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Case 18-2868, Document 279, 08/09/2019, 2628231, Page14 of 37 D. Subjecting Ms. Maxwell to liability for the media’s republication of excerpts they unilaterally selected is particularly unfair. It is undisputed that no one ever republished in toto the January 2015 statement and that various media unilaterally selected portions of the statement to republish. We said on page 14 of our Memorandum that the media’s “selective, partial republication of the statement is more problematic yet” (emphasis altered). That is to say, as improper as it is to hold a publisher of a statement liable for republications over which she had no control, worse is it to make her liable for selective, partial republications of her statement. We relied on the holding in Rand v. New York Times Co., 430 N.Y.S.2d 271, 275 (1* Dep’t 1980), that a publisher cannot be charged with 3G 6 a republisher’s “editing and excerpting of her statement.” Memo. of Law 14. Plaintiff argues that our position is “absurd on its face” because “[i]t would mean... a defamer could send to the media a long attack on a victim with one irrelevant sentence and, when the media quite predictably cut that sentence, escape liability.” Resp. 32. This argument has two erroneous assumptions. One is that the “defamer” can “escape liability.” Not true. An original publisher remains liable for her defamation. We are concerned here with republication. The second wrong assumption is that the original publisher must always remain liable for any republication. Geraci rejects that view: Under New York law “each person who repeats the defamatory statement is responsible for the resulting damages.” 938 N.E.2d at 921. The effort by plaintiff to distinguish Rand is meritless. She argues the media’s republication of the January 2015 statement actually was not a republication at all, just an original publication. Resp. 32. That argument is “absurd on its face,” id., since there is no dispute Ms. Maxwell did not control the media’s decision to republish (excerpts from) the statement. Plaintiff next argues the media did not “edit[]” or “tak[e] . . . quote[s] out of context.” Id. Plaintiff could not be more wrong. As she concedes, all republications of the statement by the