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In a federal defamation action, Plaintiff alleges that Defendant falsely wrote that Plaintiff was dishonest in business. Truth is a complete defense under the governing substantive law. Defendant seeks to prove that Plaintiff was in fact dishonest in business by offering several specific incidents in which Plaintiff falsified invoices and lied to customers. Plaintiff objects that character can be proved only by reputation or opinion.
Which statement is most accurate?

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