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Defamation is false statement which is verbal or written to another person that is intended to cause harm to an individual. For Dan construction to be held liable for libel defamation on Richard, then it has to be false that Richard is not a careless driver. In regard to this definition, the letter written to construction union does not fit to this definition, notably because it was not a false statement; Richard is a reckless and a careless driver and any employer should be aware of him. Employers often request previous employers for recommendations and that Richards case is just a prior recommendation for prospective future employers which could have been requested anyway when he sought employment from any of the union members.

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