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20 Za 22 23 24 25 Case 1:15-cv-07433-LAP Document 1332-10 Filed 01/08/24 Page 45 of 64 44 H2G8GIUC And now they want to say, Oh, no, no, hands off, we are not liable for any of that; we are not liable for our statement being disseminated in the international press; there is republication case law and we didn't control or authorize that. There is no better evidence, your Honor, of control and authorization than sending a press release to the international press saying, please publish this, please publish these defamatory statements so that the international public thinks that this little girl is a liar. So that is what is happening Here® So when we look at the republication law, you will see very clearly, there are cases that we can follow -- and it is New York case law; we have cited nothing but New York case law -—- that says it's different when you issue a press release. Look at Levy v. Smith, and that's in your binder, your Honor. That case says, yes, there is republication case law that says you have to control or authorize. But issuing a press release so that it goes out to the media, is that control or authorization? It's saying, here is a statement, I want to publish this and disseminate it internationally. We also have the National Puerto Rican Day case, which is the same thing. It was an opinion piece that was paid for and disseminated to the press. And there the court held, yes, there is control and authorization over that dissemination. Here, your Honor, we have the same thing. We have SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300