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Case 18-2868, Document 280, 08/09/2019, 2628232, Page39 of 74 Similarly, another case cited by Defendant, Davis v. Costa-Gavras, involved a libel claim against a book author who wrote an account of the 1972 military coup in Chile. Years later, the plaintiff attempted to ascribe defamation liability to a third-party publishing house’s decision to republish the book in paperback form and a third-party filmmaker who released a movie based on the book. The Court held that a “party who is ‘innocent of all complicity’ in the publication of a libel cannot be held accountable . . . [but that] a deliberate decision to republish or active participation in implementing the republication resurrects the liability.” 580 F. Supp. 1082, 1094 (S.D.N.Y. 1984). Here, Defendant made a deliberate decision to publish her press release, and actively participated in that process. At the very least, the jury must make a determination of whether Defendant was “innocent of all complicity” for a libelous statement contained in her press release. Finally, Defendant cites Karaduman v. Newsday, Inc., 416 N.E.2d 557 (1980), which held that reporters of a series of articles on narcotics trade “cannot be held personally liable for injuries arising from its subsequent republication in book form absent a showing that they approved or participated in some other manner in the activities of the third-party republisher.” Id., 416 N.E.2d at 559-560. Again, the jury could reasonably find that Defendant both approved of, and even participated in, the media’s publication of her press release. Indeed, it is hard to understand how any jury could find anything else. Defendant was obviously “active” in influencing the media to publish her defamatory press release, she both “approved” of and pushed for the publication of the press release. Accordingly, she is liable for its publication.*° On page 14 of her motion, Defendant makes wholly contradictory statements. In back-to-back sentences, she tells the Court that (1) she has no control over whether the media published the statement she sent to the media (with instructions to publish it by an influential publicist); (2) her public relations representative gave instructions to the media on how to publish it (in full); and (3) her public relations representative “made no effort to control” how the media would publish it. Indeed, the best evidence of Defendant’s control over the press is the fact dozens of media outlets obeyed her directive to publish her defamatory statement. 31