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Case 18-2868, Document 276, 08/09/2019, 2628224, Page24 of 77 defamatory statement on a party who had no “actual . . . responsibility for the decision to republish” the statement. Jd. A public figure includes a person who “voluntarily injects himself or is drawn into a particular public controversy and thereby becomes a public figure for a limited range of issues.” Gertz, 418 U.S. at 351; see, e.g., James, 353 N.E.2d at 839 (public figure includes those who have “thrust themselves to the forefront of particular public controversies in order to influence the resolution of the issues involved”). The evidence that plaintiff is a public figure is overwhelming, particularly in connection with the subject matters and issues addressed by and underlying the January 2015 statement. See This Motion {ff 51-54. In the case at bar, Ms. Maxwell and her agents had no responsibility for any media organization’s decision to republish the January 2015 statement, and they did not participate in any such decision. See EXHIBITS J § 24 & K {fj 2-3. Liability for republication by media organizations of the January 2015 statement therefore is precluded under the First Amendment. C. Plaintiff should be barred from introducing into evidence any republication of an excerpt from the January 2015 statement. In Geraci, the plaintiff suggested in a letter to the Long Island fire district where defendant was a commissioner that defendant had engaged in self-dealing in the district’s purchase of fire trucks. At trial the plaintiff sought to introduce into evidence portions of a Newsday article that republished parts of the defendant’s letter. Defense counsel objected, arguing it was inflammatory and prejudicial. Plaintiffs counsel later argued the article “was not being offered as a republication, but on the issue of damages to show how far the allegations had circulated.” 938 N.E.2d at 920. Additionally, plaintiffs counsel argued that the defendant “should have reasonably anticipated” that his letter to the fire district “would be newsworthy.” Id. The trial court admitted the article, and the Appellate Division affirmed. 17