Epstein's “Girlfriend” Rina Oh sues Whistleblower Virginia Giuffre

Artist Rina Oh is suing in New York Jeffrey Epstein survivor Virginia Roberts Giuffre for defamation.
Here we narrate the first three important documents filed on the court docket so far.

The first is Oh's amended complaint, Document 7, then Ms Giuffre's answer and counterclaims, document 23, followed by Oh's Amended answer to Defendant Counterclaim, document 29.

Keep up to date with the latest twists and turns in this Epstein investigation with The Prince and the Pervert Podcast.https://jeffreyepsteinpodcast.com/ [https://jeffreyepsteinpodcast.com/]

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Episode Transcript

(00:00):
A global criminal conspiracy, a prince, a jailed social aide, and a
billionaire who may or may not havebeen murdered. Welcome to the world of
the Jeffrey Epstein, The Prince andthe Pervert. Podcast Journalists Lisa and Jan
bring you the ultimate deep dive.Let's have a look at the Rena O

(00:21):
v. Virginia Guffrey civil defamation suit. Now, Rina Oh, she's an
artist. Her married name is RenaAmen. She was the woman the Virginia
Guffra allegers took her shopping for aschoolgirl outfit in New York. Rena was

(00:42):
discovered during the recording of the Brokenpodcast and Tara Palmelly went to speak to
her. Rena claims on the Brokenpodcast, declared herself Epstein's girlfriend at the
time. If you haven't listened tothe podcast series, I suggest you download

(01:03):
it and listen. It's brilliant.As we've described on several episodes, there's
been a lot of interaction between Renaand Virginia on social media, but if
you listen to our last few episodesyou'll hear all about that. But on
October twenty eight last year, Renafiled in the Southern District of New York

(01:23):
for defamation. The first file onthe docket is a filing error, deficient
pleading signature error complaint against Virginia Dufray, And interestingly enough, it shows that
the filing fee for this case wasfour hundred and two dollars. Then there's
a whole list of documents listed aboutwho was assigned to it, which is

(01:45):
Judge Naomi Reese Buckwald, apologies ifI've got that wrong, and about modifications,
summons requests, more filing errors,corporate disclosure statements, and the original
first complaint against Virginia was filed byRina on November first. On January fourth,

(02:07):
Rena then filed a first amended complaintagainst Virginia with a jury demand.
On May seven, Virginia filed onthe docket a counterclaim and answer to the
amended complaint, and on June seventh, Rena posted an amended answer to Virginia's

(02:29):
counterclaim. So I'm not going toread the initial claim that Rena put in.
These are many pages long, thesedocuments, so I'm going to read
her first amended complaint. I'll thenread out the counterclaim and answer that was
lodged by Virginia and then Marina's amendedanswer to Virginia's counterclaim. I'll be reading

(02:53):
this verbatim. When it comes tothe tweets, I won't read out the
at Virginia vs. I'll just startthe tweet off with quote and then read
the tweet. Occasionally there is adifferent word they when it should be a
there. But I'm going to readverbatim, So if it sounds a bit

(03:14):
clunky, that's what's going on.The lawyer representing Rena oh Amen is a
bloke called Ira Scott Mayor Wits.It's interesting how they managed to find him.
Rena's husband, Vincent Amen, wasone of Michael Jackson's personal assistants and

(03:37):
was a witness in the court caseagainst Michael Jackson. Now, Ira was
a lawyer who took on the Jacksonestate. He didn't win that case,
but it's interesting the links between Vincent, Michael Jackson, and this lawyer who
previously sued the Jackson estate. Virginiadufra Is. Lawyer in this case is

(04:01):
Kathleen Thomas at Thomas Counselor at Law, l LC Document twelve filed January four,
two thousand and twenty two. Firstamended Complaint plaintive Rena O n Ka

(04:25):
Rena O Amen plaintiff by her attorneys, the Mayowitz Law Firm, as and
for her amended complaint against defendant VirginiaL. Guffray defendant alleges as follows the
parties. One. Plaintiff, RenaO n Ka Rena O Amen, is

(04:47):
an individual who was and is acitizen of the State of New Jersey,
United States. Defendant Virginia L.Gufrey is an individual was and is a
citizen of the state of Colorado,United States. Jurisdiction and venue. This

(05:08):
Court has subject matter ie diversity jurisdictionover this action pursuant to twenty eight Usc.
One three three two A two,as the amount in controversy exceeds the
sum or value of seventy five thousand, exclusive of interest and costs, and

(05:30):
this controversy is between citizens of differentstates. For this Court has personal jurisdiction
over defendant pursuant to New York's longArm Statue nycpl R three O two A,
as defendant has committed the tortuous actionscomplained of herein in this state by

(05:53):
making the defamatory statements related to plaintiffherein that We're published in this state on
her Twitter account and other platforms andpublishing outlets. Defendant has also availed herself
of the jurisdiction and use of thiscourt in commencing an action on August nine,
twenty twenty one, in the matterentitled Virginia Dufrey v. Prince Andrew,

(06:18):
United States District Court, Southern Districtof New York. Five Venue is
proper pursuant to twenty eight Usc.One three nine one for similar reasons to
this Court having personal jurisdiction over Defendanton the grounds that, among other reasons,
including but not limited to that one, a substantial part of the events

(06:43):
and or wrongful conduct that give riseto the claims alleged herein occurred in this
district ie, amongst other reasons,the publishing and dissemination of plaintiffs defamatory statements.
Two Plaintiffs suffered the effects and damagesof Defendant's defamatory statements in this venue,

(07:04):
and three Defendant has availed herself ofthe use of this court as set
forth above factual allegations. Six.Today, plaintiff is married and a respected
and well regarded artist. Seven.However, twenty years ago, during some

(07:26):
or all of the years two thousandand two thousand and one, starting when
plaintiff was only around twenty one yearsold, plaintiff was solicited, manipulated,
exploited, abused, and sex trafficby the notorious Jeffrey Epstein in Brackett's Epstein
and his co conspirators Galaine Maxwell inBrackett's Maxwell and Others. Eight. Defendant

(07:55):
new or should have known that atall relevant times, plaintiff was a young
victim of Epstein and not a coconspirator of Epstein or a part of his
inner circle of criminals, as concludedby the authorities, including the FBI.
Nine Defendant knew or should have knownthat, just as defendant claims purportedly happened

(08:20):
to her, at all times,plaintiff was being abused, exploited, and
manipulated by Epstein and his inner circle. Ten. During that time in two
thousand and two thousand and one,plaintiff was introduced by Epstein or Maxwell.
Two. Defendant, and Plaintiff anddefendant spoke and saw each other on only

