Tull v. Higgins  ·  2021-12-27  ·  N.D. California  ·  pin 216 Cal. App. 3d at 172

“For appellant’s argument to satisfy the New York Times standard, appellant must link [the 5 reporter’s] statements [about the plaintiff, including that he was a ‘crook’ and a ‘crooked 6 politician’] to [the reporter’s] awareness of probable falsity.”