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Case 18-2868, Document 280, 08/09/2019, 2628232, Page59 of 74 malice. Tellingly, Defendant does not even attempt to address the documentary evidence, nor the testimonial evidence showing she was a recruiter of girls for Epstein. As shown above, far beyond showing that a reasonable inference could be drawn in her favor, which is all that is required at this point to defeat Defendant’s motion, Ms. Giuffre will easily be able to meet her trial burden of clear and convincing evidence of actual malice. Of course, a plaintiff need only show “actual malice” on the part of a defendant if that plaintiff is a public figure or a limited public figure, which Ms. Giuffre is not, as explained infra. VII. THE COURT NEED NOT REACH THE ISSUE, AT THIS TIME, OF WHETHER MS. GIUFFRE IS A LIMITED PURPOSE PUBLIC FIGURE For the reasons just explained, Ms. Giuffre will easily be able to prove actual malice at the trial in this case. Defendant argues that Ms. Giuffre “is a public figure who must prove actual malice.” MSJ at 49. Given the overwhelming proof of the second part of that statement, the Court need not spend its time considering the first. If the Court wishes to nonetheless consider the issue at this time, it is not appropriate for disposition at the summary judgment stage of this case. The defendant bears the burden of demonstrating that the plaintiff is a limited purpose public figure. See Lerman v. Flynt Distrib. Co., 745 F.2d 123, 136-37 (2d Cir. 1984). Defendant correctly articulates the legal test for a finding that a plaintiff is a limited purpose public figure, but glosses over the fact that all prongs of the test must be met in order for a court to make that finding. See, e.g., Contemporary Mission, Inc. v. N.Y. Times Co., 842 F.2d 612, 617 (2d Cir. 1988) (“[T]his court set forth a four part test for determining whether someone is a limited purpose public figure” (emphasis added)); Herbert v. Lando, 596 F. Supp. 1178, 1186 (S.D.N.Y. 1984) (“The Second Circuit recently summarized the criteria” (emphasis added)), aff’d in part, rev’d in part, 781 F.2d 298 (2d Cir. 1986); cf Nehls v. Hillsdale Coll., 178 F. Supp. 2d 771, 778 (E.D. Mich. 2001) (finding plaintiff 51