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Reason
Reason
Politics
Eugene Volokh

No Discovery into Alleged "Actual Malice" in Trump's Lawsuit Against WSJ Over Jeffrey Epstein Birthday Letter Story

From Trump v. Dow Jones & Co., decided Wednesday by Judge Darrin Gayles (S.D. Fla.):

On July 18, 2025, President Donald J. Trump filed his Complaint … for defamation based on an article in the Wall Street Journal … linking President Trump to convicted sex offender Jeffrey Epstein. On April 13, 2026, on Defendants' motion, the Court dismissed the Complaint without prejudice based on President Trump's failure to plausibly allege that Defendants acted with actual malice …. [See this post on the dismissal. -EV]

On April 14, 2026, President Trump filed the Motion, requesting leave to conduct limited discovery on (1) "[h]ow each Defendant acted with actual malice"; (2) "[h]ow Defendants purposefully avoided the truth of the statements at issue"; and (3) "[h]ow Defendants allegedly obtained the letter and supposedly verified its contents, including Plaintiff's signature." …

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