IN UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA PHOENIX ARIZONA DIVISION AHMED SALAU, ) Case No. P. O. BOX 6008, ) PRINCETON, WV 24740. ) Plaintiff, pro se ) vs. ) COMPLAINT CONSTANCE AGREGAARD, ) JURY TRIAL DEMANDED C/O MG Robert Ashley, Jr., 448 Christy Avenue, Building 22408, Fort Huachuca, AZ 85613 Defendant. ) ) ) ) ) ) ) COMPLAINT Plaintiff Ahmed Salau, pro se, for his complaint alleges as follows:
NATURE OF THE CAUSE This is an action for defamation, intentional infliction of emotional distress arising out of defamatory Statements made by the Defendant about Defendant s dealings with Plaintiff. As detailed herein, Plaintiff is entitled to actual damages, compensatory and punitive damages, damages for pain and suffering as a result of Defendant s actions, exemplary damages, special damages and other damages. Substantial parts of the events alleged herein took place in Arizona. The most recent and substantial events took place in Arizona and as such Arizona law applies herein. Plaintiff requests a jury decide these claims. JURISDICTION AND VENUE This Court has subject matter jurisdiction over this action based on diversity of citizenship pursuant to 28 U.S.C 1332(a). Venue is proper pursuant to 28 U.S.C 1391(b) because a substantial part of the events or actions giving rise to Salau s claims arose in this district. Salau has incurred harm in this district as a result of Agregaard s tortious conduct, and Agregaard expressly aimed her tortious conduct at this district.
THE PARTIES 1. Plaintiff, Ahmed Salau is a natural person and is a resident of Princeton, West Virginia. Plaintiff majored in chemistry and psychology and had a minor in women and gender studies. Plaintiff is also a professional research associate, co-author, co-investigator on a number of ongoing scientific projects that have been published in peer-reviewed journals published by reputable organizations like the American Chemical Society among others. Plaintiff also had another job as a student customer service assistant at the University of Missouri Campus Dining Services. Plaintiff was also involved and/or is a member of numerous groups on campus including but not limited to STOP TRAFFIC, BAPTIST STUDENT UNION, ON THE ROCK, AUTISM SPEAKS, PSI CHI, THE FOOD BANK, GREEN DOT, Foundation for the International Medical Relief of Children (FIMRC),among other organizations. Plaintiff is also the Founder, President and Chief Executive Officer of PARIS Angels a mentoring program for at-risk youth. 2. Defendant, Constance Agregaard is a natural person and is a resident of Sierra Vista, Arizona.
STATEMENT OF FACTS 3. On or about August 2012, Plaintiff and the Defendant started working at Integral Resources Incorporated. 4. On or about September 1 st 2012, Plaintiff and the Defendant start a consensual romantic relationship & move in together. 5. On or about September 15 th 2012, Petitioner and Defendant meet Plaintiff s family and Defendant s family. 6. On or about September 30 th 2012, Plaintiff and Defendant visit the Family Health Center together and are informed that the Defendant is pregnant. 7. On or about October 1 st 2012, the Plaintiff and the Defendant visit Plaintiff s attorney friend Olayinka Hamza for the weekend. 8. On or about October 12 th 2012, Plaintiff and the Defendant decide to break up. 9. On or about October 14 th 2012, the Defendant falsely reports to the Police Department that she had been raped by the Plaintiff. To with: Ahmed Raped me 10. On or about October 19 th 2012, the Plaintiff is arrested by the Police Department and is in jail for seven months. 11. In May 2013, the Defendant recanted her statement to the police, after being confronted with insurance receipts, phone records and time stamped photographs that disproved her rape allegation.
12. The Defendant continues to make these false and defamatory statements and remade them in June 2014 to Mr. Lowe specifically stating that, Ahmed raped me 13. Plaintiff was informed by Mr. Lowe that the Defendant made the statements. 14. The Defendant s statements have been widely distributed on the internet and in newspapers world wide. 15. The Plaintiff is forever damaged by these statements. 16. The Plaintiff has lost multiple jobs and business and educational opportunities because of the Defendant s lies. The Defendant lost the jobs he had when he was arrested and every job ever since because everyone thinks he raped the Defendant which he IN FACT did not. 17. The stigma caused by her statements has completely destroyed the Plaintiff s image and caused him intense emotional distress. 18. The Defendant ended up keeping the child and has subsequently kept the Plaintiff from having anything to do with his child. The Plaintiff believes upon true belief that the Defendant sold the child for money. 19. Several members of STOP TRAFFIC and Women and Gender Studies students have heard Defendant s Statements. 20. Several members of Plaintiff s church The Baptist Student Union have heard Defendant s Statements. 21. Several co-workers and supervisors have heard Defendant s
Statements. 22. Plaintiff s Advisors have heard Defendant s Statements. 23. Members of PSI CHI have heard Defendant s Statements. 24. Members of Green Dot have heard Defendant s Statements. 25. Members of On the Rock have heard Defendant s Statements. 26. Plaintiff never raped Defendant. CLAIMS FOR RELIEF FIRST CLAIM FOR RELIEF (Slander Per Se Injury to Professional Reputation) 27. Plaintiff repeats and re-alleges the allegations set forth in paragraphs 1 to 25 as if fully set forth at length herein. 28. Defendant s Statements and publications described herein (hereinafter called Statements) concerned Plaintiff and were false. 29. Defendant s Statements were widely published and not privileged in any manner. 30. Defendant s Statements were made with reckless disregard of their truth or falsity and/or with malice. 31. Defendant s Statements were slanderous per se because they injure Plaintiff s professional reputation.
