From Watergate to Dean v. St. Martin's
Response to Motion for Partial Summary Judgement
Plaintiffs' opposition to defendant Leonard Colodny's motion for partial summary judgment re: Plaintiffs' libel and misappropriation counts

Table of Contents

Full Document

• Opening Section — p.i
• Title page
• Table of contents — p.i
• Table of authorities — p.vi
• I. Introduction — p.1
• II. Summary of relevant facts: — p.13
• A. Colodny had a preconceived Watergate villain - John Dean — p.13
• B. Colodny knew before Silent Coup was published that his principal source Phillip Mackin Bailley was unreliable, mentally unbalanced and a liar; nevertheless, Colodny manipulated Bailley so that he could 'rely' on him for defamatory and false information about Mrs. Dean — p.18
• C. Colodny engaged in manipulative and deceptive interview techniques and failed to check obvious sources for fear they would contradict Silent Coup — p. 26
• III: Argument — p.29
• A. Contrary to Colodny's assertion, Silent Coup clearly implies (falsely) that Maureen Dean was involved in prostitution activities — p.29
• B. The actionable statements alleged in the Deans' complaint are statements of fact not opinion — p.42
• C. Colodny's motion fails to address all of the actionable statements at issue — p.54
• D. Colodny's motion fails to address paragraph 30(b) of plaintiffs' second amended complaint relating to the continuing publication of Silent Coup — p.54
• E. Colodny's motion disregards obvious material facts in issue — p.56
• F. Plaintiffs have developed clear and convincing evidence to support a reasonable jury finding that Colodny published the actionable statements with constitutional actual malice — p.57
• IV. Conclusion — p.159
• Certificate of service — p.162