Case 1:15-cv-07433-LAP Document 29 Filed 01/22/16 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X PLAINTIFF, DEFENDANT'S NOTICE OF SUPPLEMENTAL AUTHORITY GHISLAENE MAXWELL, 15-cv-07433-RWS V. DEFENDANT. • In further support of her Motion to Dismiss the Complaint, Defendant Ghislaine Maxwell, through her attorney Laura A. Menninger of the law firm Haddon, P.C., hereby respectfully submits the recent decision in and v. Cosby, 15 cv 1658 (W.D. Pa. January 21, 2016). In v. Cosby, the court dismissed, with prejudice, what it found to be a "very detailed and complete Complaint" alleging, among other things, that Cosby defamed an alleged sexual assault victim by issuing statements to the press describing the allegations against him as "unsubstantiated, fantastical stories...[that] have escalated far past the point of absurdity." (Ex. A at 8). Citing Gertz v. Robert Welch, Inc., 418 U.S. 323, 339 (1974), the court held that "[t]his sort of purely opnionated speech...is protected and not actionable as defamatory speech." Id. In dismissing the case, the court further noted that Cosby's public denial of the claims against him was a "legal position" that does not "lead to an inference that Plaintiff is a `liar and an extortionist."' Id. at 8, 12. In fact, the full text of each allegedly defamatory statement was set forth in the Complaint. (Ex. A at 8). EFTA02779089