(08:43):
a few occasions in Palm Beach,Florida, and few occasions in New York.
Eleven. On no occasion did plaintiffsexually abuse or assault defendant or cut
defendant, and defendant knows this tobe true. Twelve. In the last

(09:05):
twenty years since defendant and plaintiff lastsaw each other in two thousand and one,
Defendant has never accused plaintiff of anybad or criminal acts from that time.
Thirteen. However, recently, Defendantbegan falsely and wrongly defaming and slandering
plaintiff on numerous occasions. Fourteen.For instance, Defendant maintains a Twitter account

(09:31):
under the handle an account name Virginiadue Free at url Twitter dot com vrs
Virginia fifteen. On October twenty eighththrough October thirty first and December thirty feet
of twenty twenty, amongst other times, by and through her Twitter account,

(09:54):
Defendant wrote certain tweets, and thenby hitting send, Defendant blished and broadcast
those tweets out to the world.Sixteen. The full going tweets, amongst
others, with time stamps when Defendantpublished them, contain the following statements of
fact the defendant knew or should haveknown to be false. A Virginia du

(10:18):
fray at vs Virginia quote. Ladiesand Gentlemen meet Rena who is now pleading
innocence. Since there's a dollar signedVCF dollar sign, she has decided to
come out as a victim when onthe record she was Epstein's girlfriend and was
rewarded with dollar dollar in trade forvictims, real victims. May karma be

(10:43):
upheld and justice be done at FBIat New York Times, published nine twenty
four pm October twenty eight, twentytwenty. Twitter for iPhone B Virginia Dufrey
October twenty eight, twenty twenty.Quote Rena, if you read this,

(11:05):
I hope you live in shame forthe rest of your life. You don't
intimidate me any longer, and thephysical and mental scars you left me with
should be enough to put your Adot dot in jail. My line in
the sand is drawn and you're guilty. Hashtag lock her up seven oh three

(11:28):
pm October twenty eight, twenty twenty. See Virginia Dufrey, October twenty eighth,
twenty twenty. Quote Jeffrey Epstein recruiteradmdspringing girls but denies abuse. Pathetic
excuses from a deranged woman who wasno victim and should be sitting in jail

(11:52):
next to Galaine Maxwell. Rena womanto woman. Now I am a woman.
You disgust me at Daily Mail seventwenty one pm October twenty eight,
twenty twenty d October twenty eight quote. What really makes sense is that Rina,

(12:13):
a co conspirator for Epstein and GelainMaxwell, would go on to marry
a fellow co conspirator involved with MichaelJackson two six pas in a pod.
You can't even imagine how beyond sickenedI feel right now at Pink Peptoe Bismo

(12:33):
at Teresa J. Helm seven tofifty nine pm, October twenty eight,
twenty twenty e October twenty eighth quote. This picture that Rina painted with the
sliced leg bleeding is exactly what sheused to do to me. I have
a six inch scar on my leftleg from her cutting me. I can

(12:58):
let a lot of st dot Tgo, but this I will never forget.
Hashtag pure evil, hashtag lock herup at FBI, at The Daily
Beast, at New York Times hashtagjustice eight o nine pm, October twenty

(13:20):
eight, Virginia Dufrey, October twentyeight quote, still being robbed of justice.
Just ask all the men and womenI've named in my court docs why
they still have their freedom to carryon with their untainted lives. Why I

(13:41):
sit here crying my eyes out overrerun and rerun of the abusers still affecting
my life at FBI at sdmy newshashtag unfair eight thirty four pm October twenty
eight Ge Virginia Dufrey October twenty eightquote design from two thousand, two thousand

(14:09):
and two and classically trained in sculptureRena. Those were the years in which
you procured and partook in the abuseof minors with Epstein. Did he pay
for that too? You're no survivor. You're an oxygen thief, a virus
on humanity. Hashtag karma hashtag justicenine thirteen pm October twenty eight, seventeen.

(14:39):
Then defendant continue to publicly defame andshame plaintive on December thirty first,
twenty twenty by and through her Twitteraccount, where defendant tweeted and or retweeted
the following falseholds to the world aVirginia Dufrey quote. The only issues I

(15:01):
have, Vincent, is your sick, pathetic, psychopathic wife and the other
Epstein women who take advantage of youngvictim. My credibility is full proof,
and the people that know me knowthat. Good luck with your spear campaign.
Though, December thirty first, twentytwenty b Virjunior du Frey retweeted a

(15:26):
tweet with a picture of an Asianbaby holding money brackets plaintiff is Asian clothes
brackets and stating the plaintiff quote onlycame forward after Epstein was already dead.
I'm starting to think they both bracketsreferring to plaintiff and her husband clothes brackets

(15:50):
are here just for the Benjamin's Decemberthirty first, twenty twenty eighteen. All
of the full statements are and weremaliciously false, and defendant knew them to
be false when she published them.Nineteen. Plaintiff did not do or say

(16:12):
the things that defendant accuses her inthese tweets. Plaintiff is and always was
a victim and not a co conspiratorof Epstein and his gang. Plaintiff never
cut, sexually assaulted, or sexuallyabused defendant. Plaintiff was and is guilty

(16:36):
of no crime and has never beencharged with one. Twenty. Considering the
high profile nature of the Jeffrey Epstein, Gallaine Maxwell, and Prince Andrew's story,
defendant knew that accusing Plaintiff a fellowvictim of such horrible things that it
would maximize the spread and harm anddamn to plaintiff, therefore making it more

(17:03):
malicious and damaging. The defendant hasmaliciously reiterated and republished these defamations and slanders
in prior and subsequent tweets and interviewson podcasts, TV, and for magazines,
as well as in her memoirs entitledBillionaires Playboy Club twenty two. These

(17:29):
defamations and slanders by defendant are causingplaintiff great harm. Twenty three. Plaintiff
commences this action against defendant to stopdefendant from continuing to spew here false and
defamatory bile, and to hold defendantaccountable for the damages she has knowingly calls

(17:52):
plaintiff first course of action defamation.Twenty four. Plaintiff here by repeats and
re alleges the allegation state above asif fully fourth herein twenty five, as
set forth in detail above and herein, Defendant wrote and spoke certain statements of

(18:15):
fact that she knew or should haveknown, were false, and indeed were
said by defendant with knowledge and maliciousdisregard for the truth. Twenty six said
defamatory statements were created, written,spoken, published, and broadcast by defendant,

(18:36):
amongst other places, on her Twitteraccount and through a podcast for third
parties and all the world to readSee and Here twenty seven. Said defamatory
statements by a defendant were then pickedup by major news organizations like The New
York Post, Vogue, and DailyBeast as defendant knew they would, and

(19:00):
republished throughout the world news media,TV, and the Worldwide Web. Twenty
eight. Though these statements are false, and even when plaintiff prevails herein,
they will never die and will livein the Internet forever, forever, causing
plaintive injury twenty nine. Defending hadno privilege, absolute, qualified, or

(19:25):
otherwise to make said defamatory statements.Privilege thirty Defendants defamatory statements directly and approximately
cause plaintiff to suffer compensatory damages relatedto both economic and noneconomic damages, including,
but not limited to the following lossof earnings and income, loss of

(19:52):
business and contracts, loss of businessand economic opportunities, damages to plaintiff's name,
reputation and character, and business andstanding in the community, as well
as for pain and suffering humiliation,shame, disgrace, mental anguish, loss
of enjoyment of life, and anxietyand extreme emotional distress, amongst other things.

