) ) Plaintiff, Christina Chisholm, complaining of Defendants, Tauheed Epps, and. Ro Zay Richie, alleges and says:

Transcription

1 VS. Plaintiff ) COMPLAINT CHRIST(NCHISHOLM, ) ) music artist known as 2Chainz. 7. At all times pertinent to the allegations contained herein, Epps was a rap FACTUAL ALLEGATIONS defamation of Plaintiff. 6. This is an action to recover money damages resulting from Defendant s Complaint. 5. This Court has subject matter jurisdiction over the claims in this because this is where the causes of action arose and it is where Plaintiff resides. 4. Venue of this action is proper in Mecklenburg County, North Carolina, citizen and resident of 3. Defendant Ro zay Richie a/k/a Cap-i (hereinafter, Richie ) is an adult citizen and resident of 2. Defendant Ta,uhe?d Epps a/k/a 2Chainz (hereinafter, Epps ) is an adult an adult citizen and resident of Mecklenburg County, North Carolina. 1. Plaintiff Christina Chisholm (hereinafter, Mrs. Chishoim or Plaintiff ) is PARTIES, JURISDICTION AND VENUE Ro Zay Richie, alleges and says: Plaintiff, Christina Chisholm, complaining of Defendants, Tauheed Epps, and Defendants ) RO ZAY RICHIE, a/k/a CAP 1, ) TAUHEED EPPS, a/k/a 2CHAINZ, and ) COUNTY OF MECKLENBURG SUPERIOR COURT DIVISION STATE OF NORTH CAROLINA L 1NTHE GENERAL COURT OF JUSTICE

2 backstage. 9. Ms. Chishoim was invited to the show by Richie, and was admitted 2 g. This bitch dumb as fuck. f. can tell by her lips she suck alotta dick. THOUGHT #ISTHISYOTHOT. e. SHE A STUPID HOE LOL SHE d. Real talk, why respect a women who don t respect herself... She deserved it Dumb Bitch. doesn t respect herself? desperate she is... Why should they show her respect when she c. She deserved to be treated like that. A classless hoe, showing how told she should probably step before she downed some mote. get some dick, instead she got downed for being a clown ass hoe and b. He was nicer to her than she deserved. The hoe went there trying to fuckin sympathy for this groupie hoe!?!?!?!and she was DUMBI!!! a. She was thirsty ass hell maaaaaan!?!how the hell can you have the comments are: and over a milton views on Worldstarhiphop.com and other numerous sites. Some of 15. There have been over a million comments posted by viewers on Youtube views or more have been deleted. the video the view numbers have been altered and some videos with over 8 million views on Youtube and over a million views Worldstarhiphop.com, since the release of 14. The video has been viewed on multiple websites, with over 10 million creating the hashtag #isthatyothot. 13. Epps later posted the video to his blog and other websites, including skank, whore, or promiscuous person. intended audience understood to be an acronym for That Hoe Over There. 10. White backstage Epps recorded a video of Ms. Chisholm. 11. Epps is heard referring to Ms. Chisholm as a THOT, which Epps and his 12. Hoe as used by Epps, and defined by the Urban Dictionary, means a illmore Theater in Chartotte, North Carolina. 8. On Tuesday, March 20, 2014, Ms. Chishoim attended a show at the

3 #ISTHISYOTHOT. BLAST SHES TRYING TO SUE 2 CHAINZ CHECK HER INSTAGRAM IS HER ISTAGRAM LOL EVERYONE PUT HER ON Epps actions. 25. Ms. Chisholm suffered financial loss and emotional damages as a result of employment, and mental anguish. continues to suffer damages, including embarrassment public ridicule, inability to find the rights of Ms. Chishoim s rights. As a result Ms. Chishoim has suffered and 24. Epps statements were willful, wanton, and show a reckless disregard for 23. Epps published his statement to the world. the damages to Ms. Chisholm. 22. Epps made his statements in bad faith and with reckless indifference to degrade, and humiliate Ms. Chisholm. 21. Epps made his statements willingly, with the intention to defame, Chishoim constitute slander. 20. Epps publication of false and misleading statements concerning Ms. 19. subject to harassment and verbal abuse in public. 18. As a direct result of the video being posted online, Ms. Chisholm has been males working alongside Ms, Chishoim. negative publicity for No Grease company because the majority male clientele and to come back to work. Her manager said the video posted by Epps would cause 17. On April 3, 2014, Ms. Chishoim was told by her manager at No Grease not No Grease Barbershop in Charlotte. 16. Ms. Chishoim had previously been employed as a front desk manager at k. h. AHHHHHH, jus another THOT that thought she was cute! Kill urself bitch!.

