Mr. Smith is the owner and operator of a consultation company. Due to a downturn in business, he decided to terminate the employment contract of Ms. Jones. Smith softened the blow by giving Jones three months' pay to end their contract. This was all he was required to do by law and is not subject to criticism on this front. Smith had always held a very good opinion of the quality of Jones's work, but he learned subsequent to her departure that she was combative with junior employees and even somewhat of a bully. The source of this negative information was an employee of his consultation company who had personally witnessed, on a few occasions, thatJones treated support staff poorly. Meanwhile, Jones immediately began looking for a replacement job and held out high hopes of being hired by a company called Consults With Results, Ltd (Consults). This is because after her interview with Consults, Jones was told by the HR manager that she was ranked the first candidate for the job but had to check out Jones's references before an official offer could be made. Jones gave Smith's name as a reference. When the PR manager contacted Smith, he passed along the negative information regarding Jones's treatment of junior employees and also that the quality of Jones's work was generally up to standard. Additionally, he advised the PR manager that there was "no way" he would hire Jones again. Concerned about Jones's interpersonal skills, the PR manager of Consults did not make an offer of employment to Jones. Jones has now sued Smith for defamation. What will Jones have to prove to succeed? What defenses does Smith have?