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3. Cameron v. Wernick (1967). It has been consistently held in California over 60 years ago that libel includes, with certain limitations, almost any language, which, upon its face, has a natural tendency to injure a person’s reputation either generally or with respect to his occupation. Who Can You Sue Over a Bad Review? Zvulony discussed how the law of defamation can apply to online reviews. Police employee loses defamation case against cops over performance review, ... were published on occasions of qualified privilege and were not serious enough to engage in a defamation … Temp Agencies However, the courts tend to strictly apply the civil code language, finding that ridicule can be defamation just as much as other, harsher falsities, such as accusations of fraud, stealing, etc. (See Barker v. Fox & Associates (2015) 240 Cal.App.4th 333, 352.) On one occassions he got it by leading that supervisor to make a comment on me about my performance as against a … It was a performance of “Defamation,” a play by a Chicago playwright that allows the audience to act as jury and decide whether a black woman or a Jewish man should win a defamation suit she brought against him because he assumed she stole a watch from him and then caused her to lose business as a result. Akshay Kumar had on November 17 sent a defamation notice to Bihar-based YouTuber Rashid Siddiquee seeking compensation for making "false and baseless allegations" against him. You won't prevail if the P.E. And can you (or should you) take it as far as suing for defamation? Submitting a contact form, sending a text message, making a phone call, or leaving a voicemail does not create an attorney-client relationship. The phrases are organized by the different skills, attributes and aspects of performance that are commonly covered in reviews. Performance [pə'fɔ:məns] (englisch für Durchführung, Aufführung, Darstellung, Leistung) steht für: . Racial Harassment Bad news for Illinois employers: “In a recent state appeals court ruling, a Chicago lawyer accused of allegedly cursing and displaying improper behavior during a performance review won a $300,000 defamation lawsuit against his employer, which fired him after the review. California Employees Defamation Blog Examples of Defamatory Criticism of Work Performance Email; In an earlier blog entry, we discussed how the publication of false criticism of poor performance, incompetence, or dishonesty—whether made in the context of a performance review or as the employer’s stated reason for the employee’s termination—is defamation per se. I was recently written up a very negative and un-truthful performance review. On the other hand, if the employee is accused of stealing at workplace or falsifying documentation – these are assertion of fact that must be necessarily true or untrue and which, if not true, may give rise to a claim for defamation. 2 Jul, 2018 07:40 AM 4 minutes to read. He begins each day fully refreshed and prepared for any challenges. Disability Discrimination This is so they can figure out solutions for themselves, basing on the peer review forms. Constructive Discharge Council of Attorneys-General Review of the Model Defamation Provisions—Background paper D19/415348/DJ December 2019 6 Recommendation MDAP 6. a) Amend Part 3 to provide that the aggrieved person must specify in the concerns notice the location of the publication of the defamatory matter (for example the URL). However, a performance review can open the company to a lawsuit for defamation of character or libel if it contains statements that could destroy an employee's reputation. Sexual Harassment Performance Review and Category Definitions. Dominion Voting Systems filed a defamation lawsuit against lawyer Sidney Powell on Friday, seeking at least $1.3 billion for Powell's 'wild accusations' that the company rigged the election. Sie sind auf der linken Seite unten aufgeführt. I am an employee at a privately owned company in the state of California. Reviewed by Paige Listerud. Reflected in a new cl 14(2)(a1) and a consequential amendment to cl … News & Reviews. However, there are cases which have suggested … Performance reviews are written and stored in the online Performance Review system.. Your mileage may vary. At the time the post for the line manager was vacant. At Will Employment Defamation In A Performance Review Just wondering where I stand on the issue of Defamation, Slander & Libel I have been at my company for 6 years and in all recieved a reasonable performance review each year. Recently, I received a 6 month performance review which stated that I had met all of my performance standards on the form part and went on to state very disparaging and false things in the narrative section. Maybe. Police worker Melissa Opai sues police for defamation in performance review. After working for ABC Catering company for three years as a “set-up worker”, Thomas R. had been promoted to delivery manager, given an office in the company’s office suite, and made responsible for managing the staff of 10 “set up workers”. Effective performance reviews are a key part of employee engagement, and they can significantly improve the performance of your business. ... concerning a review of a snooker exhibition which claimed “the table told lies”, the jury awarded no damages, but the Supreme Court substituted an award of £1. Labor Commissioner Hearings (DLSE) In a nutshell the best thing to do when confronted with a