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maa PPL ie i 2 i 4 f SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK LANDMARK EDUCATION CORPORATION, @ Plaintiff, Index No. 114814/93 ~against~ | VERIFIED ANSWER TO THE CONDE NAST PUBLICATIONS, INC., d/b/a SELF MAGAZINE, ADVANCE MAGAZINE PI a || PUBLISHERS, INC. d/b/a SELF MAGAZINE ind DIRK MATHISON, $ , *, Defendants. KS “& x, Ss = 7 Se | Defendants The Conde Nast Publications Inc,-“a/b/a ||sexe Magazine and Advance Magazine Publishers Inc. d/b/a Self Magazine "defendants"), by their attorneys, Satterlee stephens Burke & Burke, as and for their Answer to the Amended Complaint |perein, allege as follows: NATURE OF THE ACTION i FIRST: Deny each and every allegation contained in paragraph 1 of the Complaint, except admit that the Complaint i Ipurports to state a claim for damages based on allegedly false and defamatory statements, and admit that jurisdiction and venue |are proper in this court. PARTIES SECOND: Deny knowledge or information sufficient to form a belief as to the truth of the allegations contained in lj paragraph 2 of the Complaint. | THIRD: Deny each and every allegation contained in ;Paragraph 3 of the Complaint, except admit that The Conde Nast |Publications is a division of Advance Magazine Publishers Inc., which publishes and distributes a monthly magazine known as self magazine, a publication doing business in New York County which has offices located at 350 Madison Avenue, New York, New york 10027. a FOURTH: Admit the allegations contained in paragraph 4 of the Complaint. FOURTH: Deny knowledge or information sufficient to | | | | | | “form a belief as to the truth of the allegations contained in | paragraph 5 of the Complaint, except admit that Dirk Mathison is la professional journalist who researched and authored an article lentitiea "white cotiar cults -- they Want Your Mind," that [appeared in the issue of Self magazine dated February 1993. | BACKGROUND FIFTH: Deny knowledge or information sufficient to form a belief as to the truth of the allegations contained in Paragraphs 6 through 13 of the Complaint, inclusive. cau! OF ACTION i SIXTH: With respect to the allegations contained in [Paragraphs 14 through 16 of the Complaint, inclusive, defendants admit that an article entitled "White Collar Cults -- They Want ‘Your Mind" was written by defendant Mathison and published in ‘the issue of Self magazine dated February, 1993, and beg leave | to refer to a true and accurate copy of the magazine and the article contained therein, for the contents thereof in proper i | context. | errr neem a SEVENTH: Deny each and every allegation contained "f paragraphs 17 and 18 of the Complaint, and beg leave to refer t a true and accurate copy of the magazine and the article contained therein, for the contents thereof in proper context. | EIGHTH: Deny each and every allegation contained in i paragraphs 19 through 25 of the Complaint, inclusive. NINTH: Deny each and every allegation contained in l paragraph 26 of the Complaint, except admit that plaintiff sent a written request to Self magazine for a retraction of the statements complained of, admit that the request was denied, and jbeg leave to refer to a true and accurate copy of the | correspondence for the contents thereof in proper context. | TENTH: Deny each and every allegation contained in | || Paragraphs 27 and 28 of the Complaint. FI VI S) i ELEVENTH: The Complaint fails to state a claim upon which relief can be granted. | A AS AND FOR A FIRST | i | | AS AND FOR A SECOND | i j AFFIRMATIVE DEFENSE TWELFTH: The statements complained of are substantially true. AS AND FOR A THIRD AEFIRMATIVE DEFENSE THIRTEENTH: The statements complained of are a fair |