- Consent: Express/implied, capacity, scope)
- Truth: Factually accurate
- Privileged communications: Who (absolute) and when (qualified—strong social interest in encouraging candor: (i) confidential communication to another (ii) concerning a 3rd-party (iii) in which both have a legitimate interest)
Who is privileged—spouses, government officers engaged in conduct of their official duties
When is the statement protected—Strong social interest in
encouraging candor, and ∆ reasonably believes that the statement is
accurate (e.g., letters of recommendation)