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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
ssed EFTA00591584 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 7
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
918) 8 EFTA00595585 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.,
m a pleading an insufficient defense or any redundant, immaterial, impertinent, or scandalous matter ... on its own,"" the Florida District Court (Kenneth A. Marra, Judge) sua sponte struck all allegations against additional parties from the pleadings, including those against Dershowitz, and therefore deni
s own,"" the Florida District Court (Kenneth A. Marra, Judge) sua sponte struck all allegations agains
hat document additional credibility, in fact, allegations appearing in such documents might be less credible than those published elsewhere.J9 46 Front, Inc. V. Khalil, 24 N.Y.3d 713, 718, 4 N.Y.S.3d 581, 28 N.E.3d 15 (2015); see also Kelly v. Albarino, 485 F.3d 664, 666 (2d Cir. 2007) (adopting the rea
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
d that document 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 exp
Entities connected to both Kenneth Marra and Front, Inc.

Jeffrey Epstein
PERSONJane Doe
PERSON
Paul Cassell
PERSON
Alan Dershowitz
PERSONthe Southern District
LOCATION
George W. Bush
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Virginia Giuffre
PERSON
the United States District Court
ORGANIZATION
Southern District of New York
ORGANIZATION
Julie K. Brown
PERSON
New York
LOCATION
Alfredo Rodriguez
PERSON
David Boies
PERSON
Cynthia Nixon
PERSONSigrid McCawley
PERSONSecond Circuit
ORGANIZATIONTwombly
PERSON
Denver
LOCATION