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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
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
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.