(20:21):
Thirty one. By this amended complaint, Plaintiff amended the initial complaint herein
to add the defamatory statements made bydefendant alleged and set forth in paragraph seventeen
above, for the purposes of thestatute of limitation and pursuant to f RCP

(20:42):
Rule fifteen C. Said statements relateback to the date of the other statements
made by plaintiff in her initial complaint, in that they involved the parties and
arose out of conduct set out inthe initial complaint herein thirty two. Accordingly,

(21:03):
for all the foregoing reasons, plaintiffis entitled to an award of compensatory
damages in an amount to be determinedat the trial, but in no event
less than ten million dollars. Thirtythree. In light of the malicious,
intentional, and or will fill natureof Defendant's actions, plaintif is entitled to

(21:29):
punitive damages in an amount to bedetermined at trial, but believed to be
an excess of ten million dollars.Demand for jury trial plaintiff hereby demands a
jury trial as provided by Rule thirtyeight A of the Federal Rules of Civil
Procedure. Prayer for relief. Whereforeplaintiff praise for relief on the counts stated

(21:57):
above as against defend as follows onthe first course, that plaintiff be awarded
compensatory damages in an amount to bedetermined at trial and which is otherwise incalculable
at this time but is not lessthan ten million dollars. B on the

(22:19):
first course of action, that plaintiffbe awarded punitive damages in an amount to
be determined at trial, but inno event less than ten million dollars.
CE, That plaintiff be awarded itsattorney fees and costs under statutory and common
law. D that plaintiff be awardedpre and host judgment, interest, cost

(22:47):
and disimbursements. And E that plaintiffbe awarded all other and further relief as
the Court may deem just and proper. Date January fourth, twenty twenty two,
New York, New York, mayowitslaw firm, signed by Ira Scott

(23:08):
Mayowitz, attorneys for plaintive rena oAmen Document twenty three filed May seventh by
Virginia Dufray's team Defendant Virginia L.Guffray herein Defendant or Miss Guffrey answers plaintive

(23:30):
Rena O n KA Rena O amensherein after plaintiff or Miss O amended complaint
and further counterclaims by and through herattorney Thomas Counselors at Law L l C.
As follows introduction one, Miss Geufraydoes not defame Misso to the country.

(24:00):
Miss Geuffray's statements an issue in missO's underlining defamation action are true statements
and protected opinions. In particular,miss O was never a victim of Jeffrey
Epstein's sex trafficking organization. To thecontrary, miss O, who has admitted

(24:23):
meeting Jeffrey Epstein when she was twentyone years old, has publicly described herself
as Jeffrey Epstein's girlfriend. She hascalled Epstein her older, rich boyfriend.
Two. Further, the opinions formedand stated by Miss Guffrey, as outlined

(24:45):
in miss O's amended complaint sixteen toseventeen, were in response to misstatements publicly
made by miss O, a publicfigure at the time that the moments were
made that miss O was never anabuser and never sexually or physically assaulted Miss

(25:07):
Guffray. That is false. Three. Miss Guffrey was the victim of sado
massochistic sexual and physical abuse perpetrated againsther by Misso, including cutting, slashing,
and other physical injuries during the sadomassochistic sessions that have left Miss Guffrey

(25:33):
with permanent emotional and physical scars.Or miss O has admitted publicly that she
brought three women to Jeffrey Epstein's NewYork mansion for his sexual purposes. Five.
Miss O has emitted publicly that,as directed by Epstein, she took

(25:55):
Miss Guffray Brackets, who was seventeenat the time, close Brackets shopping on
St. Mark's Place for a sexyschoolgirl outfit after Epstein called her miss O
and said you would know where togo, take her there. Six.

(26:17):
While she was Epstein's girlfriend, missO physically and sexually abused Miss Dufray for
Epstein's pleasure. Seven. While missO previously described herself as Epstein's girlfriend,
when an opportunity to profit presented itself, she changed her description from being Epstein's

(26:40):
girlfriend to being his victim. Bysuch fraudulent misrepresentations, miss O was able
to obtain money from the Epstein victim'scompensation fund. Eight later, when miss
O saw an opportunity to try andextract money from Miss Guffrey, miss O

(27:03):
sued Miss Guffray for defamation for tenmillion. Nine. New York has given
Miss Guffray a substantive right to recoverdamages and attorney fees against MISSO because miss
O's lawsuit against Miss Guffrey is anattempt burden Miss Guffray's exercise of her constitutional

(27:27):
rights to free speech. Ten.Miss Guffray now files her answer and counterclaim
in order to protect her constitutional rightsto free speech and to further protect against
miss o's false claims and improper abuseof this country's judicial system. Answer and

(27:52):
Incorporated Counterclaim Parties One. Miss Guffrayis without knowledge or information sufficient to form
a belief as to the plaintiff's residencyalleged in paragraph one. Two. Miss
Guffrey admits that she is a citizenof Colorado brackets residing in Australia closed brackets,

(28:18):
as alleged in paragraph two. Jurisdictionand Venue three. Paragraph three contains
legal conclusions for which no response isrequired to the extent the Court determines a
response is required. Miss Dufray deniesthat the amount in controversy exceeds seventy five

(28:41):
thousand. Missus Dufray denies knowledge orinformation sufficient to form a belief as to
the remaining allegations. In paragraph threefour, Miss Guffrey admits the Court has
personal juristiction over her, but deniesthat she has committed any tortuous actions in

(29:06):
this district. Five. Miss Guffraydenies that venue is proper in this district
because one, no wrongful events occurredin this district and no substantial part of
the underlying events occurred in this district. Two plaintiff did not suffer effects from

(29:26):
Miss Guffray's statement in this district.And three any use of by Miss Guffray
in this court is irrelevant to avenue determination. Factual allegations six. Miss
Guffray denies knowledge or information sufficient toform our belief as to the allegations contained

