Epstein Secrets

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

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

foreign presidents, a well-known Prime Minister, and other world leaders." Menninger Decl. Ex. C at 4-5. On April 7, 2015, U.S. District Court Judge Marra denied Plaintiff's Joinder Motion, ordered the portions of the Joinder Motion pertaining to non-parties Although the Complaint does not explicitly

. C at 4-5. On April 7, 2015, U.S. District Court Judge Marra denied Plaintiff's Joinder Motion, ordered the p

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.

omitted). 6 EFTA00092313 defense or any redundant, immaterial, impertinent, or scandalous matter . . . on its own,"4 the Florida District Court (Kenneth A. Marra, Judge) .51112 sponte struck all allegations against additional parties from the pleadings, including those against Dershowitz, and therefore deni

its own,"4 the Florida District Court (Kenneth A. Marra, Judge) .51112 sponte struck all allegations aga

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