Epstein Secrets

stituting fault as judged by, at a minimum, a negligence standard, and, it must either cause special harm or constitute defamation per se." 5 Under New York's choice-of-law rules for defamation actions, the general rule is that "the state of the plaintiff's domicile (in this case, Colorado) will usually ha

than does Colorado. Nonetheless, the laws of Colorado and New York are substantially similar. For these reasons, Ms. Maxwell asks the Court to apply New York law, but will note any differences between the two laws when applicable. 7 EFTA00595594 Case 1:15-cv-07433-RWS Document 15 Filed 12/01/15 Page 13

oot Camp, LLC, 813 F.Supp.2d 489, 550 (S.D.N.Y. 2011) 22 Sexier v. Warm/lash, P.C. v. Margrabe, 828 N.Y.S.2d 315 (1st Dep't 2007) 14 Shenkman v. O'Malley, 157 N.Y.S.2d 290, 297-98 (V' Dep't 1956) 8 Siegel v. Metropolitan Life Ins. Co., 32 N.Y.S.2d 658 (15` Dep't 1942) 8 Thai v. Cayre Group, Ltd., 7

ear-old Dominican national, is wanted on several federal weapons violations, a bureau spokeswoman said Monday. A reputed gang member, he has ties to New York and Pennsylvania." A federal judge in Newark, New Jersey "issued a warrant for Valerio's arrest last week after federal authorities charged him with

d evidence and witnesses' testimony to support the charges against the Ataligs. `These defendants betrayed the trust of the people of the CNMI; said O'Malley." Marianas Variety (8/24, Manabat) reports, "District Court for the NMI Chief Judge Ramona V. Manglona, for her part, told the jurors: `You heard e

SF and whether it has subject-matter jurisdiction over this action"). The Amended Complaint erroneously states that Jeffrey Epstein is a citizen of New York. 8 Lewis "reins 3059 Gt.** Avt Nur, Sum 340. Cooaaul Gaov1, Rama 33133 Sof 316 EFTA00234231 Case 9:08-cv-80804-KAM Document 1 Entered on FLS

indirect injuries, that is injuries sustained not as a direct result of predicate acts . . . will not allow recovery under Florida RICO."' (quoting O'Malley v. St. Thomas Univ., Inc., 599 So. 2d 999, 1000 (Fla. 3d DCA 1992))) (emphasis added). Because the Amended Complaint does not satisfy the direct-in

ear-old Dominican national, is wanted on several federal weapons violations, a bureau spokeswoman said Monday. A reputed gang member, he has ties to New York and Pennsylvania." A federal judge in Newark, New Jersey "issued a warrant for Valerio's arrest last week after federal authorities charged him with

evidence and witnesses' testimony to support the charges against the Ataligs. 'These defendants betrayed the trust of the people of the CNMI,' said O'Malley." Marianas Variety (8/24, Manabat) reports, "District Court for the NMI Chief Judge Ramona V. Manglona, for her part, told the jurors: 'You heard e

and whether it has subject-matter jurisdiction over this action"). ' The Amended Complaint erroneously states that Jeffrey Epstein is a citizen of New York. 8 Lewis Tsinn. 3059 Gum Mimic Sum 140, Cocoon Glow, Mow 33133 I of 316 EFTA00180414 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docke

indirect injuries, that is injuries sustained not as a direct result of predicate acts . . . will not allow recovery under Florida RICO."' (quoting O'Malley v. St. Thomas Univ., Inc., 599 So. 2d 999, 1000 (Fla. 3d DCA 1992))) (emphasis added). Because the Amended Complaint does not satisfy the direct-in

and whether it has subject-matter jurisdiction over this action"). 7 The Amended Complaint erroneously states that Jeffrey Epstein is a citizen of New York. 8 Lewis "rein n. 3059 GWID AVINUI. Sum 340, Comm QomItasca 33133 101319 EFTA00231020 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Dock

indirect injuries, that is injuries sustained not as a direct result of predicate acts . . . will not allow recovery under Florida RICO."' (quoting O'Malley v. St. Thomas Univ., Inc., 599 M. 2d 999, 1000 (Fla. 3d DCA 1992))) (emphasis added). Because the Amended Complaint does not satisfy the direct-inj

and whether it has subject-matter jurisdiction over this action"). 7 The Amended Complaint erroneously states that Jeffrey Epstein is a citizen of New York. 8 Lewin Teinn. 3010 Maw Ainsen,Sunt 340,Oxormart Coca, Flamm 31113 811319 EFTA00232140 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Do

'indirect injuries, that is injuries sustained not as a direct result of predicate acts . . wit! not allow recovery under Florida RICO."' (quoting O'Malley v. St. Univ., Inc., 599 So. 2d 999, 1000 (Fla. 3d DCA 1992))) (emphasis added). Because the Amended Complaint does not satisfy the direct-injury