Epstein Secrets

PLY MEMORANDUM OF LAW IN SUPPORT OF DEFENDANT'S MOTION TO DISMISS COMPLAINT Laura A. Menninger HADDON, MORGAN AND FOREMAN, P.C. East 10th Avenue Denver, CO 80203 EFTA00591577 Case 1:15-cv-07433-RWS Document 25 Filed 12/28/15 Page 2 of 13 TABLE OF CONTENTS INTRODUCTION ARGUMENT I. PLAINTIFF FA

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

-TV <https://www.thedenverchannel.cornMews/crime/former-it-director-for-vail-arrested-on- embezzlement-charges-now-fugitive-after-cutting-off-device> Denver (11/15, 168K) reports that the FBI and local authorities are "looking for the former IT director for the Town of Vail after he cut off his GPS monit

otests. The AP <https://apnews.corn/article/election-2020-joe-biden-donald-trump-race-and-ethnicity-media- 2f5cfab681cr0bbee785fccla4209701> (11/15, Khalil, Freking) reports, "Demonstrations over President Donald Trump's loss at the polls have resulted in charges against nearly two dozen people in Washi

ave begun their own probes into the shooting." Denver Police Seized Guns Over Threats To Colorado's Attorney General. The AP (1/5, Slevin) reports Denver police seized the guns of Bryce Shelby, who "was under investigation by the FBI when he made plans with an undercover agent to shoot Attorney Gener

5.69M). CRIMINAL INVESTIGATIONS Officials, Law Enforcement Prepare For Possible Violence As Trump Supports Flock To DC For Protests. The AP (1/5, Khalil, Balsamo) reports hundreds of supporters of President Trump gather in Washington, DC, "to cheer his baseless claims of election fraud a day before a

murder." King had "pleaded guilty to the charges on Feb. 10," and he was sentenced to 97 months in prison. FBI Searching For Colorado Man. KMGH-TV Denver (11/15, 168K) reports that the FBI and local authorities are "looking for the former IT director for the Town of Vail after he cut off his GPS monit

n groups like Antifa because this isn't how society is supposed to wok." Nearly Two Dozen Arrested In Washington, DC Trump Protests. The AP (11/15, Khalil, Freking) reports, "Demonstrations over President Donald Trump's loss at the polls have resulted in charges against nearly two dozen people in Washi

ding to the article, the lawsuit centered on the media company's coverage of false vote-rigging claims in the 2020 U.S. election, which claimed that Denver-based Dominion's ballot-counting machines were used to manipulate the presidential election in favor of Democrat Joe Biden over Republican Donald T

district of Tennessee. Back to Top CYBER DIVISION D.C. Health Link Data Breach Blamed on Human Error EFTA00160439 The Associated Press (04/18, Khalil) reported that the recent data breach of personal information for thousands of users of Washington D.C's health insurance exchange, including member

murder." King had "pleaded guilty to the charges on Feb. 10," and he was sentenced to 97 months in prison. FBI Searching For Colorado Man. KMGH-TV Denver (11/15, 168K) reports that the FBI and local authorities are "looking for the former IT director for the Town of Vail after he cut off his GPS monit

n groups like Antifa because this isn't how society is supposed to wok." Nearly Two Dozen Arrested In Washington, DC Trump Protests. The AP (11/15, Khalil, Freking) reports, "Demonstrations over President Donald Trump's loss at the polls have resulted in charges against nearly two dozen people in Washi

November 30, 2015. Respectfully submitted, s/ Laura A. Menninger Laura A. Menninger, Esq. HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 Phone: Fax: Attorney for Ghislaine Maxwell CERTIFICATE OF SERVICE I certify that on November 30, 2015, I electronically filed this Ghi

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.

LLP, Miami, FL, for Intervenors-Appellants Julie Brown and Miami Herald. TY GEE (Adam Mueller, on the brief), Haddon, Morgan and Foreman, P.C., Denver, CO, for Defendant-Appellee Ghislaine Maxwell. 3 EFTA00092310 PAUL G. CASSELL (Sigrid S. McCawley, Boies Schiller Flexner LLP, Ft. Lauderdale,

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

appearance • Scammers Targeting Connecticut Doctors • Man Sentenced for Attempted Sexual Assault of Child in Colorado Human Trafficking Case • FBI Denver: Colorado Man Sentenced for Production of Child Porn • FBI Investigating Five Bank Robberies on the Same Day in the Milwaukee Area • Continued Repo

dentities confidential. Trayon White Expelled From the DC Council for Corruption but He's Free to Run for His Old Seat The Associated Press (02/04, Khalil) reported that the D.C. Council voted unanimously Tuesday to expel Councilmember Trayon White, who faces a federal trial on charges of taking tens o

murder." King had "pleaded guilty to the charges on Feb. 10," and he was sentenced to 97 months in prison. FBI Searching For Colorado Man. KMGH-TV Denver (11/15, 168K) reports that the FBI and local authorities are "looking for the former IT director for the Town of Vail after he cut off his GPS monit

n groups like Antifa because this isn't how society is supposed to wok." Nearly Two Dozen Arrested In Washington, DC Trump Protests. The AP (11/15, Khalil, Freking) reports, "Demonstrations over President Donald Trump's loss at the polls have resulted in charges against nearly two dozen people in Washi