COUNT ONE (Libel) 100. Plaintiffs reincorporate by reference all of the allegations of this Complaint as if the same were fully rewritten herein. 01837109-2/ 12000.00-0027 21
101. From on or about November 9, 2016 to present, Defendants have carried out a campaign to defame Plaintiffs. Defendants have carried out their malicious campaign to permanently harm and damage the Plaintiffs through publishing false statements of fact online, LiliOU^il CXx*CXil SxXXX^ txXC xl^Ct vVilICii COixtcXXXXS i3.1s£ StSiCITlCniS Ox* xuCl iixrQ tl^ii SCItdiii^ CITl^ils which contain false statements of fact, through making verbal false statements of fact, and by other means of publication. 102. From on or about November 9, 2016 to present, Defendants published on the flyer, emails, and other means of publication, false statements of fact regarding Plaintiffs, which include, but are not limited to, affirmative statements that Plaintiffs are racists, that Gibson's Bakery is a "racist establishment with a long account of racial profiling and discrimination," and that Plaintiffs commit hate crimes against minorities. 103. Oberlin College published defamatory statements against Plaintiffs through its agents, which include, but are not necessarily limited to: Krislov, Raimondo, and other professors and staff members. Such agents were acting within the course and scope of their employment with Oberlin College at all relevant times, and the agents' acts were calculated to facilitate or promote the business, interests, and agenda of Oberlin College. Oberlin College encouraged the defamatory conduct and approved and ratified the conduct of its agents, and adopted those false statements as its own statements. These false statements were part of and
fueled Oberlin College's campaign against Plaintiffs. 104. Said written statements concerning the Plaintiffs are false and defamatory, they import a charge of an indictable offense involving moral turpitude or infamous punishment, they injure the Plaintiffs' trade, business, or occupation, and they subject Plaintiffs to public hatred, ridicule, or contempt. 01837109-2/ 12000.00-0027 22
105. Said written statements concerning the Plaintiffs attack their competence and ability to manage a local business in the city of Oberlin. 106. Said written statements were published with malice and were intended to injure Plaintiffs' business reputation and their personal standing within the community or at a minimum, Defendants were negligent when they made the disparaging statements. 107. Defendants' statements constitute libel per se and therefore, Ohio law presumes that Plaintiffs have suffered damages. Furthermore, as a direct and proximate result of Defendants' defamatory statements, Plaintiffs have suffered actual and special damages, including, without limitation, loss of business earnings, injury to their personal and business reputations, and mental anguish and humiliation.
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- Fall '16
- Dr. Olouch
- Leap year starting on Friday, Oberlin College