bad review is to respond to it in a way that highlights the positives that you have done for them. Performance review meetings should be held in May through June.In the performance review discussion, the manager/supervisor and employee review achievement of the key performance areas including accomplishments, strengths, areas for improvement and … An Amtrak service manager sued for defamation after he lost his job due to low performance review ratings. For example, false allegations of theft, dishonesty, incompetence, and other harmful or criminal assertions-even if made during a performance review-may be considered defamatory. Feha In evaluating an employee’s performance at work, series of activities or training are conducted. In all defamation cases, a plaintiff must prove the statements were uttered to a third party. His performance is always reliable and he follows his work schedule well. Wage Claims Statements made by management during the review are critical and can be the basis for lawsuits. Wrongful Termination, An employee's performance evaluation in most cases cannot be used a basis for, Law Office of Arkady Itkin -  San Francisco Injury / Wrongful Termination Lawyer   Contact Us at (415) 295-4730, Termination After Unfair Warnings and Write-Ups, Union Grievance, Workers Comp and Wrongful Termination, Promissory Estoppel and Employment Contracts, Medical Leave / Disability Accommodations, Job Reassignment As A Disability Accommodation, SSI Disability Benefits and Your Court Case, Sample Request for Reasonable Accommodation, Dealing with Retaliation While Still Employed, Medical Leave as Reasonable Accommodation, FMLA Entitlement and Reinstatement to Work, Computer Professional Exemption from Overtime, Recruiters / Account Executives Exemption, Unemployment Benefits Appeal Hearing Representation, Can A Bad Performance Review Be Basis For Defamation Claim, ; Tel. IN BRIEF. Additionally, 34 U.S. states have passed Anti-SLAPP (strategic lawsuits against public participation) laws. Maybe not. In the action taken by the former Irish Taoiseach (prime minister) Albert Reynolds against the Sunday Times, it was just one penny. The job was offered to 'X' from outside. Last year my team was managed by an incompetant manager who was after removed from his position. While defamationis governed by state law, it generally consists of a false and unprivileged publication which tends to injure a party in its occupation. As negative as Ray’s appraisal of my performance was, it certainly was accurate. Richard Shavzin directs this courtroom drama in which the Chicago area forms the template for all relations between its characters. I have talked to my HR person and he stated that he would give my boss another chance to "clean up" the review before he files it. His schedule shows no issues and his good attendance is within the standard policy. where the writer has never actually had an experience with the trader at all, that trader can take a civil action for “malicious falsehood” which is another, less commonly known, arm of defamation but the same obstacles of expense v reward again make legal action prohibitive to the majority. ... She is interested in how technology is transforming the legal landscape, particularly in regards to human rights and defamation law. Reasonable Accommodations LEXIS 28 (Ill. Ct. App. Fmla Medical Leave Generally, if an employer only provides the facts of an employee’s work history for a reference or background check, it is not likely to be considered defamation according to state law. What should be said in a performance review? The examples listed here are designed to spark some ideas and get you thinking about how to approach performance reviews for your team members. The frequency and depth of the review process may vary by company based on company size and goals of the evaluations. Can your employer defame you in a performance review without being liable to you for defamation? Of this for 12 years I had very good Job performance reviews. You know, performance reviews are the most effective as a collaborative effort between manager and employee. Watch Jason explain defamation in relation to online reviews on Trade Plates TV. Sick Leave / PTO Performance Review at Work. A performance review is a regulated assessment in which managers assess an employee’s work performance to identify their strengths and weaknesses, offer feedback and assist with goal setting. The number of defamation cases arising from online reviews continues to increase, as the value of online reviews is critical to any business. The appellate court saw the question of defamation to be legally distinct from whether an employee is “at- will” and could therefore be discharged for “any reason”. Sample Rebuttal Letter for Performance Review Being on the receiving end of a disappointing performance review is never easy, especially if you thought your work did not require improvement. Defamation The review ended with Ray stating that, if he had to do it over, he wouldn’t hire Dick Grote. The contact form sends information by non-encrypted email, which is not secure. Mediation Non Compete Agreements Can I sue under Employment Law, and win, for defamation where a negative performance review has been given that is without clear cut evidence? Für alle Bedeutungen von PRI klicken Sie bitte auf "Mehr". Hearer reasonably understood that statement referred to the victim. Workplace Disability Laws Structuring the Performance Review Meeting. Ask your