The complaint is time-barred insofar as it alleges statements made in June and July 2019. The statute of limitations for libel and slander runs from the date of publication, regardless of the fact that the libel may not have been discovered until later. Plaintiff''s bare legal conclusion that the purported defamation continued into 2022 is insufficient to save the claims. Plaintiff's equitable estoppel argument fails, as he does not allege any subsequent and specific actions that kept him from timely bringing suit. In any event, even if plaintiff's claims were not time-barred, he fails to state a claim for defamation, as the complaint does not allege the exact words complained of or the time, place, and manner of the alleged defamation.
Biaggi v. O'Flynn, NY Slip Op 02584 (1st Dep't May 11, 2023)
