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Extracted Text (OCR)
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
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Extracted Information
Dates
Document Details
| 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 |