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Wednesday, August 26, 2015 10:11:31 PM
http://static1.squarespace.com/static/557f1dc6e4b0cd2823d04cda/t/5583190de4b01fce11f8850f/1434654989345/6.16.15+Answer.pdf
Quote:
27. Defendant admits to the content of the quoted text in Paragraph 27,
which Granville sent to Morton Fink. It is noted that Plaintiffs have omitted the final sentence of this text, which states: “You shouldn’t have lied to me you old bastard.” Plaintiff denies the remainder of Paragraph 27.
Quote:
Third Affirmative Defense
Prior to the publication of the challenged statements, Plaintiffs were widely
known to be engaged in “pump and dump” schemes, naked short selling, and other abusive and unethical conduct; therefore, nothing that Granville said about Plaintiffs could have diminished their already dismal reputation.
Fourth Affirmative Defense
Any reputational harm sustained by Plaintiff, and any resulting economic
loss, was a result of the Bloomberg Article published by Bloomberg, L.P. and Zeke Faux on or about March 12, 2015, and not Defendant’s subsequent reference to or commentary on said article.
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