Janice gave an interview to the Times publicly accusing Bob, a prominent actor, of sexually assaulting her. Bob's attorney responded on his behalf by releasing a public statement. In the statement, Bob's attorney called Janice a "liar" and accused her of extorting Bob for financial gain. Janice brought a state law defamation claim against both Bob and his attorney. What standard of fault is a court likely to require for Janice's defamation suit? A. Negligence, because Janice is a private individual. B. Negligence, because Sullivan v. New York Times requires actual malice only for public officials. C. Actual malice, because Janice is bringing a claim against both Bob and his attorney. D. Actual malice, because Janice is a limited-purpose public figure who voluntarily thrust herself into a public controversy.