KAREN LECRAFT HENDERSON, Circuit Judge:
Linda Jacobs (Jacobs), an employee of the United States General Services Administration (GSA), sued her long-time supervisor, Michael Vrobel (Vrobel), in the District of Columbia Superior Court for defamation and interference with her attempts to secure alternative employment. Because Vrobel was then (and remains) a federal employee, Jacobs's lawsuit was not a garden-variety tort suit. Instead, pursuant to the Westfall Act,...
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