MEMORANDUM OPINION AND ORDER
RICHARD H. KYLE, District Judge.
INTRODUCTION
This defamation action arises from a passage in decedent Chris Kyle's autobiography describing an altercation with Plaintiff Jessie Ventura during a Navy SEAL's wake. In his book, Kyle wrote that Ventura made offensive comments about the SEALs and their service in the Iraq war, so Kyle "laid him out." Ventura claims Kyle fabricated the encounter to gain publicity. He commenced...
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