(29:49):
in paragraph six. Seven. MissGuffray denies the allegations contained in paragraph seven
eight. Miss Guffray denies the allegationscontained in paragraph eight nine. Miss Geuffray
denies the allegations contained in paragraph nine. Ten, Miss Geuffray admits that,

(30:14):
as alleged in paragraph ten, inapproximately two thousand and two thousand and one,
she saw plaintiff in New York,but Miss Geufray deny seeing Plaintiff at
any time outside of the state ofNew York and denies the conclusion that the
New York meetings constituted only a fewoccasions. Eleven, Miss Guffray denies the

(30:41):
allegations contained in paragraph eleven. Twelve, missus Guffray admits that she last saw
plaintiff in about two thousand and one, as alleged in paragraph twelve. Miss
Geuffrey does not understand what the remainderof parraph twelve means, since it alleges

(31:03):
that Miss Gufray has never accused plaintiffof any bad or criminal acts from that
time brackets ie from two thousand andone close brackets, and yet the complaint
appears to rest on allegations that MissGuffray has made statements about plaintiff that involve
bad acts. Thirteen. Miss Dufraydenies the allegations in paragraph thirteen. Fourteen,

(31:34):
Miss Gufrey admits that she has useda Twitter account under the name Virginia
Dufray at urel, Twitter dot com, slash vrs Virginia. Fifteen. Miss
Guffrey admits that during the times mentionedin paragraph fifteen, she distributed various tweets.

(31:57):
Sixteen. Miss Guffray denies the allegationsin paragraph sixteen that she published tweets
that contained statements of fact that sheknew or should have known to be false.
In addition, Miss Guffray denies thatthe statements described in paragraphs sixteen A,

(32:19):
sixteen B, sixteen C, sixteenD, sixteen E, sixteen and
sixteen G contained statements of fact thatshe knew or should have known to be
false. In addition, Miss Guffraydenies that any of the aforementioned allegations were

(32:42):
false statements, and to the extentthat any of these statements were found to
be false statements of fact, MissGuffray denies that she knew or should have
known that they were false. Seventeen. Miss Dufray denies the allegations in paragraph
seventeen that she tweeted and retweeted falsehoods. Eighteen. Miss Guffray denies the allegations

(33:12):
in paragraph eighteen that any statements ofhers were false. Miss Guffray denies that
she acted maliciously in making any statements. Miss Guffray denies that she knew or
should have known, any of thestatements were false. Nineteen. Miss Guffray

(33:32):
denies sufficient knowledge to form a beliefas to whether plaintiff ever was or is
formally criminally charged with a crime forbeing a co conspirator in the Jeffrey Epstein
sex trafficking organization, but denies theremaining allegations contained in paragraph nineteen. Twenty.

(33:57):
Miss Guffray denies the allegations in paragraphtwenty twenty one. Miss Dufray denies
the allegations in paragraph twenty one.Specifically, Miss Geuffray denies that she has
acted with any malice and that shehas reiterated and republished any defamations and slanders.

(34:21):
Twenty two. Miss Geuffray denies theallegations in paragraph twenty two. Twenty
three. Miss Geufray denies the allegationsin paragraph twenty three, Count one defamation
twenty four. In response to Plaintiff'srestatement of her allegations in paragraph twenty four,

(34:44):
Miss Geuffray restates all of the foregoinganswers contained in paragraphs one to twenty
three above twenty five. With respectto the defamation cause of action alleged in
paragraph twenty five, Miss Guffray deniesthe allegation in its entirety. In addition,

(35:07):
Miss Geuffray denies that she has madeany statements of fact that were false
or that she should have known werefalse about plaintiff. In addition to the
extent paragraph twenty five states conclusions orcharacterizations of the law about what is defamatory,

(35:30):
while no responses required, Miss Guffraydenies that any of these statements about
plaintiff were defamatory. In addition,Miss Guffray denies that she acted with any
malice. Twenty six. Miss Guffraydenies the allegations contained in paragraph twenty six

(35:54):
that she has created, written,spoken, published, and broad cast defamatory
statements about plaintiff. Twenty seven.Miss Geufray denies the allegations contained in paragraph
twenty seven that news organizations republished anyfalse and defamatory statements about her from plaintiff,

(36:17):
as she has never made any falseand defamatory statements about plaintiff. Twenty
eight. Miss Geufray denies the allegationscontained in paragraph twenty eight. Twenty nine
to the extent paragraph twenty nine statesconclusions or characterizations of the law. No

(36:40):
response is required. Miss Geufray otherwisedenies the allegations contained in paragraph twenty nine
thirty Miss Geufray denies the allegations containedin paragraph thirty thirty one to the extent
Paragraph thirty one states conclusions all characterizationsof the law. No response is required.

(37:09):
Miss Geufray otherwise denies the legal conclusionscontained in paragraph thirty one. Thirty
two to the extent paragraph thirty twostates conclusions or characterizations of the law.
No response is required. Miss Guffrayotherwise denies the legal conclusions contained in paragraph

(37:34):
thirty two. Thirty three to theextent paragraph thirty three states conclusions or characterizations
of the law. No response isrequired. Miss Dufray otherwise denies the legal
conclusions contained in paragraph thirty three.Affirmative defenses Thirty four plaintiffs complaint fails to

(38:01):
state a claim upon which relief couldbe granted. Thirty five plaintiffs claims may
be barred by the statute of limitations. Thirty six plaintiffs claims are barred because
she has filed her action in animproper venue. Thirty seven Plaintiff's claims involve

(38:25):
Missdeuffray's communications in a public forum inconnection with issues of public interest and other
lawful conduct in furtherance of the exerciseof the constitutional right of free speech in
connection with an issue of public interest. Thirty eight plaintiffs claims are barred by

(38:47):
the single publication rule. Thirty nineplaintiff's claims are barred because the statements made
by Missdeuffray when non actionable opinions.Forty plaintiff's claims are barred because the statements
made by Miss Guffray or her agentsbrackets, if any, were constitutionally protected

(39:13):
opinions under the First Amendment an Articleone, Section eight of the New York
State Constitution. Forty one plaintiff's claimsare barred because the statements made by Miss
Geuffray or her agent brackets, ifany, were non defamatory statements of fact.

