AL'JIHAD : MESSENGERS (Angels & Devil) IN THE SKY (Captured Picture) AL'JIHAD Seventh Edition - Coker College copy - Page 414

Defendant Twelfth Defense Not Justified 74. Defendant: To the extent that Plaintiffs Complaint can be construed as asserting a claim for defamation and/or slander, which L'Oreal denies, any and all statements made by L’Oreal of and concerning Plaintiff were made in good faith and with a reasonable and honest belief in their truth. L'Oreal acted reasonably under the facts and circumstances known to it. 75. Plaintiff: With the exception of Plaintiff hired and/or employment dates accepted by Defendant, all statements made by L’Oreal of and concerning Plaintiff were made in bad faith and with unreasonable and dishonest belief in their untruth. L’Oreal acted unreasonably under the facts and circumstances known to it. Defendant Thirteenth Defense Not Justified 76. Defendant: Alternatively, and to the extent that Plaintiffs Complaint can be construed as asserting a claim for defamation and/or slander, which L'Oreal denies, any and all statements made by L'Oreal of and concerning Plaintiff were neither made with knowledge of their falsity nor made with reckless disregard for whether they were true or false. 77. Plaintiff: With the exception of Plaintiff hired and/or employment dates accepted by Defendant, all statements made by L’Oreal USA Inc. of and concerning Plaintiff were made with knowledge of their falsity and made with reckless disregard knowingly they were untrue or false or in Bad-Faith. Defendant Fourteenth Defense Not Justified 78. Defendant: To the extent that Plaintiffs Complaint can be construed as asserting a claim for defamation and/or slander, which L'Oreal denies, Plaintiffs claim for defamation and/or slander is barred by a qualified and/or absolute privilege under the “AL’JIHAD”– by, Imam Mahdi . © ® ™ : Of 842 Pages Is 414