Where did Judge Merryday say the first defamation count appeared in Trump's complaint?

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In his four-page order on September 19, 2025, U.S. District Judge Steven D. Merryday criticized former President Trump’s 85-page complaint under Federal Rule of Civil Procedure 8(a)(2), which requires a “short and plain statement of the claim.” Merryday noted that Trump’s attorneys did not present the first formal defamation allegation until page 80 of the filing, after 79 pages of background on media appearances, “The Apprentice,” and other rhetoric he deemed extraneous to the legal claim ).

Where did Judge Merryday say the first defamation count appeared in Trump's complaint?

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