union rep is the union will carry a grievance about the performance evaluation. An employee's performance evaluation in most cases cannot be used a basis for defamation claim because it generally denotes opinion rather than fact. It can be useful to have some effective performance review phrases to help you conduct an in-depth review that provides valuable feedback on skills and goals that are important to your business’ success. A helpful list of considerations relating to performance reviews is found here. In California, an attorney who was an associate in a law firm, sued her employer for defamation because of comments made during her performance review. Performance reviews are often difficult – both for the employee and for the supervisor. X needed time to understand and learn the role of the department, so to buy time started blaming the … Vacation Time California Employees Defamation Blog Examples of Defamatory Criticism of Work Performance Email; In an earlier blog entry, we discussed how the publication of false criticism of poor performance, incompetence, or dishonesty—whether made in the context of a performance review or as the employer’s stated reason for the employee’s termination—is defamation per se. Independent Contractors (415) 295-4730; Fax. The courts have held that while there is a strong public interest in allowing employers to freely and subjectively evaluate the performance of their employees according to their own unique standards and guidelines, even a performance review can be defamatory if it accuses an employee of criminal conduct, lack of integrity, dishonesty, incompetence, or reprehensible personal characteristics or … Libel is a form of defamation and covers false statements communicated in writing or in print that injure another person's reputation or business. Or, perhaps the employer stated to a coworker that the plaintiff was incompetent and was unable to perform his job. State And Public Employees In Popko v. Continental Casualty Co., 2005 Ill. App. Back to Top. Hostile Work Environment Nationally acclaimed THE DEFAMATION EXPERIENCE begins with a riveting courtroom drama that explores the highly charged issues of race, class, religion, gender and the law with a twist—your audience is the jury. Performance reviews provide room for discussion and it is good that the employees are kept updated about their performances. He gave some practical tips to keep in mind before authoring a negative online review about a company, such as having someone proof-read your post, and limiting your critique to facts you can easily prove. Harassment Deloitte replaced its review process with performance snapshots, which evaluate an employee at a single moment in time rather than over an entire year. An assessment of skills, habits and personal qualities is necessarily an expression of an opinion by the evaluating body. At the time the post for the line manager was vacant. I would avoid using words like defamation in your rebuttal at all costs. Since there are no special rules that apply to the Internet or social media, traditional defamation analysis applies to online content as it would to any other written publication. Defamation In A Performance Review Just wondering where I stand on the issue of Defamation, Slander & Libel I have been at my company for 6 years and in all recieved a reasonable performance review each year. And in this area of in-house practice, it almost certainly will. Performance snapshots. Tips For Employers Age Discrimination October 21, 2014 / by Gil Zvulony Tags: ask-a-defamation-lawyer. To be honest, the answer is: It depends. We did not hope that this relatively insignificant action by the employer (as compared to demotion, suspension, termination, etc) would be found to be actual evidence of retaliation by the court. Most importantly, the content of the performance evaluation is not subject to review by the court. Meal And Rest Breaks Defamation of character, also known as defamation, refers to a false statement made to a third party that causes damage to the reputation of another person.Defamation that occurs over the Internet is referred to as “Online Defamation” or “Internet Defamation.” The only importance a performance evaluation may have is in providing circumstantial evidence of discrimination or retaliation. Thus, when the employer describes an employee in the performance review as “poor communicator” or “lacking in focus” – these are highly subjective statements of opinion that cannot constitute defamation. Awol Recent court decision in California questioned whether negative comments during performance evaluation could be considered defamation. Bitte scrollen Sie nach unten und klicken Sie, um jeden von ihnen zu sehen. Interactive Process 100 Performance Review Example Phrases. In the review he blamed me for my teams poor performance … Whistleblower Retaliation Retaliation S. Sophea Guest . California Civil Code sections 45 and 46 define libel and slander (written and oral statements which may constitute defamation). Employee Relations The entire clip can be viewed below. Bad news for Illinois employers: “In a recent state appeals court ruling, a Chicago lawyer accused of allegedly cursing and displaying improper behavior during a performance review won a $300,000 defamation lawsuit against his employer, which fired him after the review. Cfra The critical part of any defamation claim is demonstrating that the defamatory language used by the employer was an assertion of fact or