…THE ACTION1 1. Ms. Maxwell denies the factual allegations and legal conclusions contained in Paragraph 1. JURISDICTION AND VENUE 2. Paragraph 2 contains legal conclusions for which no response is required. To the extent the Court determines a response is…
…before the court. Seeming to recognize this problem, 3 Tellingly, Defendant cites no case law – in any jurisdiction – to support the proposition that To the contrary, even rulings in the Southern District of New York hold the opposite, but …
…Protected Material; and (j) any other person by written agreement of the parties or by Order of a Court of competent jurisdiction.” Proposed subjection (h)(1) seems to apply to anyone who is the recipient of the Protected Material. Thus…
…1st Am. ed. Bigelow 1881). New York, along with numerous other jurisdictions6 and the Restatement (Second) of Torts, recognizes a qualified privilege to respond in self-defense to verbal defamatory attacks levied by another upon the speaker. See, e.g…