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ion in March 2011. Constitutionally protected opinion. The United States Constitution and the New York Constitution renders opinion nonactionable. United Kingdom's Defamation Act of 2013. Mr. Barden prepared the January 2015 statement in compliance with the Defamation Act. To the extent the Act applies in this
(4) falsity; (5) special damages or per se libel." February 27, 2016 Order at 6. See also McNamee v. Clemens, 762 F. Supp. 2d 584 (E.D. N.Y. 2011); Dillon v. City of New York, 261 A.D.2d 34 (1999). Ms. alleged that Defendant was involved with a man named Jeffrey Epstein in the recruitment of girls, including m
ion in March 2011. Constitutionally protected opinion. The United States Constitution and the New York Constitution renders opinion nonactionable. United Kingdom's Defamation Act of 2013. Mr. Barden prepared the January 2015 statement in compliance with the Defamation Act. To the extent the Act applies in this
(4) falsity; (5) special damages or per se libel." February 27, 2016 Order at 6. See also McNamee v. Clemens, 762 F. Supp. 2d 584 (E.D. N.Y. 2011); Dillon v. City of New York, 261 A.D.2d 34 (1999). Ms. alleged that Defendant was involved with a man named Jeffrey Epstein in the recruitment of girls, including m
ment 15 Filed 12/01/15 Page 6 of 29 INTRODUCTION The Plaintiff in this case falsely and maliciously launched a media campaign several years ago in the United Kingdom accusing Defendant Ghislaine Maxwell of serious and criminal sexual abuse from 1999-2002. Plaintiff repeated those allegations in litigation pleadi
provided in the Complaint. See Comp1.1 30. Her failure to provide the context within which the Statements were delivered alone warrants dismissal. Dillon v. City of New York, 261 A.D.2d 34, 39-40 (1st Dep't 1999) (plaintiff's failure to set forth the entirety of the alleged defamatory statement resulted in only
Entities connected to both United Kingdom and Dillon v. City of

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Prince Andrew
PERSON
George W. Bush
PERSON
New York
LOCATION
Virginia Giuffre
PERSON
Alan Dershowitz
PERSON
Bradley Edwards
PERSON
Wilbur Ross
PERSON
Colorado
LOCATIONMaria Farmer
PERSON
Denver
LOCATION
Alfredo Rodriguez
PERSON
Vicky Ward
PERSON
Paul Cassell
PERSON
Kenneth Marra
PERSON
David Boies
PERSON
Jean-Luc Brunel
PERSONJeffrey Pagliuca
PERSON