (1st Dep't 1999) ("The comments attributed to defendant...in the New York Post were in the nature of a general deni
age 12 of 13 right to seek redress at the repetition of such claims." Id. at 15; McCawley Decl., Ex. 3. New York's highest court stated recently in Khalil, 24 N.Y.3d at 720, such statements, made in anticipation of litigation, are protected by a qualified privilege unless the statements were made with
584 Case 1:15-cv-07433-RWS Document 25 Filed 12/28/15 Page 9 of 13 defamation complaints based on a qualified privilege. See, e.g., Front, Inc. v. Khalil, 24 N.Y.3d 713 (N.Y. 2015) (affirming motion to dismiss based on pre-litigation qualified privilege); Orenstein v. Figel, 677 F.Supp.2d 706, 722 (S
" The AP <https://apnews.corn/article/new-york-immigration-deferred-action-for- childhood-arrivals-program-6da7a068fd66722136fcl fd5eb82098b> (11/14, Porter) reports Garaufis wrote, "DHS failed to follow the order of succession as it was lawfully designated.... Therefore, the actions taken by purported
otests. The AP <https://apnews.corn/article/election-2020-joe-biden-donald-trump-race-and-ethnicity-media- 2f5cfab681cr0bbee785fccla4209701> (11/15, Khalil, Freking) reports, "Demonstrations over President Donald Trump's loss at the polls have resulted in charges against nearly two dozen people in Washi
ral hastily crafted administration moves designed to get people into the top DHS position outside of standard operating procedures." The AP (11/14, Porter) reports Garaufis wrote, "DHS failed to follow the order of succession as it was lawfully designated. ... Therefore, the actions taken by purported
n groups like Antifa because this isn't how society is supposed to wok." Nearly Two Dozen Arrested In Washington, DC Trump Protests. The AP (11/15, Khalil, Freking) reports, "Demonstrations over President Donald Trump's loss at the polls have resulted in charges against nearly two dozen people in Washi
ral hastily crafted administration moves designed to get people into the top DHS position outside of standard operating procedures." The AP (11/14, Porter) reports Garaufis wrote, "DHS failed to follow the order of succession as it was lawfully designated. ... Therefore, the actions taken by purported
n groups like Antifa because this isn't how society is supposed to wok." Nearly Two Dozen Arrested In Washington, DC Trump Protests. The AP (11/15, Khalil, Freking) reports, "Demonstrations over President Donald Trump's loss at the polls have resulted in charges against nearly two dozen people in Washi
869 ticket to Australia, according to a criminal complaint filed in Brooklyn federal court. The article added that Pham is accused of working with Porter and three other suspects who remain at large to defraud sports betting sites by placing bets on Porter's performance. Federal authorities say Porter
5, Lucas), USA TODAY (06/05, Wire, et al.), Axios (06/OS, Thompson), the Hill (06/OS, Suter), Newsweek (06/OS, Holliday, Keller), NEWSNATION (06/OS, Khalil, et al.), Fox News (06/05, Hagstrom, et al.), CNN (06/05, Lybrand, Cohen), Washington Post (06/05, Viser, et al.), NBC News (06/05, Doyle), and BBC
ral hastily crafted administration moves designed to get people into the top DHS position outside of standard operating procedures." The AP (11/14, Porter) reports Garaufis wrote, "DHS failed to follow the order of succession as it was lawfully designated. ... Therefore, the actions taken by purported
n groups like Antifa because this isn't how society is supposed to wok." Nearly Two Dozen Arrested In Washington, DC Trump Protests. The AP (11/15, Khalil, Freking) reports, "Demonstrations over President Donald Trump's loss at the polls have resulted in charges against nearly two dozen people in Washi
Entities connected to both Porter and Khalil

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Donald Trump
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Prince Andrew
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Prince Charles
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Department of Justice
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Virginia Giuffre
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George Mitchell
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Bloomberg L.P.
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George W. Bush
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Julie K. Brown
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Joe Biden
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Paul Ryan
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Michigan
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Barack Obama
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Scarlett Johansson
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Houston
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William Barr
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