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10 AEs i 12 13 14 LS 16 T7 18 19 20 21 22 23 24 25 Case 1:15-cv-07433-LAP Document 1325-18 Filed 01/04/24 Page 15 of 23 ‘a G1ETGIUA With respect to the allegations that we haven't pled properly libel per se, I want to be clear we pled that in two ways. And the case law is a case cited in the defendant's brief, and it's Jewell, and it does a very good job of parsing out the difference between slander and libel, and there is a difference in the case law, as your Honor knows. In the instance of libel, the written words, Cardozo has said, it stings, it stings longer, so therefore, in pleading libel per se, you don't have to plead special damages in the way that you do for slander. The Matherson case, which is out of New York, also articulates that. The difference, it says, quote, on the other hand, a plaintiff suing on libel need not plead or prove special damages if the defamatory statement tends to expose the plaintiff to public contempt, ridicule, aversion, or disgrace. And that is exactly what we have pled in this case, that the statements that our client lied about the sexual abuse she endured as a minor were statements that exposed her to that public contempt and ridicule. She has also pled libel per se with respect to her profession. While my colleague may make light of the fact that she is involved in helping victims that -- people who are victims of sexual trafficking, that is what she has dedicated her life to doing. And to come out and publicly proclaim her a liar about sexual abuse harms the nonprofit and harms the work SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300