32. Defendant falsely and as a matter of fact charged the Plaintiff with raping her asserting as fact, no prior interaction with him, he raped me that night, contrary to and inconsistent with time stamped photographs that show otherwise and her subsequent actions. 33. Defendant falsely and as a matter of fact charged the Plaintiff with raping her asserting as fact, he raped me that night, contrary to and inconsistent with the events that followed and time stamped photographs. 34. Defendant s statements forever falsely taint and permanently damage Plaintiff in the eyes of The University of Missouri at large, The Chemistry Department of the University of Missouri, The Psychology Department of the University of Missouri, the Women and Gender Studies Department at the University of Missouri, STOP TRAFFIC, The Baptist Student Union, On the Rock Church, PSI CHI, and Green Dot. In addition individuals will be less likely to associate with Plaintiff as a result of his tainted reputation. In addition individuals will be less likely to associate with Plaintiff as a result of his tainted reputation. WHEREFORE, Plaintiff prays this honorable Court to enter a judgment against Defendant awarding compensatory damages in the amount of $1,100,000.00 plus punitive damages in an amount that will fairly and
reasonably punish Defendant for their conduct, and further ordering Defendant to pay consequential and incidental damages, pre-judgment and post-judgment interest costs of suit and attorney s fees, and further equitable relief as this honorable Court deems just. SECOND CLAIM FOR RELIEF (Slander Per Se Injury to Personal Reputation) 35. Plaintiff repeats and re-alleges the allegations set forth in paragraphs 1 to 33 as if fully set forth at length herein. 36. Defendant s Statements concerned Plaintiff and was false as a matter of fact. 37. Defendant s Statements were widely published and not privileged in any manner. 38. Defendant s Statements were made with reckless disregard of their truth or falsity and/or with malice. 39. Defendant s Statements were slanderous per se because they injure Plaintiff s personal reputation. 40. Defendant falsely and as a matter of fact charged the Plaintiff with raping her asserting as fact, no prior interaction with him, he raped me that night, contrary to and inconsistent with time stamped photographs that show otherwise and her subsequent actions.
41. Defendant false and as a matter of fact charged the Plaintiff with raping her asserting as fact, he raped me that night, contrary to and inconsistent with the events that followed and time stamped photographs. 42. Defendant falsely and as a matter of fact charged the Plaintiff with raping her asserting as fact that, he raped me, contrary to and inconsistent with the statements of the bar manager and her subsequent actions. 43. Defendant s statements forever falsely taint and permanently damage Plaintiff in the eyes of The University of Missouri, The Chemistry Department of the University of Missouri, The Psychology Department of the University of Missouri, The Women and Gender Studies Department at the University of Missouri, STOP TRAFFIC, The Baptist Student Union, On the Rock Church, PSI CHI, and Green Dot. In addition individuals will be less likely to associate with Plaintiff as a result of his tainted reputation. The Defendant had dedicated significant time and effort into to the City and community of Columbia. Defendant s statements permanently damage Plaintiff s reputation in Missouri and all over the world. Plaintiff will soon have to leave the world of academia and will likely face difficulties in obtaining employment at another university as a result of Defendant s false and defamatory statements.
WHEREFORE, Plaintiff prays this honorable Court to enter a judgment against Defendant awarding compensatory damages in the amount of $1,100,000.00 plus punitive damages in an amount that will fairly and reasonably punish Defendant for their conduct, and further ordering Defendant to pay consequential and incidental damages, pre-judgment and post-judgment interest costs of suit and attorney s fees, and further equitable relief as this honorable Court deems just. THIRD CLAIM FOR RELIEF (Slander Per Se Accusations of Criminal Conduct) 44. Plaintiff repeats and re-alleges the allegations set forth in paragraphs 1 to 44 as if fully set forth at length herein. 45. Defendant s statements concerned Plaintiff and were false. 46. Defendant s statements were widely published and not privileged in any manner. 47. Defendant s statements were made with reckless disregard of their truth or falsity with malice. 48. Defendant s statements were slanderous per se because they allege Plaintiff was engaged in criminal conduct.
