ELDRIDGE, Judge.
This case concerns the appropriate standard, under Maryland common law, for the allowance of punitive damages in defamation actions.
In late 1987 Francisco Valentin, having lived all but the first year of his life in Puerto Rico, moved to New York City in the hopes of improving his limited mastery of the English language and in search of better job opportunities. He immediately went to work as a stock room clerk at Le Marc's Fifth Avenue Cards...
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