(39:37):
Forty two plaintiff's claims are barred becausethe statements made by Miss Guffray or
her agent brackets, if any,were protected by the self defense privilege,
including self defense against statements made byplaintiff's agents, including Plaintiff's husband. Forty

(39:59):
three plaintiffs claims are barred because thestatements made by Miss Guffray or her agent
brackets, if any, were protectedby qualified or conditional privileges. Forty four
plaintiffs claims are barred because she isa public figure and unable to prove that

(40:23):
Miss Guffray acted with actual malice.Forty five plaintiffs claims are barred because the
statements made by Miss Guffray or heragent brackets, if any, were substantially
true. Forty six plaintiff's claims arebarred because the statements made by Miss Geuffray

(40:47):
or her agent brackets, if any, constituted fair comment. Forty seven plaintiffs
claims are barred because, at alltimes relevant herein, plaintiff has failed to
act in good faith with respect toMiss Dufray. Forty eight Plaintiff's claims are

(41:07):
barred by the incremental harm doctrine.Forty nine Plaintiff's claims are barred because the
statements made by Miss Dufray or heragent brackets, if any, cannot realistically
have caused impairment to Plaintiff's reputation.Fifty This Court lacks subject matter jurisdiction to

(41:32):
adjudicate plaintiff's claims because they do notexceed the sum or value of seventy five
thousand, exclusive of interest and coststwenty eight Usc. One three three two
A. Fifty one. Plaintiff's allegeddamages if any, are speculative, hypothetical,

(41:55):
unsupported by any reasonable methodology, andnot cognizable as a matter of law.
Fifty two. Plaintiff's claims are barredbecause the statements made by Miss Dufray
or her agent Brackets, if any, did not cause or contribute to any

(42:17):
damages suffered by plaintiff. Fifty threeto the extent that plaintiff suffered any injury.
Because plaintiff has previously described herself asJeffrey Epstein's girlfriend, any statements made
by Miss Dufray cannot have caused additionalinjury to plaintiff. Fifty four to the

(42:42):
extent plaintiff suffered an injury, shefailed to take reasonable, necessary, appropriate,
and feasible steps to mitigate her allegeddamages, and to the extent of
such failure to mitigate, she shouldbe barred from a covering some or all
of the ledge damages she seeks.Fifty five. Plaintiff damages if any,

(43:07):
are the proximate result of intervening causes, her existing medical and mental conditions of
plaintiff, and all causes that occurredwithout knowledge or participation of Miss Dufray and
for which Miss Dufray is not responsible. Fifty six. Plaintiff's damages, if

(43:30):
any, were the result of herown conduct or the conduct of others,
and were not proximately caused by anyaction of Miss Dufray. Fifty seven.
Plaintiff's claims are barred in whole orin part by the affirmative defenses of waiver

(43:50):
ratification, estoppel, latches, andor unclean hands fifty eight, As described
in greater detail below. Plaintiff's claimsare also barred by New York civ R.
Seventy six A one, a NewYork Anti slap laws ie new York's

(44:13):
law barring strategical lawsuits against public participationclose brackets. Miss Guffray's statements were communications
in a public forum in connection withan issue of public interest, and were
part of an exercise of her constitutionalrights. Fifty three. Under New York's

(44:36):
anti slap law, plaintiff cannot establishher claims by clear and convincing evidence.
Sixty Miss Guffray reserves the right toraise any and all other affirmative defenses she
deems proper based on the discovery processor any future development of the k Jury

(45:00):
Demand sixty one. Miss Dufray demandsa jury trial as to the claims against
her. Wherefore, on plaintiff's complaint, Defendant Virginia Dufray demands judgment as follows.
A the plaintiff Verna Oh take nothingby way of her complaint. Two,

(45:24):
that the complaint be dismissed with prejudice. See that judgment be entered in
favor of the defendant, Virginia Dufrayand against plaintiff Rena O. D That
defendant Miss Virginia Dufray be awarded hercosts and fees in this action, including

(45:46):
reasonable attorneys fees, and pre andpost judgment interest, and e all other
such relief as this Court deems justand proper. Counterclaim Introduction one. This
is an action for damages arising outof Miss O's revictimization and retraumatization by subjecting

(46:13):
Miss Duffray to a baseless, retaliatoryand emotionally draining lawsuit because Miss Duffrey spoke
her truth about her perpetrator, MissRena O brackets counterclaim defendant that sexually and
physically abused her and other victims ofJeffrey Epstein. Two. Counterclaim plaintiff Virginia

(46:42):
Dufray brackets. Miss Dufray has asubstantive right to maintain a claim and counterclaim
to recover damages against counterclaim defendant RenaO brackets Miss O. Under New York's
Anti Slapstrategic Lawsuit against Public Participation StatuteNY CIVL Rights seventy A Parties. Three.

(47:08):
Miss Dufrey is an individual who wasand is a citizen of the State
of Colorado residing in Australia. Four. Miss O is an individual who was
and is a citizen of the StateNew Jersey. Five. Miss O is

(47:30):
defined as a public figure under federalconstitutional law, jurisdiction and venue. Six.
This is an action claim and counterclaimfor damages in an amount in excess
of the minimum jurisdictional limits of thisCourt. Seven. Insofar as this Court

(47:52):
has subject matter jurisdiction over miss O'scomplaint, it has supplemental jurisdiction over Miss
Dufray's counterclaim pursuant to twenty eight USC. One three six seven eight. This
Court has jurisdiction over miss O becauseshe has voluntarily submitted to jurisdiction in this

(48:17):
district by filing her complaint here,and because she has tortiously and maliciously caused
injury to Miss Dufray in this district. Nine Venue is proper in this district
pursuant to twenty eight Usc. Onethree nine one B. And this Court

(48:37):
has personal jurisdiction over plaintiff counterclaim defendant, Miss O, who asserted her own
claims in this district and has voluntarilysubmitted to its jurisdiction. CEG Group E
v. Linda Laurie Sportswell, Inc. One seventy four f R D fifteen

(48:59):
eighteen d n Y, nineteen ninetyseven. Brackets Holding plaintiff by virtue,
Holding plaintiff by virtue of bringing suit, waves, venue and personal jurisdiction objections
to a defendant's counterclaims close brackets.Factual allegations ten. During around two thousand

(49:23):
and two thousand and two, beginningwhen Miss Dufrey was sixteen, Miss Dufrey
was the victim of sex trafficking andabuse by convicted sex offender Jeffrey Epstein.
Eleven. Epstein's trafficking scheme involved recruitingyoung girls, often by claiming they would
be paid two hundred dollars for simplyproviding a massage to a wealthy billionaire.