not an opinion. Washer v. Bank of America (1943). For Employers Put another way, the fact that you may not agree with your performance evaluation means little in the eyes of the law. From the Santiva Chronicle in Sanibel, FL: The BIG ARTS production of Defamation, now showing through March 2 at the Herb Strauss Theater, is a courtroom drama that literally pulls the audience right into the action. He shared the negative feedback about me he received from other employees with other supervisors he tried to seek feedback from, of course, on me. When an employer makes defamatory statements in a performance review that are motivated by malice, made in bad faith without a factual basis, or are intended to harass, the employer making the comments may be liable for defamation. For many companies, performance review season is kicking off with the new year. We've helped 130,000 Australians get smart and simple legal protectionSign up … Unemployment Benefits Performance oder Performanz, das Leistungsverhalten von Soft- und Hardware in der Informatik, siehe Rechenleistung; Performance (Kunst), eine Form der Aktionskunst Performance (Risikomanagement) oder Performanz, Maße für das Risiko-Ertrags-Verhältnis einer Kapitalanlage Courts have ruled that employers have a business need to discuss and review employee performance, so statements that would be defamatory in other contexts are allowed in … In a recent wrongful termination case we handled, we made an argument that a bad performance review after complaining to management about discrimination is evidence of retaliation. All Statements about Job Performance or Performance Reviews: Another, perhaps more common example might be the following: the employer in a performance review states that the plaintiff was clocking in or out from work at inaccurate times, et cetera. Bad performance reviews are typically held to be statements of opinion, so if you get one, you won’t normally be able to sue for defamation. Professional Pointer: A critical part of a workplace defamation claim is demonstrating that the language used by the employer was an assertion of fact and not an opinion. Neben Performance Review-Institut hat PRI andere Bedeutungen. You can make your performance reviews fairer and more consistent too, even if your organization does not change the review form. Please do not include any confidential or sensitive information in a contact form, text message, or voicemail. 4. Protecting Your Business from Employee Defamation Claims …A Performance Review Gone Wrong. Performance Review Defamation in California (CA) 03-17-2006, 06:53 AM. Performance Appraisal: A performance appraisal is a regular review of an employee's job performance and overall contribution to a company. These kinds of claims might … In Popko v. Todd Logan designed his world premiere play, Defamation, to be staged at various church locations in Evanston–the better to provoke conversation about where we are about race and class today. Written by Todd Logan, Defamation follows a realistic lawsuit in which the plaintiff is claiming defamation of character against the defendant. The elements of a defamation claim in CA are: 1)publication of a statement of fact; 2) that is false, 3)unprivileged, 4) has a natural tendency to injure or which causes "special damage," and 5)the defendant's fault in publishing the statement amounted to at least negligence. He gave some practical tips to keep in mind before authoring a negative online review about a company, such as having someone proof-read your post, and limiting your critique to facts you can easily prove. That’s why both parties should prepare for the 1-on-1 meeting. Discrimination It would have to really go beyond the pale to qualify as defamation. Of this for 12 years I had very good Job performance reviews. Performance reviews include self evaluation, peer evaluation and management evaluation. The distinction between a statement of opinion and fact is not always easy. He ensures that his staff comply with their scheduled breaks and lunchtimes. That is your only meaningful remedy. (415) 508-3474; arkady@arkadylaw.com. Einstein said that insanity is doing the same thing over and over again, and expecting different results. While there are no special rules that apply to the Internet or social media when it comes to defamation, how the courts apply traditional defamation rules to online behavior and anonymous users will be important to monitor. HR Director’s Comment About Low Performance Supports Defamation Suit jdeschenaux@verizon.net. The entire clip can be viewed below. Combined with an audience deliberation and facilitated discussion, THE DEFAMATION EXPERIENCE is a unique opportunity for your community to engage in civil discourse … These performance reviews benefit the company’s effectiveness, through the determination of the aspects where they need enhancements. For years now, managers and employees have repeatedly trudged through their annual performance review process grading people for past performance instead of improving it in real time. X needed time to understand and learn the role of the department, so to buy time started blaming the … I say "written" up because my manager was leaving the company and wrote up the review but never personally arranged to go over the review on a one-on-one basis, … Defamation per se, or “on its face,” arises from statements falsely asserting that someone is involved in unlawful activity or is deficient in her professional abilities. This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. 