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Case 1:09-cv-06338

Document 1

Filed 10/09/2009

Page 9 of 11

25. At all relevant times, Gooch was Haro's agent, acting within the actual and

apparent scope of

his authority.

26. As a consequence, Harpo is vicariously liable for Gooch's false and defamatory

statements, which Harpo additionally ratified by its conduct including, inter alia, its failure to

reinstate Plaintiff, its failure to seasonably terminate Gooch, and its failure to adhere to the

provisions of the employee handbook concerning all of these matters.

27. As a direct and proximate consequence of

Harpo's conduct, Plaintiff

has been

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

embarrassment, humiliation, and emotional harm.

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

against Haro 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 III Interference With Gehris' Prospective Economic Advantage by Bumpus and Gooch

1 - 27. As paragraphs 1 through 27 of

Count II, Plaintiffrealleges and incorporates by

reference paragraphs 1 - 27 of Count II.

28. At all relevant times, Ms. GehrIs had a reasonable expectation of prospective

economic advantage through her employment with Harpo of which Defendants Bumpus and

Gooch were aware.

29. As described above, Bumpus and Gooch wilfully, maliciously and unjustifiably

interfered with Ms. GehrIs' prospective economic advantage.

30. As a direct and proximate consequence of

Bumpus' and Gooch's conduct, Ms.

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