49. Defendant s statements accused Plaintiff of engaging in a pattern of behavior that is criminal and punishable with up to 30 years of incarceration at the Missouri Department of Corrections. 50. Defendant falsely and as a matter of fact charged the Plaintiff with raping her asserting as fact, no prior interaction with him, he raped me that night, contrary to and inconsistent with time stamped photographs that show otherwise and her subsequent actions. 51. Defendant false and as a matter of fact charged the Plaintiff with raping her asserting as fact, he raped me that night, contrary to and inconsistent with the events that followed and time stamped photographs. 52. Defendant falsely and as a matter of fact charged the Plaintiff with raping her asserting as fact that, he raped me, contrary to and inconsistent with the statements of our roommates and coworkers. 53. Defendant s statements forever falsely taint and permanently damage Plaintiff in the eyes of The University of Missouri at large, The Chemistry Department of the University of Missouri, The Psychology Department of the University of Missouri, the Women and Gender Studies Department at the University of Missouri, STOP TRAFFIC, The Baptist Student Union, On the Rock Church, PSI CHI, and Green Dot. In addition individuals will be less likely to associate with Plaintiff as a
result of his tainted reputation. In addition individuals will be less likely to associate with Plaintiff as a result of his tainted reputation. WHEREFORE, Plaintiff prays this honorable Court to enter a judgment against Defendant awarding compensatory damages in the amount of $1,100,000.00 plus punitive damages in an amount that will fairly and reasonably punish Defendant for their conduct, and further ordering Defendant to pay consequential and incidental damages, pre-judgment and post-judgment interest costs of suit and attorney s fees, and further equitable relief as this honorable Court deems just. FOURTH CLAIM FOR RELIEF (Slander By Implication) 54. Plaintiff repeats and re-alleges the allegations set forth in paragraphs 1 to 54 as if fully set forth at length herein. 55. Defendant s Statements concerned Plaintiff and indicates the existence of other facts which are defamatory. 56. Defendant s Statements were widely published and not privileged in any manner. 57. Defendant s Statements were made with reckless disregard of their truth or falsity and/or with malice.
58. Defendant has no reasonable grounds for believing the truth of her Statements. 59. Defendant falsely and as a matter of fact charged the Plaintiff with stalking her asserting as fact, no prior interaction with him, he raped me that night, contrary to and inconsistent with time stamped photographs that show otherwise and her subsequent actions. 60. Defendant false and as a matter of fact charged the Plaintiff with raping her asserting as fact, he raped me that night, contrary to and inconsistent with the events that followed and time stamped photographs. 61. Defendant falsely and as a matter of fact charged the Plaintiff with raping her asserting as fact that, he raped me, contrary to and inconsistent with the statements of our roommates and co-workers. 62. Defendant s statements forever falsely taint and permanently damage Plaintiff in the eyes of The University of Missouri at large, The Chemistry Department of the University of Missouri, The Psychology Department of the University of Missouri, the Women and Gender Studies Department at the University of Missouri, STOP TRAFFIC, The Baptist Student Union, On the Rock Church, PSI CHI, and Green Dot. In addition individuals will be less likely to associate with Plaintiff as a result of his tainted reputation. In addition individuals will be less likely to associate with Plaintiff as a result of his tainted reputation.
WHEREFORE, Plaintiff prays this honorable Court to enter a judgment against Defendant awarding compensatory damages in the amount of $1,100,000.00 plus punitive damages in an amount that will fairly and reasonably punish Defendant for their conduct, and further ordering Defendant to pay consequential and incidental damages, pre-judgment and post-judgment interest costs of suit and attorney s fees, and further equitable relief as this honorable Court deems just. FIFTH CLAIM FOR RELIEF (Slander Reckless Disregard/Malice) 63. Plaintiff repeats and re-alleges the allegations set forth in paragraphs 1 to 61 as if fully set forth at length herein. 64. Defendant s Statements concerned Plaintiff and was false. 65. Defendant s Statements were widely published and not privileged in any manner. 66. Defendant s Statements were made with reckless disregard of their truth or falsity and/or with malice. 67. Defendant falsely and as a matter of fact charged the Plaintiff with raping her asserting as fact, no prior interaction with him, he raped
me that night, contrary to and inconsistent with time stamped photographs that show otherwise and her subsequent actions. 68. Defendant falsely and as a matter of fact charged the Plaintiff with raping her asserting as fact, he raped me that night, contrary to and inconsistent with the events that followed and time stamped photographs. 69. Defendant falsely and as a matter of fact charged the Plaintiff with getting her drunk and raping her asserting as fact that, he raped me contrary to and inconsistent with the statements of the bar manager and the Defendant s subsequent actions. 70. Defendant s statements forever falsely taint and permanently damage Plaintiff in the eyes of The University of Missouri at large, The Chemistry Department of University of Missouri, The Psychology Department of University of Missouri, the Women and Gender Studies program at the University of Missouri, STOP TRAFFIC, The Baptist Student Union, On the Rock Church, PSI CHI, and Green Dot. In addition individuals will be less likely to associate with Plaintiff as a result of his tainted reputation. In addition individuals will be less likely to associate with Plaintiff as a result of his tainted reputation.
