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

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

wn All Facilities Indefinitely. The AP <https://apnews.corn/article/politics-museums-coronavirus-pandemic- b4d260745c8312d4607559dc804dffec> (11/19, Khalil) reports, "In response to rising COVID-19 infection numbers, the Smithsonian Institution is indefinitely shutting down operations at all its facilit

s effectiveness, particularly in states like Virginia, where evictions continue due to loopholes and misinformation." EFTA00148306 The AP (3/29, Khalil, Casey) reports to be eligible for the protection, "renters must earn $198,000 annually or less for couples filing jointly, or $99,000 for single fi

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

take in-person classes provide written consent to receive a coronavirus test." Smithsonian Shuts Down All Facilities Indefinitely. The AP (11/19, Khalil) reports, "In response to rising COVID-19 infection numbers, the Smithsonian Institution is indefinitely shutting down operations at all its facilit

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

. history, passing John C. Calhoun's 31." HUD Withdraws Trump-Era Rule Restricting Transgender People's Access To Homeless Shelters. The AP (4/22, Khalil) reports HUD "is withdrawing a Trump-era policy that would have allowed taxpayer-funded homeless shelters to deny access to transgender people." HUD

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

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

unt, Gibson, Sorace), The Hill (11/25, Beitsch), NBC News (11/25, Reilly, Thorp V, et al.), Newsmax (11/25, Katz), EFTA00164106 NewsNation (11/25, Khalil, Noone), New York Post (11/25, King), New York Times (11/25, Jaffe), Newsweek (11/25, Silverman, Gooding), Politico (11/25, Wu), TMZ (11/25, Staff W

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.

News (11/25, Spunt, Gibson, Sorace), The Hill (11/25, Beitsch), NBC News (11/25, Reilly, Thorp V, et al.), Newsmax (11/25, Katz), NewsNatlon (11/25, Khalil, Noone), New York Post (11/25, King), New York Times (11/25, Jaffe), Newsweek (11/25, Silverman, Gooding), Politico (11/25, Wu), TMZ (11/25, Staff W

News (11/25, Spunt, Gibson, Sorace), The Hill (11/25, Beitsch), NBC News (11/25, Reilly, Thorp V, et al.), Newsmax (11/25, Katz), NewsNation (11/25, Khalil, Noone), New York Post (11/25, King), New York Times (11/25, Jaffe), Newsweek (11/25, Silverman, Gooding), Politico (11/25, Wu), TMZ (11/25, Staff

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

5, Lucas), USA TODAY (06/05, Wire, et al.), Axios (06/OS, Thompson), the Hill (06/OS, Suter), Newsweek (06/OS, Holliday, Keller), NEWSNATION (06/OS, Khalil, et al.), Fox News (06/05, Hagstrom, et al.), CNN (06/05, Lybrand, Cohen), Washington Post (06/05, Viser, et al.), NBC News (06/05, Doyle), and BBC

News (11/25, Spunt, Gibson, Sorace), The Hill (11/25, Beitsch), NBC News (11/25, Reilly, Thorp V, et al.), Newsmax (11/25, Katz), NewsNatlon (11/25, Khalil, Noone), New York Post (11/25, King), New York Times (11/25, Jaffe), Newsweek (11/25, Silverman, Gooding), Politico (11/25, Wu), TMZ (11/25, Staff W

take in-person classes provide written consent to receive a coronavirus test." Smithsonian Shuts Down All Facilities Indefinitely. The AP (11/19, Khalil) reports, "In response to rising COVID-19 infection numbers, the Smithsonian Institution is indefinitely shutting down operations at all its facilit

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

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