DocumentCloud_Epstein_Docs_p02007.png

Case 18-2868, Document 287, 08/09/2019, 2628251, Page59 of 76 projects. The court held that the author of the book could not be held liable for the republications, explaining that a “party who is ‘innocent of all complicity’ in the publication of a libel cannot be held accountable.” 580 F. Supp. at 1094 (internal citations omitted). The court further noted that “active participation in implementing the republication resurrects the liability.” Id. Likewise, in Karaduman v. Newsday, Inc., 416 N.E.2d 557 (1980), also cited by Maxwell, the court held that reporters of a series of articles on narcotics trade “cannot be held personally liable for injuries arising from [the] 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. at 559- 560. However, the court explicitly noted that this result was required because “the record [wa]s barren of any concrete evidence of the reporters’ involvement in the republication of the newspaper series.” Id. at 540. Here, there is evidence in the record that Maxwell “actively participated” in influencing the media to publish the Press Release, Davis, 580 F. Supp. at 1094, and “approved” of and sought the publication of the press release, Karaduman, 416 N.E.2d at 560. Maxwell retained a public relations media 59