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aintiff's spurious claims. Plaintiff's allegations of sexual abuse extend beyond just Ms. Maxwell and encompass many notable public figures, such as Prince Andrew and Harvard Law Professor Alan Dershowitz, as well as un-named "numerous American politicians, powerful business executives, foreign presidents, a w
pass many notable public figures, such as Prince Andrew and Harvard Law Professor Alan Dershowitz, as wel
ession and a particular disreputable vice of that profession." Id. While explaining defamation per se, this Court quoted the following passage from Prosser and Keeton on the Law of Torts § 112, at 791 (5th ed. 1984): 21 EFTA00595608 Case 1:15-cv-07433-RWS Document 15 Filed 12/01/15 Page 27 of 29 [I]
to comply in a reasonable manner. COUNSEL: rli ANDREW L. CAPDEVILLE, Eso., Law Offices of Andrew Capdev
L DB-SONY-0020020 EFTA 00167764 EFTA01295861 Page 2 2012 U.S. Dist. LEXIS 93633, * PRIOR HISTORY: Carroll v. N. Shore Real Estate Corp. (In re Prosser), 2010 Bankr. LEXIS 1566 (Bankr. D.V.I., May 26, 2010) CASE SUMMARY: OVERVIEW: Appellant filed a notice of appeal from a decision of the bankruptc
to comply in a reasonable manner. COUNSEL: rli ANDREW L. CAPDEVILLE, Eso., Law Offices of Andrew Capdev
Islands, St. Thomas and St. John Division 2012 U.S. Dist. LEXIS 79534 June 6, 2012, Decided June 6, 2012, Filed SUBSEQUENT HISTORY: Affirmed by Prosser v. Carroll (In re Prosser), 2013 U.S. App. LEXIS 15853 (3d Cir. V.I., Aug. 1, 2013) For internal use only SDNY_GM_00059974 CONFIDENTIAL - PURSUAN
Entities connected to both Prince Andrew and Prosser

Jeffrey Epstein
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Woody Allen
PERSON
Bradley Edwards
PERSON
Prince Charles
PERSON
John F. Kennedy
PERSON
Eric Trump
PERSON
Harvey Weinstein
PERSON
Denver
LOCATION
Kenneth Marra
PERSON
Samantha Power
PERSON
Sarah Ferguson
PERSON
U.S. Virgin Islands
LOCATION
Supreme Court
ORGANIZATIONGarcia
PERSONHaley Robson
PERSON
Fidelity
ORGANIZATION
JPMorgan Chase
ORGANIZATION
United States District Court
ORGANIZATION