Deborah Galarneau was hired as a Financial Advisor trainee by the Portland, Maine branch office of Merrill, Lynch, Pierce, Fenner & Smith (ML) in February 1989. She became a Financial Advisor (FA) in 1991. Beginning in 1998, Galarneau and her husband worked as a team called the “Galarneau Group.” Amy Ford, a client of the Galarneau Group, sent ML a letter in 2003, in which she accused the Galarneaus and ML of “churning” her account. A lengthy internal investigation, as well as an investigation by Maine’s Securities Division, followed. ML settled with Ford in 2003 and terminated Deborah Galarneau in January 2004. ML told her that she was being terminated because of (1) her exercise of time and price discretion; (2) her prior history, as reflected in two personnel memos and “prior warnings”; and (3) the judgment she used in trading in the Ford account. No specific reference was made to inappropriate trading, excessive trading, or churning. On February 6, 2004, ML filed a Uniform Termination Notice for Securities Industry Registration (Form U-5) with the National Association of Securities Dealers, as required by NASD rules whenever a registered stockbroker leaves a firm. In the Form U-5, ML stated the reason for terminating Galarneau as follows: “Ms. Galarneau was terminated after the firm concluded that she had (I) engaged in inappropriate bond trading in one client’s account and (II) utilized time and price discretion in the accounts of three clients.” This was followed by a statement disclosing that Galarneau disagreed with the firm’s conclusions. After Galarneau was terminated, she tried unsuccessfully to find employment as a stockbroker at Smith Barney, Edward Jones, and Morgan Stanley. Is ML liable for defamation? [Galarneau v. Merrill Lynch, 504 F.3d 189 (1st Cir. 2007).]