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10 17, 12 13 14 15 16 LT 18 Lg 20 21 22 23 24 25 Case 1:15-cv-07433-LAP Document 1325-18 Filed 01/04/24 Page 7 of 23 G1ETGIUA also argue that to the extent any of these sentence fragments can be pieced together, the statements, at most, are a general denial. In other words, plaintiff admits in the complaint that she started a media campaign against my client, she issued some very salacious allegations against my client in the British press and in some pleadings that she filed in Florida. And after having done that, my client, she says, issued a statement that the allegations are quote, unquote, untrue. Repeatedly, cases both in New York State and federal courts have found general denials are not actionable, that individuals have a right, when they have been accused of misdeeds in the press, to respond, so long as they don't abuse that privilege. And by abuse of privilege, that means including numerous defamatory extraneous statements about the person to whom they are responding and/or excessively publicizing their response. In this case, your Honor, the statement the allegations are untrue is about as plain vanilla as one can find. There's no better way to issue a general denial than to just say that the allegations are untrue, without more. There's not a single reference to plaintiff herself. Although, in opposition, plaintiff claims to have been called a liar, complains that she was called dishonest, she doesn't actually point to any statement which contains those words, nor any statement which actually refers to her as a SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300