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Ruddell v. Viscia
This is the second appeal following a complaint filed by plaintiff Dane Ruddell against defendant George Viscia alleging defamation, intentional interference with prospective economic advantage, and intentional infliction of emotional distress. The complaint was based on a letter Viscia wrote and sent to at least one of Ruddells clients or prospective clients stating Ruddell had been terminated from his prior employment with a school district and engaged in questionable business dealings with at least two school districts. Viscia filed a special motion to strike the complaint under Code of Civil Procedure section 425.16. The trial court denied the motion, concluding that Viscia failed to make a prima facie showing that the letter was connected to a public issue. In the first appeal, we disagreed with the trial courts conclusion and reversed and remanded the matter to the trial court to determine whether Ruddell could demonstrate a probability of prevailing on his claims. (Ruddell v. Viscia (Aug. 31, 2006, C049043) [nonpub. opn.], pp. 12-13.) On remand, the trial court again denied the motion, concluding that Ruddell had met his burden of demonstrating that the complaint is both legally sufficient and supported by a sufficient prima facie showing of facts.

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