Dickinson

*1144 In 2014, plaintiff Janice Dickinson publicly alleged that defendant William Cosby drugged and raped her in 1982. Cosby responded by issuing a demand letter and several press releases through his attorney, which expressed or implied that Dickinson was lying. Dickinson filed a complaint against Cosby for defamation and related causes of action, which Cosby moved to strike under Code of Civil Procedure section 425.16 (the anti-SLAPP statute). 1 The trial court granted Cosby's motion in part, which we subsequently reversed in Dickinson v. Cosby (2017) 17 Cal.App.5th 655 , 225 Cal.Rptr.3d 430 ( Dickinson I ). We concluded that none of Dickinson's claims were barred by the anti-SLAPP statute.

On remand, Cosby filed a second anti-SLAPP motion seeking to strike claims newly asserted in Dickinson's first amended complaint. The trial court granted the motion in substantial part, but refused to strike Dickinson's claims premised on two allegedly defamatory statements appearing in press releases issued by Cosby's attorney.

Cosby contends the trial court erred in declining to grant his motion in full. He argues that Dickinson cannot show he is directly or vicariously liable for his…