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Case 18-2868, Document 276, 08/09/2019, 2628224, Page58 of 77 F.2d 1287, 1298 (D.C. Cir. 1980)). The law requires only that “the statement need be no more than generally related to a dispute in issue to qualify for protection.” Robert D. Sack, Sack on Defamation: Libel, Slander, and Related Problems (“SACK ON DEFAMATION’) § 5:3.3 (4th ed. 2015). The question whether a plaintiff is a public figure is a question of law for the court to decide. Celle v. Filipino Reporter Enters. Inc., 209 F.3d 163, 176-77 (2d Cir. 2000); accord Biro, 963 F. Supp. 2d at 270. 1. Plaintiff successfully invited public attention to influence others. The record amply demonstrates that plaintiff invited public attention to herself and her views regarding the Plaintiffs alleged desire to draw attention to the issue of her purported sex slavery. Beginning in at least 2011, the Plaintiff met with Sharon Churcher to promote her cause and economic interests. According to Ms. Churcher, the Plaintiff granted Ms. Churcher extensive interviews that resulted in 7 widely distributed articles from March 2011 through January 2015. According to Ms. Churcher, she regularly communicated with the Plaintiff and her “attorneys or other agents” from “early 2011” to “the present day.” See Doc.216 4 2-11 and referenced exhibits; Docs.261-1 to 216-8, incorporated by reference. Plaintiff was amply compensated for this “public attention” and received approximately $160,000 for her stories. and pictures that were published by many news organizations. EXHIBIT N at 247-248. Plaintiff had a contract with the news organizations, The Mail on Sunday. Plaintiff, in addition to selling this story to the media, again thrust herself into the public’s attention when she sought to join the ongoing CVRA litigation against Jeffrey Epstein in the United States District Court in Florida. The Plaintiff, through the same lawyers in this matter, publicly filed a joinder motion that was the equivalent of a press release. The unnecessary and 51

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Filename DocumentCloud_Epstein_Docs_p00107.png
File Size 297.1 KB
OCR Confidence 94.7%
Has Readable Text Yes
Text Length 2,014 characters
Indexed 2026-02-04 12:22:35.506537