In the underlying action, plaintiff, a former resident in the Internal Medicine Residency Program at Cabrini Medical Center, alleged that she was injured in her professional reputation as a physician and defamed by a statement contained in a discrete internal memorandum of the Committee of Interns and Residents (CIR), an independent labor union, written by the CIR executive director, defendant Jonathan House, and circulated within CIR only to CIR's general counsel, Irwin...
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