In this action against Telerep, Inc., her former employer, and others, plaintiff asserted eight causes of action, including, inter alia, constructive discharge and breach of an employment contract, as well as tortious interference. In the seventh and eighth causes of action, plaintiff sought damages for defamation and intentional infliction of emotional distress. After answering, defendants, in a document request, sought "[a]ll documents concerning [plaintiff's] allegation...
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