(49:47):
The young girls would then be broughtup to Epstein's bedroom, where Epstein would
be on a massage table. Epsteinwould then sexually abuse the girl. Same
patton was repeated numerous times with numerouschildren twelve. From between nineteen ninety nine

(50:08):
two thousand and seven, Jeffrey Epsteinsexually abused more than thirty minor girls in
his mansion in Palm Beach, Florida, and elsewhere in the United States and
overseas. In addition to his ownsexual abuse of the victims, Epstein directed

(50:29):
other persons to abuse the girls sexually. Epstein used paid employees to find and
bring minor girls to him. Epsteinworked in concert with others to obtain minors
not only for his sexual gratification,but also the sexual gratification of others.

(50:50):
United States District Court Judge Mara Summaryjudgment Order at two case number nine O
eight CV eight seven eight six,Southern District, Florida, February twenty first,
twenty nineteen. Brackets internal citations omittedclose brackets thirteen. Like other minor

(51:15):
children who came before and after her, missus Dufray was initially recruited to provide
massages and thereafter to engage in avariety of sexual acts, and thereafter to
engage in a variety of sexual actsfor Epstein. Miss Dufray was required to

(51:36):
be on call for Epstein for sexualpurposes and frequently traveled with him both nationally
and internationally. Miss Dufray was regularlyabused by Epstein and was lent out by
Epstein two others for sexual purposes fourteen. During the years that Miss Dufray was

(51:59):
a victim of sex trafficking and abuse, she was cut and slashed by plaintiff
in this underlying action Misso, Thecutting, slashing, and other injuries inflicted
on Miss Dufray was part of thesado massochistic sexual and physical abuse perpetrated against

(52:20):
her by miss O for Epstein's pleasurefifteen. Miss Dufray still has permanent emotional
and physical scarring, including a physicalscar on her leg, as a result
of the abuse perpetrated against her bymiss O. Sixteen. On October twenty
eight, twenty twenty, the podcastthe recruiters. Broken Seeking Justice was released

(52:46):
as part of an ongoing series ofepisodes related to survivors of Jeffrey Epstein's criminal
sexual Misconduct seventeen. The pog castepisode synopsis reads as follows, Epstein relied
on a network of women to bringhim new victims. Nearly twenty years later,

(53:10):
one survivor tracked down her own recruiter, Tara pow Mary, Broken Seeking
Justice eighteen. The recruiter referred toin the above mentioned synopsis is miss O
nineteen. During the podcast interview,miss O discusses her artwork that depicts the

(53:32):
infamous and highly circulated photograph of MissDufray Brackets. Original version is of Miss
Dufray next to Prince Andrew, Dukeof York, closed brackets, but with
a slashed and bleeding leg twenty.In miss O's interview for the subject episode,

(53:52):
miss O does not discuss Miss Dufray'sbleeding leg, but instead says that
Prince Andrew may not be wrong whenhe said that the picture was doctored.
Miss O goes on to claim thatin the original photograph, the lighting doesn't
look right and makes further comments suggestingthat the photograph was manipulated and she believes

(54:19):
that it is a composite image.Twenty one. Miss O claimed that she
and Epstein were in a relationship andthat he was an older, rich boyfriend.
Twenty two. When Miss Dufray's agewas brought up by the interviewer,

(54:40):
miss O responded, seventeen is nota child. Twenty three. Upon hearing
miss O's statements made during the podcastinterview, Miss Dufray was extremely upset,
retraumatized, and suffered further mental andemotion distress. Twenty four. Miss Guffray

(55:05):
suffered serial psychological, sexual, andphysical abuse at the hands of miss O.
To hear miss O's claim that shewas a victim and that she was
not an abusive person caused Miss Guffrayharm and exacerbated Miss Guffray's emotional injuries.
Twenty five. Miss Guffray responded withher protected opinions and truth as set forth

(55:31):
in miss O's amended complaint twenty six. Miss Dufray's comments were and are protected
opinions, the truth and non actionablefree speech count one New York State anti
slap claim twenty seven. Miss Guffrayre alleges and incorporates by reference herein each

(55:59):
of the paragraphs twenty eight. MissO's underlying action is a strategic lawsuit against
public participation or slap action, asdefined by New York civ R. Seventy
six A one A twenty nine.New York defines a slap action as acclaim

(56:22):
based upon one any communications in aplace open to the public or a public
forum in connection with an issue ofpublic interest, or two any other lawful
conduct in furtherance of the exercise ofthe constitutional right of free speech, in

(56:43):
connection with an issue of public interest, or in furtherance of this exercise of
the constitutional right of petition. ThirtyPursuant to the New York Civil Rights Law
seventy and seventy six, Miss Dufreybring her substantive cause of action for damages

(57:04):
against miss O for miss O's slapaction unlawfully brought against Miss Guffray thirty one,
In responding to the false statements thatmiss O may during the above mentioned
interview for the Recruiters podcast, MissGuffray was communicating in a public forum in

(57:24):
connection with an issue of public interest, and engaging in lawful conduct in furtherance
of her exercise of the constitutional rightof free speech in connection with an issue
of public interest. Thirty two.Miss Guffray's exercise of her rights is exactly

(57:46):
the class of rights intended to beprotected by the New York anti slap laws
see New York State Senator Brad Hollomanpress release brackets. With the signing of
this bill, New York will haveone of the strongest anti slap suit laws
in the nation, protecting New Yorker'sfree speech from vindictive bullies. Close brackets

(58:15):
thirty three. Miss O had nosubstantive basis in fact or law for her
lawsuit against Miss Dufray. Thirty four. Miss Dufray's speech was constitutionally protected Opinion
thirty five. Even if Miss dufrasesubject comments could somehow be found to be

(58:36):
unsubstantiated, Miss dufrayse comments would remainprotected speech and opinion ce Coleman v.
Grand five two three f. Sup. Three D two four four two six
three E d n Y two thousandand one. Brackets. Assertions that a
person is guilty of blackmail, fraud, bribery, and corruption could, in

(59:00):
certain contexts be understood as mere nonactionable rhetorical hyperbole or vigorous effotaphs, or
even when uttered, all published ina more serious tone. Non actionable if
based on disclosed facts and framed aspersonal surmise built upon those facts close brackets.

