Epstein Secrets

ecruitment of girls, including minors, for the purpose of sexual abuse. Plaintiff claims she was a minor when she was recruited by Defendant over to Jeffrey Epstein's house. Plaintiff further alleged that Defendant and Epstein commonly lured females to Jeffrey Epstein by telling them they would be paid for giving

Plaintiff claims she was a minor when she was recruited by Defendant over to Jeffrey Epstein's house. Plaintiff further alleged that Defendant and Epstein commonly lured females to Jeffrey Epstein by telling them they would be paid for giving a massage to Epstein; however, once at Epstein's house Plain

1-7364 Fax: 303-832-2628 [email protected] Jeffrey Pagliuca: Haddon Morgan and Foreman, P.C. 150 E

nce or actual malice, depending on the plaintiff's status; (4) falsity; (5) special damages or per se libel." February 27, 2016 Order at 6. See also McNamee v. Clemens, 762 F. Supp. 2d 584 (E.D. N.Y. 2011); Dillon v. City of New York, 261 A.D.2d 34 (1999). Ms. alleged that Defendant was involved with

ecruitment of girls, including minors, for the purpose of sexual abuse. Plaintiff claims she was a minor when she was recruited by Defendant over to Jeffrey Epstein's house. Plaintiff further alleged that Defendant and Epstein commonly lured females to Jeffrey Epstein by telling them they would be paid for giving

Plaintiff claims she was a minor when she was recruited by Defendant over to Jeffrey Epstein's house. Plaintiff further alleged that Defendant and Epstein commonly lured females to Jeffrey Epstein by telling them they would be paid for giving a massage to Epstein; however, once at Epstein's house Plain

l: Defendant's Trial Counsel: Laura Menninger: Jeffrey Pagliuca: Haddon, Morgan and Foreman, P.C. 150

nce or actual malice, depending on the plaintiff's status; (4) falsity; (5) special damages or per se libel." February 27, 2016 Order at 6. See also McNamee v. Clemens, 762 F. Supp. 2d 584 (E.D. N.Y. 2011); Dillon v. City of New York, 261 A.D.2d 34 (1999). Ms. alleged that Defendant was involved with

s federal civil actions in Florida. Compl. ¶ 8-21, 26-27. Ms. Maxwell was not a party to any of those litigations: not the criminal case against Mr. Epstein (Compl. ¶ 14), any non-prosecution agreement between Mr. Epstein and the U.S. Attorney's Office (Comp1.11 11-13), the litigation concerning the Cri

those litigations: not the criminal case against Mr. Epstein (Compl. ¶ 14), any non-prosecution agreement bet

rivilege and therefore is not actionable. Further, general denials such as the January 3 Statement are not actionable as defamatory statements. See McNamee v. Clemens, 762 F.Supp.2d 584, 601 (E.D.N.Y. 2011) ("general denials of accusations aren't actionable"); Independent Living Aids, Inc. v. Mau-Aids,