Gail Davis worked as an executive assistant to Motown legend, Diana Ross. After about a year, the woman voluntarily resigned. About a year later, Diana Ross wrote and distributed the following letter:
“To whom it may concern:
The following people are no longer in my employment.
[list of former employees including Gail Davis]
If I let an employee go, it’s because either their work or their personal habits are not acceptable to me. I do not recommend these people. In fact, if you hear from these people, and they use my name as a reference, I wish to be contacted.”
Gail Davis had not used Ms. Ross as a reference, nor had any employer requested information from her about Gail Davis.