4 [Defamation perse Libel FIRST CLAIM FOR RELIEF and Slander] believed to be in excess of ooo,ooojjv without limitation metal suffering, injury to her reputation, and injury to her ability to carry out her trade, business, or profession, in an amount not yet fully determined, but statements, all of which are false, Plaintiff has suffered actual damages, including 38. As a direct and proximate cause of Defendant s per se defamatory 37. Defendants statements constitute libel per se and slander per Se. them and to deter each of them and others similarly situated from engaging in such misconduct in the future. maliciously, warranting an award of punitive damages in an amount sufficient to punish 36. Defendants published the statements willfully, wantonly and/or knowledge that they were false, or with a reckless disregard for their truth. 35. Defendants published such statements with actual malice, that is, with 34. No privilege of any type protects the statements made by Defendants. and there was no justification for Defendant s misconduct in publishing the statements. 33. The statements made by Defendant s have no reasonable basis in fact repeatedly engaging in immoral and illegal activities. 32. Defendant s statements accuse Plaintiff of having low moral character and disgrace. 31. Defendant s statements subjected Plaintiff to ridicule, contempt and known and unknown to Plaintiff statements were published, transmitted, and/or viewed by countless third parties, both concerning Plaintiff, as more specifically described above. Defendant s defamatory 30. Defendants intentionally published false oral and written statements of and paragraphs as if fully set out. 29. Plaintiff restates and realleges the allegations contained in the preceding 27.

5 as if fully set forth herein. 39. Plaintiff realleges and incorporates by reference the preceding paragraphs 5 N.C.G.S. id-i, et seq., to prevent Defendants from future bad acts, and to prevent wanton, and done with a reckless disregard for the rights of the Plaintiff. Pursuant to 49. Defendants actions described herein were malicious, intentional, willful, paragraphs as if fully set out. 48. Plaintiff restates and realleges the allegations contained in the preceding [Punitive Damages] THIRD CLAIM FOR RELIEF excess of $000,000.O business, or profession, in an amount not yet finally determined, but believed to be in mental suffering, injury to her reputation, and injury to her ability to carry out her trade, of which are false, Plaintiff has suffered actual damages, including without limitation 47. As a direct and proximate result of Defendants defamatory statements, all knowledge that they were false or with a reckless disregard of their truth. them and to deter each of them and others similarly situated from engaging in such misconduct in the future. maliciously, warranting an award of punitive damages in an amount sufficient to punish 44. No privilege of any type protects the statements made by Defendants. 45. Defendants published such statements with actual malice, that is, with there was no justification for Defendants misconduct in publishing the statements. 43. The statements made by Defendants have no reasonable basis in fact and 46. Defendants published the statements willfully, wantonly and/or one involving moral turpitude. 42. Defendants statements accuse Plaintiff of committing a heinous crime or otherwise subject Plaintiff to ridicule, contempt, or disgrace. 41. Defendants statements impeach Plaintiff in her trade or profession, and/or statements were published, transmitted, and/or viewed by countless third parties, both concerning Plaintiff, as more specifically described above. Defendants defamatory 40. Defendants intentionally published false oral and written statements of and known and unknown to Plaintiff. [Defamation Libel and Slander] SECOND CLAIM FOR RELIEF

6 paragraphs as if fully set out. 50. Plaintiff restates and realleges the allegations contained in the preceding [INTENTIONAL!RECKLESS INFLICTION OF SEVERE EMOTIONAL DISTRESS] FOURTH CLAIM FOR RELIEF 6 under the circumstances. 5. Grant Plaintiff any other remedy which this Court deems just and equitable 4. Tax the costs of this action against Defendants; and allowed by law; 3. That Plaintiff have and recover her attorneys fees to the fullest extent willful and wanton conduct, pursuant to N.C. Gen. Stat. 1 D-1, et seq immediately. 2. Grant Plaintiff punitive damages against Defendants for their malicious, and intentional infliction of emotional distress of Plaintiff immediately. amount to be proven at trial, for their assault, battery, false imprisonment, and 1. Award Plaintiff damages against Defendants, jointly and severally, in an WHEREFORE, Plaintiff prays the Court: PRAYER FOR RELIEF N.C. Gen. Stat : Unfair & Deceptive Trade Practices Fifth claim physically. infliction of severe emotional distress, Plaintiff suffered damages, emotionally and 54. As a direct and proximate result of Defendants intentional or reckless to the likelihood that it would cause, severe emotional distress to Plaintiff. 52. Defendants conduct was intended to cause, or was recklessly indifferent 53. Defendants conduct in fact caused severe emotional distress to Plaintiff. bounds usually tolerated by decent society. 51. Defendants conduct was extreme and outrageous in that it exceeded all others engaging in similar wrongful conduct, Plaintiff is entitled to recover punitive damages from Defendants.

7 F C I I