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