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and associates. Exh. A. DEFAMATION 27. On information and belief, on or about April 28, 2016, Defendant Trump provided the following statement to American Media, Inc. and/or Radar Online LLC for publication on at least their website RadarOnline.com regarding Plaintiff's complaint ED CV 16- 797-DMG (KSx) filed in t
of California. 2. Upon information and belief, Defendants Donald J. Trump and Jeffrey E. Epstein each reside in this District and are citizens of the State of New York. JURISDICTION AND VENUE 3. Plaintiff is a citizen of the State of California for purposes of diversity jurisdiction under 28 U.S.C. § 1332. 4.
and associates. Exh. A. DEFAMATION 27. On information and belief, on or about April 28, 2016, Defendant Trump provided the following statement to American Media, Inc. and/or Radar Online LLC for publication on at least their website RadarOnline.com regarding Plaintiff's complaint ED CV 16- 797-DMG (KSx) filed in t
of California. 2. Upon information and belief, Defendants Donald J. Trump and Jeffrey E. Epstein each reside in this District and are citizens of the State of New York. JURISDICTION AND VENUE 3. Plaintiff is a citizen of the State of California for purposes of diversity jurisdiction under 28 U.S.C. § 1332. 4.
state and local investigations, and twelve Congressional investigations.15421 Hush money payments During the 2016 presidential election campaign, American Media, Inc. (AMI), the parent company of the National En vi ker,l5411 and a company set up by Trump's attorney Michael Cohen paid flayboy model Karen McDougal
d the company that its use of the word "university" violated state law, its name was changed to Trump Entrepreneur Initiative in 20105151 In 2013, the State of New York filed a $40 million civil suit against Trump University, alleging that the company made false statements and defrauded consumers.(9111 In addition,
Entities connected to both American Media, Inc. and the State of New York

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
George W. Bush
PERSON
New York
LOCATIONJane Doe
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the United States District Court
ORGANIZATIONMaria Farmer
PERSON
Eric Trump
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Wilbur Ross
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Donald Trump
PERSONSecond Circuit
ORGANIZATIONSigrid McCawley
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David Boies
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Tiffany Trump
PERSONthe State of California
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Tiffany Doe
PERSONthe Central District
LOCATION
Thomas Francis Meagher
PERSONCullen v. Margiotta
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