This section contains the nature of the case and procedural background.

This is a defamation action against D. D proposes to seek damages and other relief under New York's anti-SLAPP law. P contends that the motion should be denied because (1) D has delayed unduly in seeking leave, (2) lie seeks leave for dilatory purposes, (3) granting leave would be unduly prejudicial to P, and in any case, (4) leave would be futile because D's proposed affirmative defense and counterclaim would be subject to dismissal on motion.

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