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Case 18-2868, Document 280, 08/09/2019, 2628232, Page36 of 74 attacks. If accepted, this remarkable claim would eviscerate defamation law, as it would permit a defamer to send defamatory statements to the media and then stand back and watch — immune from liability — when (as in this case) the defamatory statements are published around the world. This absurd position is not the law, particularly given that the Defendant released a statement to media asking them to “[p]lease find attached a quotable statement on behalf of Ms. Maxwell.” To make her claim seem plausible, Defendant cites older cases, some dating back as far as 1906. This presents a distorted picture of the case law on these issues. As a leading authority on defamation explains with regard to liability for republication by another of statement by a defendant: “Two standards have evolved. The older one is that the person making the defamatory statement is liable for republication only if it occurs with his or her express or implied authorization of consent. The more modern formulation adds responsibility for all republication that can reasonably be anticipated or that is the ‘natural and probable consequence’ of the publication.” SACK ON DEFAMATION § 2.7.2 at 2-113 to 2-114 (4th ed. 2016). In this case, however, the nuances of the applicable legal standards make little difference because Defendant so clearly authorized — indeed, desired and did everything possible to obtain — publication of her defamatory statements attacking Ms. Giuffre. 1. Under New York Law, Defendant is liable for the media’s publication of her press release. Given the obvious purposes of defamation law, New York law unsurprisingly assigns liability to individuals for the media’s publication of press releases. Indeed, New York appellate courts have repeatedly held that an individual is liable for the media publishing that individual’s defamatory press release. See Levy v. Smith, 18 N.Y.S.3d 438, 439, 132 A.D.3sd 961, 962-63 (N.Y.A.D. 2 Dept. 2015) (Generally, [o]ne who makes a defamatory statement is not responsible for its recommunication without his authority or request by another over whom he 28