Back to Results

DocumentCloud_Epstein_Docs_p00856.png

Source: DOCUMENTCLOUD  •  Size: 325.2 KB  •  OCR Confidence: 94.0%
View Original Image

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.) 29

Document Preview

DocumentCloud_Epstein_Docs_p00856.png

Click to view full size

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