Cary, a Prominent Local Attorney, Was the Subject of a Newspaper

Cary, a prominent local attorney, was the subject of a newspaper article concerning a trial in which he was involved as counsel. In that article, Cary was reported to have been disbarred in another state ten years previously. It is not true of Cary, but of his cousin, Frank. Cary will win a suit for defamation against the newspaper:

A) simply by proving the falsity of the statement.
B) only if Frank was not disbarred.
C) only if he can prove that the paper acted with actual malice.
D) by only showing that harm to his character resulted from the statement.