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Case 1:09-cv-06338

Document 1

Filed 10/09/2009

Page 8 of 11

Count I Defamation of Gehris by Bumpus and Gooch

1 - 21. As paragraphs 1 through 21 of Count I, Plaintiff realleges and incorporates by

reference paragraphs 1 - 21 of the Complaint.

22. Bumpus' and Gooch's false statements about Plaintiffs conduct on June 14,2009

and the necessary implications therefrom knowingly and falsely impeached Ms. Gehrls' integrity,

virtue, human decency, and reputation and thereby were designed to lower Ms. GehrIs in the

estimation of

her employer as well as the community.

23. In addition to being defamatory per quod, Bumpus' and Gooch's statements

constituted defamation per se, because they prejudiced Plaintiff in her occupation and profession

and because they accused her of

adultery and fornication with Pansing, a maried man. Gooch's

knowingly false statements about Plaintiff were made with the direct intention to injure Plaintiff

or a reckless disregard of her rights, and they were further made the intention to benefit Gooch.

24. As a direct and proximate consequence of

Bumpus' conduct, Plaintiff

has been

injured in an amount in excess of $75,000. Additionally, Ms. GehrIs has suffered severe

embarassment, humiliation, and emotional har.

WHEREFORE, for the foregoing reasons, Plaintiff requests judgment in her favor and

against Bumpus and Gooch, jointly and severally, for actual damages in an amount in excess of

$75,000, plus costs, attorneys fees, punitive damages, and such other relief

that is just and proper.

Count II Defamation by Harpo Based Upon Respondeat Superior

1 - 24. As paragraphs 1 through 24 of Count II, Plaintiff realleges and incorporates by

reference paragraphs 1 - 24 of Count 1.

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