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.

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

-Accusations; Alaska-Helicopter Crash; Eviction Ban; Biden-Vietnam Memorial. NBC: Chauvin Trial; COVID Update; CDC-Wuhan Report; Cuomo-Accusations; Ghislaine Maxwell; Tennessee-Floods; Border Crisis; Georgia-Election Laws; Suez Canal; COVID-Vacation Rentals; North Carolina-High School Football. Network TV At A G

"the charges contained in a rewritten indictment returned by a grand jury in Manhattan federal court alleged that a conspiracy between Epstein and Ghislaine Maxwell occurred between 1994 and 2004." The indictment "returned after Maxwell's July arrest limited crimes to a three-year period in the 1990s." Reuters

attan federal court alleged that a conspiracy between Epstein and Ghislaine Maxwell occurred between 1994 and 2004." The indictment "returned after Maxwell's July arrest limited crimes to a three-year period in the 1990s." Reuters (3/29, Stempel) reports that "it is unclear whether the new charges could

rivate Email Server. CRIMINAL INVESTIGATIONS • Ghislaine Maxwell Charged With Sex Trafficking In Expanded

s effectiveness, particularly in states like Virginia, where evictions continue due to loopholes and misinformation." EFTA00148306 The AP (3/29, Khalil, Casey) reports to be eligible for the protection, "renters must earn $198,000 annually or less for couples filing jointly, or $99,000 for single fi

/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

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.

one Data. In continuing coverage, Newsweek (1/5, Royston, 2.67M) reports an affidavit indicates that the FBI's Jeffrey Epstein investigation traced Ghislaine Maxwell "using her cell phone data and a fake mobile phone mast." Newsweek adds, "The FBI had already obtained a warrant for her GPS and location data on t

ion. • Continuing Coverage: FBI Traced Ghislaine Maxwell Using Cell Phone Data. • Continuing Coverage: Ba

Distribution. • Continuing Coverage: FBI Traced Ghislaine Maxwell Using Cell Phone Data. • Continuing Cove

5.69M). CRIMINAL INVESTIGATIONS Officials, Law Enforcement Prepare For Possible Violence As Trump Supports Flock To DC For Protests. The AP (1/5, Khalil, Balsamo) reports hundreds of supporters of President Trump gather in Washington, DC, "to cheer his baseless claims of election fraud a day before a

18-2868; 16-3945-cv(L) Brown v. Maxwell; Dershotvitz v. Giuffre 3n tlje Elute)) i§tateo Court of appeat55 for the i§ecortb Circuit AUGUST TERM 2018 No. 18-2868-cv JULIE BROWN, MIAMI H

tateo Court of appeat55 for the i§ecortb Circuit AUGUST TERM 2018 No. 18-2868-cv JULIE BROWN, MIAMI HERALD COMPANY, Intervenors-Appellants, v. GHISLAINE MAXWELL, Defendant-Appellee, v. VIRGINIA L. GIUFFRE, Plaintiff-Appellee. No. 16-3945-cv(L) No. 17-1625 (CON) No. 17-1722(CON) ALAN M. DERSHOW

ons. In response to the allegations, on January 3, 2015, Maxwell's publicist issued a press statement declaring that Giuffre's allegations "against Ghislaine Maxwell are untrue" and that her "claims are obvious lies. "6 B. Giuffre Sues Maxwell On September 21, 2015, Giuffre filed the underlying action against

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

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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

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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

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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