Epstein Secrets

Case 1:15-cv-07433-RWS Document 25 Filed 12/28/15 Page 1 of 13 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK Plaintiff, Ghislaine Maxwell, Defendant. Case No.: I5-cv-07433-RWS REPLY MEMORANDUM OF LAW IN SUPPORT OF DEFENDANT'S MOTION TO DISMISS COMPLAINT Laura A. Menninger HADDON,

INTRODUCTION ARGUMENT I. PLAINTIFF FAILED TO PLAUSIBLY PLEAD DEFAMATION A. Plaintiff Failed to Adequately Plead a Defamation Claim 1 B. Ms. Maxwell's Statement In Context Is Not Defamatory 3 II. MS. MAXWELL'S STATEMENTS ARE PROTECTED BY PRIVILEGE 6 A. Qualified Privilege May Form the Basis f

OR THE SOUTHERN DISTRICT OF NEW YORK Plaintiff, Ghislaine Maxwell, Defendant. Case No.: I5-cv-07433-RWS

ed to Adequately Plead a Defamation Claim 1 B. Ms. Maxwell's Statement In Context Is Not Defamatory 3 II.

aims regarding the accusers as "liars" who were financially motivated. Specifically, Boeheim stated inter alia "I believe they saw what happened at Penn State [a similar case of sex abuse], and they are using ESPN to get money." Id. The N.Y. Court of Appeals while reiterating that "general denials are not

927, In the 151st Judicial District Court of Harris County, Texas Law Firm: Arnold & Itkin LLP 2016 Deposition Report Plaintiff Plaintiff, v. GHISLAINE MAXWELL, Defendant. Case #: I :15-cv-07433 United States District Court Southern District of New York Law Firms: Boies Schiller & Flexner LLP and

16 Deposition Report Plaintiff Plaintiff, v. GHISLAINE MAXWELL, Defendant. Case #: I :15-cv-07433 United States

tion Report Plaintiff Plaintiff, v. GHISLAINE MAXWELL, Defendant. Case #: I :15-cv-07433 United States

ction (SBP15). Washington DC, p. 131-140. 31 Mar.-3 Apr. 26 EFTA00601602 Honors and Awards 2011 Teaching and Learning with Technology Fellow at Penn State (May 2011 - May 2012). Teaching research fellowship to develop subject-based learning apps that leverage cellular technology, the contextual (locat

eron *Ronald Crowley *Jeffrey Lehman Christine Maxwell EFTA_R1_01474945 EFTA02412966 *Brock Pierce

Rockefeller David Helfand, Astronomy, Columbia Bob Kirshner, Astronomy, Columbia EFTA_R1_01474943 EFTA02412964 Richard Alley. Climate Science, Penn State Eric Kandel, Neuroscience, Columbia Vilayanur Ramachandran, Neurology, UCSD Raold Hoffman, Chemistry , Cornell Shahid Naeem,Ecology, Columbia An

antine housing for students who get infected or exposed. Michigan State University will quarantine sick students in a 500-person "isolation dorm." Penn State will quarantine sick students at an on-campus hotel, while the University of North Carolina at Chapel Hill will convert two dorms — one for student

p's description of the coordinator of his coronavirus task force was magical: Videos of the day Stephen Colbert was confused by Trump's message to Ghislaine Maxwell: GJ Seth Meyers said Trump is trying to convince America that he suddenly cares about the virus: The Congressional Black Caucus hosted a special

bert was confused by Trump's message to Ghislaine Maxwell: GJ Seth Meyers said Trump is trying to convinc

tephen Colbert was confused by Trump's message to Ghislaine Maxwell: GJ Seth Meyers said Trump is trying to