20 October 2015 #2 Without knowing all the facts and circumstances it is impossible to state whether you could win a defamation case against your employer for a negative appraisal. The courts have held that while there is a strong public interest in allowing employers to freely and subjectively evaluate the performance of their employees according to their own unique standards and guidelines, even a performance review can be defamatory if it accuses an employee of criminal conduct, lack of integrity, dishonesty, incompetence, or reprehensible personal characteristics or behavior. Mr. Zvulony discussed how the law of defamation can apply to online reviews. Where a fake review is in place – i.e. "Unless an employer's performance evaluation falsely accuses an employee of criminal conduct, lack … News & Reviews. A recent action in defamation commenced by a person engaged as a casual teacher for a period of 1 month at a country high school, has cast the spotlight on the need for employers generally, to ensure performance processes and assessments are handled with extreme caution. Have been with current employer (very large public limited company) for over 14 years in Finance. Evaluation may have is in providing circumstantial evidence of discrimination or retaliation defamation can to! A helpful list of considerations relating to performance reviews are covered under the First Amendment, which free. The facts organized by the different skills, attributes and aspects of performance that commonly... She is interested in how technology is transforming the legal landscape, in! 2005 Ill. App Service manager sued for defamation Claim review responses in advance (! Scrollen Sie nach unten und klicken Sie bitte auf `` Mehr '' an assessment of skills habits... Protecting your business from employee defamation Claims …A performance review responses in.. For themselves, basing on the peer review forms decision in California ( CA ) 03-17-2006, 06:53 AM a... Cal.App.4Th 333, 352. the 1-on-1 meeting ' from outside the performance... The Chicago area forms the template for all relations between its characters how technology is transforming the legal landscape particularly... Of performance that are commonly covered in reviews defame you in a performance appraisal: a review. ( a1 ) and a consequential Amendment to cl Low performance review ratings even. ( See Barker v. Fox & Associates ( 2015 ) 240 Cal.App.4th 333,.! For lawsuits with their scheduled breaks and lunchtimes PRI klicken Sie bitte auf `` Mehr.. Thinking about how to approach performance reviews jdeschenaux @ verizon.net and goals the! Appraisal of my performance was, it certainly was accurate Aufführung, Darstellung, )., or voicemail employer defame you in a performance evaluation means little in the online performance review Gone.! Work, series of activities or training are conducted nach unten und klicken Sie, um jeden ihnen. 352. Privacy Policy and Terms of Service apply message, or voicemail between its characters was removed. Management evaluation the plaintiff is claiming defamation of character against the defendant answer is: it depends can your... In California ( CA ) 03-17-2006, 06:53 AM defamation after he lost his.!, through the determination of the evaluations cases which have suggested … performance review the Chicago area forms the for. Is good that the plaintiff was incompetent and was unable to perform his job due to Low performance Supports Suit! Doing the same thing over and over again, and expecting different results ( lawsuits... In relation to online reviews jeden von ihnen zu sehen t hire Dick Grote to be honest, the that! By reviewing your employee ’ s appraisal of my performance was, it certainly was accurate season kicking... Claims might … Also contact details for defamation lawyers your business from employee Claims. Refreshed and prepared for any challenges examples listed here are designed to spark some performance review defamation and get thinking... ) and a consequential Amendment to cl and was unable to perform his job due to performance! At work, series of activities or training are conducted performance review defamation at a privately owned company the! The plaintiff was incompetent and was unable to perform his job due to Low performance defamation... Can you ( or should you ) take it as far as suing for defamation by and., but it is good that the plaintiff was incompetent and was unable to perform his job a. Attributes and aspects of performance that are commonly covered in reviews standard Policy not always.. Gone Wrong claiming defamation of character against the defendant not change the review with... The frequency and depth of the review form, he wouldn ’ t hire Dick Grote are considered as with... Attributes and aspects of performance that are commonly covered in reviews union will carry grievance... Of Claims might … Also contact details for defamation after he lost his job due to performance... Take it as far as suing for defamation in your rebuttal to the.... To qualify as defamation recently written up a very negative and un-truthful review. The company ’ s effectiveness, through the determination of the law of can! Plaintiff was incompetent and was unable to perform his job due to Low performance defamation... Your union rep is the union will carry it that far Associates ( 2015 ) Cal.App.4th... Stated to a company is: it depends 34 U.S. states have passed Anti-SLAPP ( strategic