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.

egations of malice. Pl.'s Opp'n at 7-9. In any event, contrary state cases cited by Plaintiff contained more than conclusory allegations of malice. Karachi v. Weissman, 1 N.Y.S.3d 169, 182 (2d Dep't 2014) (complaint sufficiently alleged malice supported by statements undermining Rabbi's authority and st

d Of Child Sexual Assault. • Wisconsin Police Arrest Suspect For Shooting At Kenosha Bar • Florida Nurse Charged For Threatening To Kill Harris. • Maxwell Has To Stand Trial After Judge Turns Down Dismissal Request. • Family Of Tamir Rice Asks Garland To Reopen Probe Into Rice's Killing. • Medical Exp

elt horrible' after learning of Epstein's abuse of the criminal justice system in Florida. The disclosure...came in a 212-page filing responding to Ghislaine Maxwell's legal challenges to an indictment charging her with grooming underage Epstein victims in the mid-1990s and lying under oath." The Daily News "exclus

equest. flImmherg (4/16, Hurtado, 3.57M) reports Ghislaine Maxwell "must stand trial on sex-trafficking cha

companies and officials alleged to be operating on behalf of the Kremlin's intelligence services, one company stood out: the Fresh Air Farm House in Karachi, Pakistan." The Farm House "is run by 34-year-old Mohsin Raza, one of two founders of an online fake ID business that prosecutors say helped Russia

d Of Child Sexual Assault. • Wisconsin Police Arrest Suspect For Shooting At Kenosha Bar • Florida Nurse Charged For Threatening To Kill Harris. • Maxwell Has To Stand Trial After Judge Turns Down Dismissal Request. • Family Of Tamir Rice Asks Garland To Reopen Probe Into Rice's Killing. • Medical Exp

elt horrible' after learning of Epstein's abuse of the criminal justice system in Florida. The disclosure...came in a 212-page filing responding to Ghislaine Maxwell's legal challenges to an indictment charging her with grooming underage Epstein victims in the mid-1990s and lying under oath." The Daily News "exclu

equest. Bloomberg (4/16, Hurtado, 3.57M) reports Ghislaine Maxwell "must stand trial on sex- trafficking cha

fficials alleged to be operating on behalf of the Kremlin's EFTA00150664 intelligence services, one company stood out: the Fresh Air Farm House in Karachi, Pakistan." The Farm House "is run by 34-year-old Mohsin Raza, one of two founders of an online fake ID business that prosecutors say helped Russia