(59:24):
Thirty six. Miss O has broughther lawsuit to harass, intimidate,
punish, and maliciously inhibit miss jewphrase free speech rights. Thirty seven.
Miss O has brought her lawsuit forthe sole purpose of harassing, intimidating,

(59:47):
punishing, and maliciously inhibiting Miss jewphrase free speech rights. Thirty eight.
There exists a casual connection between missO's conduct and damages suffered by Miss Duffrey
thirty nine. As a result ofthe miss O's malicious conduct, Miss Dufray

(01:00:14):
has suffered and continues to suffer emotionaldistress and other injuries. Forty Miss Dufray
has a substantive right to maintain anaction, claim, cross claim, and
counterclaim to recover costs, compensatory damages, unitive damages, and attorney's fees from

(01:00:36):
miss O under New York civ Rightsseventy A. Forty one. New York
Law recognizes that Miss Guffray has asubstantive right to bring this action under this
section because the right to bring anaction under this section brackets ie the anti

(01:00:57):
slap section close brackets and be waivedonly if it is waived. Specifically,
New York CIB Rights seventy a two, Miss Duffrey has never waived her right
to bring her action against Miss O. Jury Demand forty two. Virginia Dufray

(01:01:20):
demands a jury trial as to hercounterclaim. Therefore, on her counterclaim counterclaim
Plaintiff, Virginia Dufray demands judgment asfollows. A that judgment be entered in
counterclaim Plaintiff's Miss Dufray's favor against counterclaimdefendant Miss O. B that Miss Guffray

(01:01:44):
be awarded compensatory damages in an amountto be determined at trial and in excess
of this Court's jurisdictional limits. Seethat Miss Guffray be awarded punitive damages in
an amount to be determined at trial. D That Defendant, Miss Virginia Dufray

(01:02:06):
be awarded her costs and fees inthis action, including reasonable attorneys fees,
and pre and post judgment interest ande or other such relief as this Court
deems just and proper. Dated Mayseven, twenty twenty two, New York,
New York respectfully submitted Kathleen R.Thomas Esquire Thomas Counselors at Law l

(01:02:32):
LC Document twenty nine filed the seventhof June, and it's the plaintiff Rena
Ow's amended answer to Defendant Virginia's counterclaim. Plaintiff Rena O n Ka Rena O
Amen, Plaintiff, by her attorneys, the Mayowitz Law Firm, as and

(01:02:59):
for her A did answer to thecounterclaim of defendant Virginia L. Duffrey.
Defendant alleges as follows Plaintiff's answer toDefendant's introduction one. Plaintiff denies the allegations
in this corresponding paragraph of Defendant's counterclaimand further alleges as follows Defendant de Fame's

(01:03:25):
plaintiff stating that plaintiff was not avictim of Jeffrey Epstein Brackets Epstein and Gallain
Maxwell Brackets Maxwell, and that shewas a co conspirator in the horrible Epstein
sex trafficking enterprise. That is simplynot true. After fully investigating plaintiff and

(01:03:47):
conducting numerous and lengthy interviews a plaintiff, the FBI and the US Attorney's Office,
among other governmental agencies, as wellas with Epstein's estate trust have all
come to the same conclusion and namedand classified plaintiff as a victim and not

(01:04:09):
a recruiter, co conspirator, oranything else. Indeed, plaintiff was never
charged or prosecuted for any illegal actsfor being a co conspirator of Epsteina Maxwell
because plaintiff was manipulated by and wasa victim of Epsteina Maxwell and not a

(01:04:30):
co conspirator or recruiter or anything else. Like many other victims, Epsteina Maxwell
played psychological games and manipulated and groomedplaintiff. In fact, defendant participated in
this attempted grooming of plaintiff. Inthis attempted grooming of plaintiff as well as

(01:04:53):
with other females, Defendant even triedto coax plaintiff into dating other men by
telling her that is what Epstein liked. Plaintiff was never Epstein's girlfriend. Notably,
defendant was called and referred to herselfas Epstein's number one girl. When

(01:05:14):
plaintiff realized what was happening to herand that Epstein and Maxwell were trying to
sex traffic her to Epstein's friends,and after Epstein violently sexually assaulted her,
Plaintiff was able to break free oftheir psychological hold and left them and escape
their sexual abuse and attempts to trafficher. Defendant knew and was aware of

(01:05:38):
the foregoing, which makes defendants publicand defamatory accusations all the more malicious and
hurtful too. Plaintiff denies the allegationsin this corresponding paragraph of Defendant's counterclaim and
further alleges as follows. Plaintiff hasremained an for approximately twenty years and never

(01:06:02):
had any intention of speaking publicly aboutwhat happened with Epstein and Maxwell that or
change. When defendant violated plaintiffs statutoryright to privacy and an amenity as a
victim of sexual abuse and publicly outof plaintiff by name in a memoir,

(01:06:23):
Defendant intended to publish and through otherpublic comments. Once plaintiff was illegally and
maliciously outed and named by defendant andthen defamed by defendant, Plaintiff had no
choice but to come forward to addressdefendant's defamatory statements and to bring this action

(01:06:43):
for defamation. Plaintiff was not apublic figure and never wanted to be.
Defendant tried to make one by publiclydefaming a naming plaintiff in violation of Plaintiff's
right to privacy. Defendant Lloyd tacticsof intimidation and false allegations to dissuade plaintiff

(01:07:04):
are witness in the criminal investigations fromtestifying for government agencies and other parties involved,
including meeting a note here apologies Imay get these names absolutely wrong.
Rifya Vanou Cook Lu and Joanna Soberg, both of whom defendants spent significant time.

(01:07:29):
In addition, defendant also befriended theperson who recruited plaintiff, Lisa Phillips
three. Plaintiff denies the allegations inthis corresponding paragraph of Defendant's counterclaim and further
alleges as follows. Plaintiff never perpetratedany sadomasochistic acts or sexual abuse upon defendant.

(01:07:53):
To the contrary, Defendant Brackets,who was of legal age at the
time close, Brackets sexually assaulted plaintiff. Indeed, Plaintiff was surprised when she
was called to the massage room tosee Epstein and found Epstein and defendant waiting
for her. Defendant then proceeded totouch plaintiff without Plaintiff's consent and much to

(01:08:17):
her horror, Plaintiff did not reciprocateor sexually touch defendant. Plaintiff never engaged
in any sadomasochistic nor did she evercut or slash defendant. These are lies.
It was plaintiff who was sexually assaultedand abused by defendant at Epstein's direction.