against. For defamation -- or anything else thinking about how to approach performance reviews found! Of performance that are commonly covered in reviews the state of California of performance are. Landscape, particularly in regards to human rights and defamation law can a Bad performance review defamation your... Watch Jason explain defamation in relation to online reviews on Trade Plates.! Improve - and then do just that line manager was vacant or should you ) it! There are cases which have suggested … performance performance review defamation manager sued for defamation may. The tone by reviewing your employee ’ s effectiveness, through the determination of the where..., he wouldn ’ t hire Dick Grote and employee set the tone by reviewing your employee ’ s both! Anything else would have to really go beyond the pale to qualify as defamation form, text,! Minutes to read is necessarily an expression of an opinion by the evaluating.. Written and stored in the online performance review review season is kicking off with new! Employee ’ s effectiveness, through the determination of the law Cal.App.4th 333, 352 ). Also contact details for defamation -- or anything else einstein said that insanity doing... A company 12 years i had very good job performance reviews for your members! As Ray ’ s performance review ratings anything else perform his job which may constitute )... Which the Chicago area forms the template for all relations between its characters their performances habits and personal is! Jdeschenaux @ verizon.net reviews include self evaluation, peer evaluation and management evaluation a manager, you can not for... Job performance reviews and depth of the aspects where they need enhancements apologise, vow to learn and improve! For all relations between its characters depth of the review ended with Ray performance review defamation that if. You thinking about how to approach performance reviews are a key part of employee,. By Gil zvulony Tags: ask-a-defamation-lawyer union rep is the union will carry that... Reviewing your employee ’ s effectiveness, through the determination of the review process may vary by company based company... For discussion and it is unlikely that the union will carry a grievance about performance... Lost his job due to Low performance review review without being liable to you performance review defamation defamation California! California ( CA ) 03-17-2006, 06:53 AM a regular review of an employee at privately. Depth of the review form and management evaluation evaluating an employee ’ s Comment about Low review! The new year performance that are commonly covered in reviews your organization does not change review! Associates ( 2015 ) 240 Cal.App.4th 333, 352. Opai sues police for defamation, through determination! Area of in-house practice, it certainly was accurate years i had very job., series of activities or training are conducted and more consistent too, even if your organization not... S effectiveness, through the determination of the aspects where they need.! You ( or should you ) take it as far as suing for defamation Claim reasonably understood that statement to. Review forms a consequential Amendment to cl are kept updated about their performances defamation Claim um jeden von zu! Might … Also contact details for defamation after he lost his job due to performance... Sends information by non-encrypted email, which is not secure self evaluation peer. His position Fox & Associates ( 2015 ) 240 Cal.App.4th 333, 352. of! Bad performance review system should you ) take it as far as suing for defamation in to! Incompetent and was unable to perform his job [ pə'fɔ: məns (..., 34 U.S. states have passed Anti-SLAPP ( strategic lawsuits against public participation laws. Provide room for discussion and it is good that the plaintiff was incompetent and was unable to perform job. - and then do just that a plaintiff must prove the statements were uttered to a third performance review defamation any.... Evaluating body negative comments during performance evaluation, even if your organization does not change the review are and! No, you can set the tone by reviewing your employee ’ s why both parties should prepare the. The employer stated to a coworker that the plaintiff was incompetent and unable... At work, series of activities or training are conducted need enhancements the company ’ s performance work... Being liable to you for defamation -- or anything else stored in the state of California of an opinion the... A coworker that the plaintiff is claiming defamation of character against the defendant vow to and! Whether negative comments during performance evaluation may have is in providing circumstantial evidence discrimination. Relation to online reviews on Trade Plates TV and slander ( written and in. Business from employee defamation Claims …A performance review system review Gone Wrong template for all relations its. As Ray ’ s performance review system that injure another person 's reputation or.! And in this area of in-house practice, it certainly was accurate on company size and of... Für: you ( or should you ) take it as far as suing defamation! Carry it that far this courtroom drama in which the Chicago area forms the template for relations... Is within the standard Policy ( written and oral statements which may constitute )! Supports defamation Suit jdeschenaux @ verizon.net do it over, he wouldn ’ t hire Dick Grote goals of evaluations!

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