Epstein Secrets

him. Afterwards, Carlos Sires ("Sires"), a partner at the Firm's Fort Lauderdale office, emailed Dershowitz saying Jeffrey Epstein's compatriot, Ghislaine Maxwell. that Defendant had a "very strong appearance on the (Schiller Decl. Ex. I2 at ¶ 8). Today [S]how" and informing him, "If there is anythi

ards, Carlos Sires ("Sires"), a partner at the Firm's Fort Lauderdale office, emailed Dershowitz saying Jeffrey Epstein's compatriot, Ghislaine Maxwell. that Defendant had a "very strong appearance on the (Schiller Decl. Ex. I2 at ¶ 8). Today [S]how" and informing him, "If there is anything I Sir

his is a subject on which reasonable men may differ." Reynolds v. Pegler 223 F.2d at 433. In M. MtucwelMas she does here, alleged that defendant Ghislaine Maxwell's statements in that case were made "with malice and knowledge of their falsity." 165 F. Supp. 3d at 155. This was a sufficient pleading to defeat a

Court:] You argue at page 5 of your reply that if Ms. Maxwell's simple denials destroyed the plaintiffs reputa

ginal U.S. Government Works. 10 EFTA00100694 Dershowitz, 410 F.Supp.3d 564 (2019) qualified privilege in New York. 165 F. Supp. 3d at 155; cf. Liberman v. Gelstein 80 N.Y.2d 429, 438, 590 N.Y.S.2d 857, 605 N.E.2d 344 (N.Y. 1992). The New York Court of Appeals has defined constitutional malice as "

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.

for determining whether a statement concerning a plaintiffs 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,

/15 Page 1 of 29 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X PLAINTIFF, V. GHISLAINE MAXWELL, DEFENDANT. X 15-cv-07433-RWS GHISLAINE MAXWELL'S MEMORANDUM OF LAW IN SUPPORT OF MOTION TO DISMISS COMPLAINT Laura A. Menninger, Esq. HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Ave

r CO 80203 Tel: Dated: November 30, 2015 EFTA00595583 Case 1:15-cv-07433-RWS Document 15 Filed 12/01/15 Page 2 of 29 Table of Contents I. MS. MAXWELL'S STATEMENTS ARE PRIVILEGED 9 A. The Self-Defense Privilege Protects Ms. Maxwell's Statements 9 B. The Pre-Litigation Privilege Protects Ms. Maxw

attributed statement responds directly to allegations and claims made by Plaintiff. Compl. 1 31. Likewise to the extent the claimed statement that "Ghislaine Maxwell's original response to the lies and defamatory claims remains the same" (Compl. 1 32) refers to an earlier statement describing Plaintiff's "factual

led 12/01/15 Page 2 of 29 Table of Contents I. MS. MAXWELL'S STATEMENTS ARE PRIVILEGED 9 A. The Self-Defen

513, 516 (S.D.N.Y. 2003) 16, 21 Kirk v. Heppt, 532 F.Supp.2d 586 (S.D.N.Y. 2008) 14 Krepps v. Reiner, 588 F.Supp.2d 471, 483 (S.D.N.Y. 2008) 7 Liberman v. Gelstein, 80 N.Y.2d 429, 590 (N.Y. 1992) 22 McNamee v. Clemens, 762 F.Supp.2d 584, 601 (E.D.N.Y. 2011) 19 Mencher v. Chesley, 85 N.Y.S.2d 431