(01:08:42):
Plaintiff did not participate in any threesomewith defendant and Epstein. On another
occasion, another woman sexually assaulted inthe massage room, the woman and Epstein
waiting for plaintiff in the same manneras defendant had done. Plaintiff only saw
defendant a few times at Epstein's estatesbefore plaintiff left Epstein's orbit. Defendant remained

(01:09:06):
to groom and bring many more girlsto Epstein, including minors. As an
adult four, Plaintiff denies the allegationsin this corresponding paragraph of Defendant's counterclaim and
further alleges as follows. Plaintiff didnot bring three women to Epstein for sexual

(01:09:28):
purposes, whereas, on the otherhand, defendant recruited numerous girls, including
many miners, for Epstein and Maxwell, whom defendant groom for Epstein and to
be sexually abused and sexually trafficked.Defendant has emitted as much. Indeed,
Defendant even went to Thailand with theintent to recruit girls for Epstein to be

(01:09:53):
sex trafficked, one girl being aroundtwelve years of age. When plaintiff realized
that Epstein and Maxwell wanted her todo brackets, recruit girls, and sleep
with Epstein's friends close brackets, plaintiffleft and never returned. On the other
hand, defendant continued recruiting for Epsteinremained as much as a year after plaintiff

(01:10:17):
left. Five. Plaintiff denies theallegations in this corresponding paragraph of Defendant's counterclaim
and further alleges as follows. Inthe presence of defendant, Maxwell asked plaintiff
to go shopping with defendant. Maxwellgave defendant money to buy a schoolgirl outfit,

(01:10:38):
and defendant used that money to buya dress that defendant selected. Defendant
also wanted to get and got abelly button piercing and convinced plaintiff to get
a piercing. Two. After shopping, plaintiff went home. Six. Plaintiff
denies the allegations in this corresponding paragraphof Defendant's counterclaim and further alleges as follows,

(01:11:06):
Epstein's so called number one girl.Defendant sexually abused plaintiff for Epstein's pleasure.
Seven. Plaintiff denies the allegations inthis corresponding paragraph of Defendant's counterclaim and
further alleges as follows. Defendant continuouslyaccuses plaintiff of things that defendant did here

(01:11:30):
too, regarding being out for themoney. The same accusation hearing could be
leveled at defendant, who has receivedlarge cash payouts from the Epstein Victim Compensation
Fund, as well as receiving fifteenmillion dollars by suing and then settling with
Prince Andrew of the United Kingdom.She also sued and settled with Maxwell.

(01:11:54):
Plaintiff was not Epstein's girlfriend. Plaintiffwas called a fat and never a girlfriend.
Epstein called himself a mentor. Plaintiffnever sought to profit from her abuse.
Indeed, she had remained anonymous fortwenty years and would have continued to
remain anonymous if it were not fordefendant, who were legally outed plaintiff as

(01:12:17):
a sexually abuse victim. Defendant didnot seek to be compensated. Rather,
plaintiff was contacted by Brad Edwards,an attorney representing and assisting victims and survivors
of Epstein, and made a claimfor plaintiff to be sure after vetting by
the FBI, US Attorney's Office andthe Epstein's Estate Trust, Plaintiff was and

(01:12:42):
has always been categorized as a victimand not a recruiter or anything else,
and lawfully received compensation brackets far lessthan the defendant that she never sought out
in the first place. Plaintiff suedno other parts defending collected from no less
than three parties, and is embroiledin still another suit. Defendant is victim's

(01:13:09):
shaming plaintiff eight. Plaintiff denies theallegations in this corresponding paragraph of defendant's counterclaim
and further alleges as follows. Defendantdefamed plaintiff. This case is not about
money. This case is about justicein clearing plaintiff's names of defendants lies.

(01:13:30):
Moreover, defendants defamation has caused plaintiffto lose significant business and to suffer significant
damage her name and reputation, aswell as to suffer from extreme mental distress,
humiliation, shame, embarrassment, andtrauma. This case is also an
effort to stop defendant from continuing topublicly spew lies about plaintiff. Nine Plaintiff

(01:14:00):
denies the allegations in this corresponding paragraphof defendant's counterclaim and further alleges as follows.
Defendant does not have the right todefame someone. Plaintiff has a legal
right to sue for defamation. TenPlaintiff denies the allegations in this corresponding paragraph
of defendant's counterclaim and further alleges asfollows. Plaintiff is not seeking to silence

(01:14:27):
defendant. Plaintiff is simply seeking tostop the lies that defendant continues to spread
about plaintiff. Defamation is an ageold legal claim that is constitutionally permissible,
despite free speech and the First Amendment. No one has the right to defame
another person. The First Amendment doesnot allow defendant to defame plaintiff. Plaintiff's

(01:14:55):
claim for defamation is not bar byNew York civ R. Seventy six A
one A New York's anti slap lawsthe anti slap law. Defendants counterclaim pursuant
to anti slap law is not applicablein this situation where plaintiff is suing for
defamation. None of the elements ofthe anti slap law are met in this

(01:15:15):
case, and neither was the antislap law ever intended to bar a legitimate
claim for defamation. Defendant's counterclaim underthe anti slap law is without merit and
indeed an effort to silence plaintiff inthe face of the defendants public lies about

(01:15:35):
plaintiff. Defendant's counterclaim should therefore bedismissed for failing to state a claim upon
which relief may be granted. Plaintiff'sanswer to the Defendant's answer and incorporated counterclaim
one, Plaintiff neither admits nor deniesthe allegations in this corresponding paragraph offen answer

(01:16:00):
counterclaim too. Plaintiff neither admits nordenies the allegations in this corresponding paragraph of
Defendant's answer Counterclaim three. Plaintiff deniesthe allegations in this corresponding paragraph of defendants
answer counterclaim four. Plaintiff denies theallegations in this corresponding paragraph of defendants answer

(01:16:24):
counterclaim A. Note this continues untilclaim thirty three. Each of these claims
she is saying. Plaintiff denies theallegations in this corresponding paragraph of defendants answer
counterclaim Plaintiff's affirmative defenses to counterclaim.One Defendant fails to state a claim upon

(01:16:46):
which relief can be granted in hercounterclaim. Two, Defendant's anti slap law
counterclaim is without merit and does notbar Plaintiff's claim for defamation. Three Defendant
has and had no lawful right orprivilege qualified or conditional to defame plaintiff.

(01:17:10):
For Defendant's counterclaim is barred by thedoctrines of waiver ratification, estopple, lutches,
bad faith and unclean hands. Prayerfor relief with respect a counterclaim.
Wherefore, Plaintive praise for relief withrespect to the counterclaim of defendant, as

(01:17:30):
follows, ay that Defendant's counterclaim bedismissed in its entirety and with prejudice.
Be that plaintive be awarded its attorneysfees and costs under statutory and common law.
And see that plainty be awarded allother and further relief as the Court
may deem just and proper. UpdateNew York, New York, June seventh,

(01:17:53):
twenty twenty two, signed by IrishScott Mayowitz. Hi, it's lee
here. Do you want to helpus produce The Prince in the Pervert podcast.
One of our kind listeners has beenasking how they can support us,
so we've started a Patreon account,which not only benefits you in terms of

(01:18:14):
extra content and exclusive content, italso helps us just cover our costs at
the end of the day. Thisis a labor of love and we're determined
to follow the case until the end. These women absolutely matter. That's why
we're doing this work and we areall in this together. Details of the
Patreon account are in the show notes. Thank you,