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Case 18-2868, Document 276, 08/09/2019, 2628224, Page20 of 77 “[W]here a defendant ‘had no actual part in composing or publishing,’ he cannot be held liable ‘without disregarding the settled rule of law that no man is bound for the tortious act of another over whom he has not a master’s power of control.’” /d. (quoting Folwell v. Miller, 145 F. 495, 497 (2d Cir. 1906)); see Geraci v. Probst, 938 N.E.2d 917, 921 (N.Y. 2010) (holding that defendant was not liable for republication, in part because “there is no indication that Probst had any control over whether or not Newsday published the article”). “Conclusive evidence of lack of actual authority [is] sufficiently dispositive that the [trial court] ‘ha[s] no option but to dismiss the case... .’” Id. (quoting Rinaldi v. Viking Penguin, Inc., 420 N.E.2d 377, 382 (N.Y. 1981)). As the New York Court of Appeals held in Geraci: It is too well settled to be now questioned that one who . . . prints and publishes a libel[] is not responsible for its voluntary and unjustifiable repetition, without his authority or request, by others over whom he has no control and who thereby make themselves liable to the person injured, and that such repetition cannot be considered in law a necessary, natural and probable consequence of the original slander or libel. 938 N.E.2d at 921 (internal quotations and citation omitted). The rationale behind this rule is that “each person who repeats the defamatory statement is responsible for the resulting damages.” Jd. (internal quotations omitted). With the goal of garnering maximum publicity and defaming Ms. Maxwell, Ms. Giuffre filed an “entirely unnecessary” joinder motion with “lurid details” about sexual acts for the purpose of attracting the attention of the public, which was “‘curious, titillated or intrigued’ about alleged sexual acts and relationships among the rich and famous. In defense of Ms. Maxwell’s reputation, Messrs. Barden and Gow responded with the January 2015 statement. TEXHIBIT E, at 7. ’Time, Inc. v. Firestone, 424 U.S. 448, 488 n.1 (1976) (Marshall, J., dissenting) (quoting Firestone v. Time, Inc., 271 So. 2d 745, 752 (Fla. 1972)). 13