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Monday, September 19, 2011

DONALD J. TRUMP VS. TIMOTHY L. O'BRIEN, ET AL. A-6141-08T3


We affirm the trial court's order of summary judgment in favor of defendants Timothy L. O'Brien, the author of the book TrumpNation, The Art of Being The Donald, and his publishers, determining that Trump failed to demonstrate by clear and convincing evidence that O'Brien acted with actual malice when he reported that three unnamed sources had estimated Trump's net worth as between $150 million and $250 million, not the $5 to $6 billion that Trump claimed. In doing so, we focus principally on when an inference of actual malice may arise when an allegedly false report is published solely in reliance on confidential sources. 9-07-11