Epstein Secrets

10590 Tel: 914-763-8333 [email protected] Defoulanes [dal Counsel: Laura Menninger: Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver, CO 80203 Tel: 303-831-7364 Fax: 303-832-2628 [email protected] Jeffrey Pagliuca: Haddon Morgan and Foreman, P.C. 150 East 10th Avenue Den

(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

South Salem, NY 10590 Tel: Defendant's Trial Counsel: Laura Menninger: Jeffrey Pagliuca: Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver, CO 80203 Tel: Fax: Haddon Morgan and Foreman, P.C. 150 East 10th Avenue Denver, CO 80203 Tel: Fax: EFTA00617397 Ty Gee: Haddon, Morgan an

(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

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

uately identifies the purported communication, and an indication of who made the communication, when it was made, and to whom it was communicated"); Dillon v. City of N.Y., 261 A.D.2d 34, 39-40 (1st Dep't 1999) (dismissing defamation complaint for, among other things, failing to specify the actual defamatory word

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

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