The Second Department offers an instructive opinion in Berger v. Temple Beth-el of Great Neck, which was decided on June 19, 2007. Plaintiff alleged that defendants had defamed him by issuing statements disclosing and explaining the termination of his membership from the synagogue. The court granted defendants' summary judgment motion on the basis of a qualified privilege, since the challenged statements had been made in the discharge of a private duty and in furtherance of a religious organization's common interest. The court noted that plaintiff could not defeat the qualified privilege by arguing that the challenged statements were excessively published, since the recipients all shared a common interest.