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Extracted Text (OCR)
Case 18-2868, Document 280, 08/09/2019, 2628232, Page37 of 74
has no control... Here, however . . . the appellant intended and authorized the republication of
the allegedly defamatory content of the press releases in the news articles”); National Puerto
Rican Day Parade, Inc. v. Casa Publications, Inc., 914 N.Y .S.2d 120, 123, 79 A.D.3d 592, 595
(N.Y.A.D. 1 Dept. 2010) (affirming the refusal to dismiss defamation counts against a defendant
who “submitted an open letter that was published in [a] newspaper, and that [the defendant] paid
to have the open letter published,” and finding that the defendant “authorized [the newspaper] to
recommunicate his statements.”) See also RESTATEMENT (SECOND) OF TorRTS § 576 (1977) (“The
publication of a libel or slander is a legal cause of any special harm resulting from its repetition
by a third person if. . . the repetition was authorized or intended by the original defamer, or...
the repetition was reasonably to be expected.”)**
Defendant deliberately sent her defamatory statement to major news media publishers for
worldwide circulation because Defendant wanted the public at large to believe that Ms. Giuffre
was lying about her abuse. Defendant even hired a public relations media specialist to ensure the
media would publish her statement. Her efforts succeeded: her public relations agent instructed
dozens of media outlets to publish her “quotable” defamatory statement and they did.
Despite this deliberate campaign to widely publicize her defamatory statement,
Defendant now disclaims any responsibility for the media publishing her press release. If we
understand Defendant’s position correctly, because she somehow lacked “control” over what
major newspapers and other media finally put in their stories, she escapes liability for
defamation. This nonsensical position would let a defamer send a false and defamatory letter to
major media, and then, when they published the accusation, escape any liability. Such an
“Cf, Eliah v. Ucatan Corp., 433 F. Supp. 309, 312-13 (W.D.N.Y. 1977) (“The alleged multistate publication of
plaintiff's photograph without her consent thus gives rise to a single cause of action. ... However, evidence of the
multistate publication of the magazine and the number of copies sold would be competent and pertinent to a
showing of damages, if any, suffered by plaintiff.)
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Extracted Information
Dates
Document Details
| Filename | DocumentCloud_Epstein_Docs_p00856.png |
| File Size | 325.2 KB |
| OCR Confidence | 94.0% |
| Has Readable Text | Yes |
| Text Length | 2,371 characters |
| Indexed | 2026-02-04 12:26:41.867017 |