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10 A, 12 13 14 15 16 17 18 139 20 aL 22 23 24 25 Case 1:15-cv-07433-LAP Document 1325-18 Filed 01/04/24 Page 21 of 23 an G1LETGIUA I think in the McNamee v. Clemens case there were some 27 exhibits attached to the amended complaint where Mr. Clemens had been on 60 Minutes and given statements to reporters and gone on at length calling the plaintiff in that case, Mr. McNamee, a liar, calling him a liar 25 ways to Sunday, talking about his financial motives, his potential financial gain, et cetera. Likewise, in the Davis v. Boeheim case, Mr. Boeheim gave a press conference in which he called the accusers liars. He questioned their financial incentives following the Sandusky case to be coming forward then, and he went on at length about all of the reasons why they might be coming forward now with their, quote, unquote lies. In each of those cases, McNamee v. Clemens and Davis v. Boeheim, the New York Court of Appeals, as well as the Federal Court in the Eastern District of New York, made clear that the one thing that is not actionable is a general denial. And then they talk about why Mr. Boeheim's comments and Mr. Clemens' comments went well beyond what anyone might consider a general denial. And fortunately, those cases actually had records which included the statements, included the articles in which the statements were made, so the Court could engage in the sort of analysis that it must, that is, to decide whether, in context, the statement has a defamatory meaning. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300