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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
25 ii EFTA00595584 Case 1:15-cv-07433-RWS Document 15 Filed 12/01/15 Page 3 of 29 Cases Abrams v. United States, 250 U.S. 616, 630 (1919) 17 Adelson v. Harris, 973 F. Supp.2d 467, 477 (S.D.N.Y. 2013) 7 Armstrong v. Simon & Schuster, Inc., 625 N.Y.S.2d 477 (1995) 7 Ashcroft v. lqbal, 129 S. Ct.
14 Let me turn then to point number 19. Here again, we 15 have a narrow issue presented to your Honor. We are asking 16 that you exclude Judge Marra's ruling on the joinder motion. 17 As your Honor is well aware, the triggering event in this case 18 was when Ms. then known as Jane Doe Number
o your Honor. We are asking 16 that you exclude Judge Marra's ruling on the joinder motion. 17 As your Hono
ork street 20 that, "I am referring to the statement that we made." As we 21 set forth in our summary judgment brief, this Court's ruling in 22 Adelson v. Harris is directly on point, that a mere reference 23 to another writing that contains defamatory statements does not 24 constitute an actiona
14 Let me turn then to point number 19. Here again, we 15 have a narrow issue presented to your Honor. We are asking 16 that you exclude Judge Marra's ruling on the joinder motion. 17 As your Honor is well aware, the triggering event in this case 18 was when Ms. , then known as Jane Doe Numbe
o your Honor. We are asking 16 that you exclude Judge Marra's ruling on the joinder motion. 17 As your Hono
t on a New York street that, "I am referring to the statement that we made." As we set forth in our summary judgment brief, this Court's ruling in Adelson v. Harris is directly on point, that a mere reference to another writing that contains defamatory statements does not constitute an actionable repe
you already. Let me turn then to point number 19. Here again, we have a narrow issue presented to your Honor. We are asking that you exclude Judge Marra's ruling on the joinder motion. As your Honor is well aware, the triggering event in this case was when Ms. Giuffre, then known as Jane Doe Number 3,
ed to your Honor. We are asking that you exclude Judge Marra's ruling on the joinder motion. As your Honor is
t on a New York street that, "I am referring to the statement that we made." As we set forth in our summary judgment brief, this Court's ruling in Adelson v. Harris is directly on point, that a mere reference to another writing that contains defamatory statements does not constitute an actionable repe
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al*, regaling the methodology used to determine the enema, of Volt and the date of the hfonnacon that Is Ow bass for the thane hyaena:6N Your ends Adelson - Shto parry estinated ones may be reflected as 'Net pnCedi n sena Mann ten an Merlinl valuation In, has not moped a d untie to assign a van when
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2 Total current year 30.57 $8.02 Prior year adjustment 0.00 1.93 Total dividend & interest 30.57 $9.95 Cash activity summary Your el nodal Adelson SCOTT STACK MANf LYLE CASRIEL See Account activity this month for details Balances In your Sweep Options are indudedin the °penny and closing bala
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Entities connected to both Kenneth Marra and Peter Mandelson

Jeffrey Epstein
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Scarlett Johansson
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
United States
LOCATION
Alan Dershowitz
PERSON
Alexander Acosta
PERSONLeon Black
PERSON
George W. Bush
PERSONthe Southern District
LOCATION
Prince Andrew
PERSON
Department of Justice
ORGANIZATION
Ghislaine Maxwell
PERSONMaria Farmer
PERSONSouthern District
LOCATION
Jay Lefkowitz
PERSONFBI
ORGANIZATIONMartin Weinberg
PERSON