No Defamation Claim for Failure to Allege Place Where the Defamatory Statement Was Made

On August 11, 2016, the First Department issued a decision in Beach v. Touradji Capital Management, LP, 2016 NY Slip Op. 05777, holding that a trial court properly denied an amendment to counterclaims to add a defamation claim because the counterclaimant "did not allege the place where the statements were made."