California, United States of America
The following excerpt is from Franco v. Otto Nemenz Int'l, Inc., B219350 (Cal. App. 2011):
Plaintiff argues that as the court erred in ruling she could not establish a discrimination or harassment claim, it also erred in ruling for defendants on this cause of action. As the court did not err in its ruling on the causes of action for discrimination and harassment, it did not err in its ruling on this cause of action. (See Trujillo v. North County Transit Dist. (1998) 63 Cal.App.4th 280, 288-289.)
"Defamation" is the "intentional publication of a statement of fact that is false, unprivileged, and has a natural tendency to injure or which causes special damage." (Smith v. Maldonado (1999) 72 Cal.App.4th 637, 645.)
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