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Chevalier v. Animal Rehab. Ctr., 839 F. Supp 1224 (N.D. Tex. 1993). (Statutes of Limitations; Defamation; Public Figure Doctrine)
A claim for conspiracy to defame is still valid even after the one year statute of limitations for defamation has run if filed before the two year statute of limitations for conspiracy. While the statute of limitations bars recovery for the defamation claim, it does not extinguish all liability. A person will qualify as a Limited Public Figure for the purposes of defamation, even though the other party started the controversy by initiating a letter writing campaign, if he participates in the public controversy by participating in interviews and writing letters of his own in response.