It is further noted that a defamation claim, as is the case here, is subject to the heightened pleading standard of CPlR 3016 (a) which states that “… the particular words complained of shall be set forth in the complaint, but their application to the plaintiff may be stated generally” (see Rubin v Napoli Bern Ripka Shkolnik, LLP, 151 AD3d 603, 604 [1st Dept 2017]). [read post]