Giuffre_Maxwell_Batch7_p00243.png

20 Za 22 23 24 25 Case 1:15-cv-07433-LAP Document 1332-10 Filed 01/08/24 Page 46 of 64 45 H2G8GIUC Maxwell hiring a paid press agent to issue a statement to the international press with defamatory statements in it, your Honor. They focus on the Geraci case. And that is case law in New York. We looked at that case. We take no issue with that case. That case is vastly different than the situation here. In that case, the republication happened three years later. The initial publication was a statement to a fire commissioner, it was a letter, but then three years later a newspaper published. This here is vastly different. We have a press release that's given directly to the international media for publication saying, Please, here, attached find a quotable statement for your distribution, your Honor. This is the perfect situation. If the law were otherwise, it would turn defamation on its head. It would mean that you could issue a press release to the international press and then sit back and say, I am not liable because those other publications put the quotes in, I didn't. That's not the law, your Honor. She controlled and authorized this entire process. So, your Honor, we believe that the cases that they focus on there are distinguishable because they are situations where -- for all of their cases -—- where the publication was in a different type of publication, happened years after the fact. Those are the types of republication issues where the court SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300