[brief] This independent review can lead to only one conclusion: Plaintiff has failed to meet the pleading standard articulated in *Neuwirth v. State*, 476 N.J. Super. 377 (App. Div. 2023), and predecessor cases.  Though Plaintiff urges this Court to ignore its own precedent and defer to the erroneous rulings below, it is clear that the Complaint asserts no “facts from which a factfinder could conclude” that each of the [...] knew, or had serious doubts about, the veracity of the allegedly defamatory statements they made.  *Id.* at 392-93.  Indeed, in her Opposition (“Opp.”) Plaintiff appears to concede that her arguments in support of actual malice rest largely on patently insufficient claims of corrupt motive and failure to sufficiently investigate, as well as conclusory boilerplate language.  In an attempt to justify this dearth of facts supporting actual malice, Plaintiff concocts a false scenario wherein every Challenged Statement made by the [...] was a “wholly unbelievable” fabrication.  The Complaint’s own allegations flatly preclude such a finding.  Indeed, Plaintiff even admits that a version of the Incident—one on its face prone to being viewed differently by those involved—actually occurred, pleading in her Complaint that she touched her young student’s hijab without the girl’s consent and exposed her hair.  While Plaintiff’s and [...]’s accounts of the impact and aftermath of these events may differ, the core facts of the Incident are hardly unbelievable.  In fact, they indisputably occurred.  Moreover, by her own admission Plaintiff was subsequently put on administrative leave and criminally investigated—circumstances inconsistent with any theory that Muhammad’s account was wholly unbelievable.  Plaintiff’s Opposition also admits unreservedly that the [...] relied solely upon the account published by Muhammad—a person the Complaint describes as having a stellar reputation both in [...] and nationwide, and for whom Plaintiff herself had great “affinity and respect. ”  By Plaintiff’s own allegations, therefore, the [...] had every reason to believe Muhammad’s statements about the Incident.  Tied down by these admissions, Plaintiff now bizarrely claims that Muhammad should not have been trusted “precisely because of her public reputation and advocacy work. ”  Opp. at 25.  Yet she offers no law—or even logic—supporting a theory that a person’s positive reputation and widely admired advocacy work should cause them to be mistrusted.  [...]’s allegations concerning the subjective state of mind of Muhammad, a public figure whose social media posts were the source for the [...]’ statements, moreover, say nothing about the subjective state of mind of any of the [...].  The court below erroneously imputed Muhammad’s alleged subjective knowledge to the [...], in contravention of long-settled constitutional principles.  Plaintiff now hopes this Court will do the same.  It should unequivocally decline.  Having exhausted her legal and factual arguments, Plaintiff attempts to manufacture outrage based on facts outside of the pleadings and unconnected to the Incident.  Rather than bolstering her case, her attempts at inflaming personal passions expose the weakness in her arguments.  As the saying goes, “when neither the law or the facts are on your side, pound the table. ”  As this Court can easily recognize, this case is not a referendum on current international events.  It is a simple matter of defamation law.  The question before this Court is whether Plaintiff can survive a motion to dismiss where she is required, but has failed, to plead facts supporting a theory of actual malice as to each defendant.  Under settled caselaw, she cannot.