You two are talking past each other on two different points. Budwad is noting that PA law requires a notice of intent to sue prior to filing a tort claim against a local government agency. You are addressing which torts PA law states may be the basis of a claim against a local government. While defamation is a tort, it is not included within the list of the torts that PA allows as a basis for a tort claim against a government agency. That's not unusual; the federal government excludes defamation claims from the Federal Tort Claims Act which specifies which torts the federal government may be sued for. So as I see it, you are both correct, just addressing different issues.