In McKinney v. County of Santa Clara (1980) 110 Cal.App.3d 787, the plaintiff argued that "having given allegedly false reasons to appellant for his dismissal, it must have been foreseeable to respondents that appellant would be under a strong compulsion to republish the statements to prospective employers upon their inquiry." (Id. at p. 795.) Relying upon the rule that ordinarily the originator of defamatory material is also liable for each such repetition if he could reasonably have foreseen the repetition (Di Giorgio Corp. v. Valley Labor Citizen (1968) 260 Cal.App.2d 268, 273 67 Cal. Rptr. 82), the McKinney court held, on a summary judgment motion basis, that two republications that had been stated to third parties were "foreseeable" and thus the defendant could be liable for them. (McKinney, at p. 797.) The court created an exception from the rule of Shoemaker v. Friedberg (1947) 80 Cal.App.2d 911 183 P.2d 318 that a person defamed who voluntarily discloses cannot recover, finding it appropriate to have an exception where the party defamed would have a "strong compulsion" to disclose. (McKinney, at p. 796.)