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20 Za 22 23 24 25 Case 1:15-cv-07433-LAP Document 1332-10 Filed 01/08/24 Page 47 of 64 46 H2G8GIUC says, well, that person is not really liable. Three years later a different movie came out with a statement that the original publisher had no involvement with. That's where the republication law lands. But if you look at Levy and if you look at the National Puerto Rican Day cases, you will see that the courts do hold you liable when you issue a press release, which is what happened here. So I submit to you that on republication and the publication issue, she is certainly liable for publication of the initial statement to the 30 international press, and then thereafter she is liable for those being quoted. Now, she says, well, there is another issue, because if it's excerpted or quoted or edited in any way, under New York v. Rand, I am not liable. New York v. Rand is a case that involves an interview of a singer, and it's a long interview that takes place, and then the publication that comes out takes statements from that interview and changes the words. So it uses different words than what happened during the interview. That's not our situation here, your Honor. The defamation that we have gone after, that you see from our expert, Jim Jansen, has gone after, are the quoted statements. That's what we are looking at. The press release has those statements; those being quoted by the international media that she sent it to, she is liable for that. It's not a Rand situation. This is exact quotes from her statement that she SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300