MEMORANDUM OPINION AND ORDER
JOYCE HENS GREEN, District Judge.
These consolidated cases arise from the transmittal of an allegedly libelous memorandum to an official of the Congressional Research Service. The memorandum was created by an employee of defendant Sun Company and sent to various individuals within the company including defendant Anthony L. Anderson, who forwarded it to Congressional Research Service (CRS) official David M. Lindahl. It contained...
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