Epstein Secrets

ey manager, told the teen he managed finances for Victoria's Secret and "Could get you into the catalog" if

(“Where a speaker exists . . . the protection afforded [by the First Amendment] is to the communication, to its source and to its recipients both.”); Pittman v. Cole, 267 F.3d 1269, 1283 n. 12 (11th Cir. 2001) (“The Supreme Court has recognized that the First Amendment offers protection to both speakers an

ey manager, told the teen he managed finances for Victoria's Secret and "could get you into the catalog" if

“Where a speaker exists . . . the protection afforded [by the First Amendment] is to the communication, to its source and to its recipients both.”); Pittman v. Cole, 267 F.3d 1269, 1283 n.12 (11th Cir. 2001) (“The Supreme Court has recognized that the First Amendment offers protection to both speakers a

- tious under New York law. Robinson, 269 F.3d at 142. In New York, conspiracy and aiding and abetting are varieties of con- certed action liability. Pittman v. Gray- son, 149 F.8d 111, 122 (@d Cir.1998). There must be “(1) an express or tacit agreement to ‘participate in a common plan or design to commit

CO is an unusually potent weapon . ‘courts should strive to flush out frivo- lous RICO allegations at an early stage of the litigation.’” Katzman v. Victoria’s Se- cret, 167 F.R.D. 649, 655 (S.D.N.Y.1996). [74] The Federal complaint asserts a RICO claim under § 1962(a), which states in part: “It shall be

may proceed with this claim. Wantanabe Realty Corp. v. City of New York, 01 Civ. 10187(LAK), 2003 WL 22862646, at *4 (S.D.N-Y. Dec. 3., 2003) (citing Pittman, 149 F.3d at 122-28). 8. Negligence [86-88] In New York, a plaintiff may establish negligent infliction of emotional distress under the bystander o