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ew salacious details about public figures." Even Judge Marra noted in his April 7 Order that Plaintiff's lates
ous lies" immediately follows the sentence: "Each time the story is retold it changes, with new salacious details about public figures." Even Judge Marra noted in his April 7 Order that Plaintiff's latest story involves Plaintiff's reference to Brach v. Congregation Yetev Lev D'Saimar, Inc., 696 N.Y.S
nse...which constituted an appropriate reaction by [defendant] to a situation which seemed to threaten his reputation." Id. at 1056-57. Here, as in Buckley, Ms. Maxwell's Statement was a "tempered and reasoned response" to Plaintiff's vicious character attacks. The Statement addressed only Plaintiff's a
s simply no factual basis alleged in the Complaint, in Plaintiff's Opposition, or certainly in the Statement itself to evidence such an intent. Cf. Buckley, supra at 1056 ("There is nothing in either the content or tone of the letter which could possibly suggest, as Vidal contends, that Buckley's intent
UTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE 1 AND JANE DOE 2, Petitioners, vs. U
ause that act is `fairly within the prosecutor's function as an advocate."' Mikko v. City of Atlanta, GA, 857 F.3d 1136, 1142 (10 Cir. 2017), citing Buckley v. Fitzsimmons 509 U.S. 259, 272-73 (1993). 3 EFTA00601684 Case 9:08-cv-80736-KAM Document 421 Entered on FLSD Docket 08/25/2017 Page 4 of 11 Re
UTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE 1 AND JANE DOE 2, Petitioners, vs. U
ause that act is `fairly within the prosecutor's function as an advocate."' Mikko v. City of Atlanta, GA, 857 F.3d 1136, 1142 (10 Cir. 2017), citing Buckley v. Fitzsimmons 509 U.S. 259, 272-73 (1993). 3 EFTA00799966 Case 9:08-cv-80736-KAM Document 421 Entered on FLSD Docket 08/25/2017 Page 4 of 11 Re
Entities connected to both Kenneth Marra and Buckley

Jeffrey Epstein
PERSONJane Doe
PERSON
Bradley Edwards
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Scarlett Johansson
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Paul Cassell
PERSONJack Goldberger
PERSON
A. Marie Villafana
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United States
LOCATION
Alan Dershowitz
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Alexander Acosta
PERSONthe Southern District
LOCATIONLeon Black
PERSON
George W. Bush
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Department of Justice
ORGANIZATIONMaria Farmer
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Prince Andrew
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Ghislaine Maxwell
PERSONFBI
ORGANIZATIONMartin Weinberg
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Dexter Lee
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