staff and to the public were part of an overt, coordinated campaign and conspiracy among the defendants.” (ComplJ 94). Second, they contend Cox should be liable for Marlatt’s actions because her actions were at Cox’s direction or done with his approval (ComplY 96.) Third, they claim Cox is culpable for the negligent supervision of Marlatt “in thus allowing, participating in, authorizing, directing and/or approving her actions as described herein ... such conduct amounts to express or tacit authorization of said conduct.” (Compl.f 97.) Even if Plaintiffs were to succeed in showing the statements were defamatory, they cite no authority in support of finding Cox liable on the basis of the statements made by others. See Berry v. Stevinson Chevrolet, 804 F.Supp. 121, 133-4 (D.Colo. 1992) (<HOLDING>). The only communication Defendant Cox was
holding that reversal for a new trial on liability is appropriate only where the error complained of affects only the issues of liability holding that bivens liability does not extend to a corporate entity because the deterrence rationale applies only to individual actors holding that connecticut courts look to the identity or instrumentality test to determine whether one corporate entity can properly be held responsible for the obligations of another corporate entity holding mere status as a director does not create liability where the actions complained of were taken by individual managerial employees of a corporate entity recognizing the right of a creditor to sue a corporate director for breach of fiduciary duty