Epstein Secrets

tiffs business, profession or trade is libelous per se follows the same rules, articulated in Liberman..., as the standard for slander per se." Id. Jewell v. NYP Holdings, Inc., 23 F.Supp.2d 348, 400 (S.D.N.Y 1998). In fact, addressing a libel claim, this Court specifically noted that "[d]efamation per

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

ee of drugs and violence."' WITI-TV <https://www.fox6now.cotn/news/law-enforcement-action-taken-on-drug-trafficking-organization> Milwaukee (11/19, Jewell, 159K) reports, "Officials noted just two milligrams of fentanyl is a lethal dose — and used a picture of a penny to illustrate just how little two

wn All Facilities Indefinitely. The AP <https://apnews.corn/article/politics-museums-coronavirus-pandemic- b4d260745c8312d4607559dc804dffec> (11/19, Khalil) reports, "In response to rising COVID-19 infection numbers, the Smithsonian Institution is indefinitely shutting down operations at all its facilit

al Gang Task Force in Racine will continue to work with our partners to keep our communities free of drugs and violence." WITI-TV Milwaukee (11/19, Jewell, 159K) reports, "Officials noted just two milligrams of fentanyl is a lethal dose - and used a picture of a penny to illustrate just how little two

take in-person classes provide written consent to receive a coronavirus test." Smithsonian Shuts Down All Facilities Indefinitely. The AP (11/19, Khalil) reports, "In response to rising COVID-19 infection numbers, the Smithsonian Institution is indefinitely shutting down operations at all its facilit

al Gang Task Force in Racine will continue to work with our partners to keep our communities free of drugs and violence." WITI-TV Milwaukee (11/19, Jewell, 159K) reports, "Officials noted just two milligrams of fentanyl is a lethal dose - and used a picture of a penny to illustrate just how little two

take in-person classes provide written consent to receive a coronavirus test." Smithsonian Shuts Down All Facilities Indefinitely. The AP (11/19, Khalil) reports, "In response to rising COVID-19 infection numbers, the Smithsonian Institution is indefinitely shutting down operations at all its facilit