Epstein Secrets

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

ssed EFTA00591584 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 7

595585 Case 1:15-cv-07433-RWS Document 15 Filed 12/01/15 Page 4 of 29 Frechtman v. Gutterman, 979 N.Y.S.2d 58 (1st Dep't 2014) 14 Front, Inc. v. Khalil, 24 N.Y.3d 713, 720 (2015) 13 Fuji Photo Film U.S.A., Inc. v. McNulty, 669 F.Supp.2d 405 (S.D.N.Y. 2009) 8 Gertz v. Robert Welch, Inc., 418 U.S.

918) 8 EFTA00595585 Case 1:15-cv-07433-RWS Document 15 Filed 12/01/15 Page 4 of 29 Frechtman v. Gutterman, 979 N.Y.S.2d 58 (1st Dep't 2014) 14 Front, Inc. v. Khalil, 24 N.Y.3d 713, 720 (2015) 13 Fuji Photo Film U.S.A., Inc. v. McNulty, 669 F.Supp.2d 405 (S.D.N.Y. 2009) 8 Gertz v. Robert Welch, Inc.,

additional credibility, in fact, allegations appearing in such documents might be less credible than those published elsewhere" 46 Front, Inc. v. Khalil, 24 N.Y.3d 713, 718 (2015); see also Kelly v. Albarino, 485 F.3d 664, 666 (2d Cir. 2007) (adopting the reasoning of the District Court explaining t

d that document additional credibility, in fact, allegations appearing in such documents might be less credible than those published elsewhere" 46 Front, Inc. v. Khalil, 24 N.Y.3d 713, 718 (2015); see also Kelly v. Albarino, 485 F.3d 664, 666 (2d Cir. 2007) (adopting the reasoning of the District Court exp