WHEREFORE, Plaintiff prays this honorable Court to enter a judgment against Defendant awarding compensatory damages in the amount of $1,100,000.00 plus punitive damages in an amount that will fairly and reasonably punish Defendant for their conduct, and further ordering Defendant to pay consequential and incidental damages, pre-judgment and post-judgment interest costs of suit and attorney s fees, and further equitable relief as this honorable Court deems just. SIXTH CLAIM FOR RELIEF (Libel Per Se Injury to Professional Reputation) 71. Plaintiff repeats and re-alleges the allegations set forth in paragraphs 1 to 69 as if fully set forth at length herein. 72. Defendant s Statements concerned Plaintiff and was false. 73. Defendant s Statements were widely published and not privileged in any manner. 74. Defendant s Statements were made with reckless disregard of their truth or falsity and/or with malice. 75. Defendant s Statements were libelous per se because they injure Plaintiff s professional reputation. 76. Defendant falsely and as a matter of fact charged the Plaintiff with raping her asserting as fact, no prior interaction with him, he raped
me that night, contrary to and inconsistent with time stamped photographs that show otherwise and her subsequent actions. 77. Defendant falsely and as a matter of fact charged the Plaintiff with raping her asserting as fact, he raped me that night, contrary to and inconsistent with the events that followed and time stamped photographs. 78. Defendant falsely and as a matter of fact charged the Plaintiff with raping her asserting as fact that, he raped me, contrary to and inconsistent with the statements of the bar manager and her subsequent actions. 79. Defendant s statements forever falsely taint and permanently damage Plaintiff in the eyes of The University of Missouri at large, The Chemistry Department of the University of Missouri, The Psychology Department of the University of Missouri, the Women and Gender Studies Department at the University of Missouri, STOP TRAFFIC, The Baptist Student Union, On the Rock Church, PSI CHI, and Green Dot. In addition individuals will be less likely to associate with Plaintiff as a result of his tainted reputation. In addition individuals will be less likely to associate with Plaintiff as a result of his tainted reputation. WHEREFORE, Plaintiff prays this honorable Court to enter a judgment against Defendant awarding compensatory damages in the amount of
$1,100,000.00 plus punitive damages in an amount that will fairly and reasonably punish Defendant for their conduct, and further ordering Defendant to pay consequential and incidental damages, pre-judgment and post-judgment interest costs of suit and attorney s fees, and further equitable relief as this honorable Court deems just. SEVENTH CLAIM FOR RELIEF (Libel Per Se Injury to Personal Reputation) 80. Plaintiff repeats and re-alleges the allegations set forth in paragraphs 1 to 78 as if fully set forth at length herein. 81. Defendant s Statements concerned Plaintiff and was false as a matter of fact. 82. Defendant s Statements were widely published and not privileged in any manner. 83. Defendant s Statements were made with reckless disregard of their truth or falsity and/or with malice. 84. Defendant s Statements were libelous per se because they injure Plaintiff s personal reputation. 85. Defendant falsely and as a matter of fact charged the Plaintiff with raping her asserting as fact, no prior interaction with him, he raped
me that night, contrary to and inconsistent with time stamped photographs that show otherwise and her subsequent actions. 86. Defendant falsely and as a matter of fact charged the Plaintiff with raping her asserting as fact, he raped me that night, contrary to and inconsistent with the events that followed and time stamped photographs. 87. Defendant falsely and as a matter of fact charged the Plaintiff with getting her drunk and raping her asserting as fact that, he raped me, contrary to and inconsistent with the statements of the bar manager and her subsequent actions. 88. Defendant s statements forever falsely taint and permanently damage Plaintiff in the eyes of The University of Missouri, The Chemistry Department of the University of Missouri, The Psychology Department of the University of Missouri, The Women and Gender Studies Department at the University of Missouri, STOP TRAFFIC, The Baptist Student Union, On the Rock Church, PSI CHI, and Green Dot. In addition individuals will be less likely to associate with Plaintiff as a result of his tainted reputation. The Defendant had dedicated significant time and effort into to the City and community of Columbia. Defendant s statements
WHEREFORE, Plaintiff prays this honorable Court to enter a judgment against Defendant awarding compensatory damages in the amount of $1,100,000.00 plus punitive damages in an amount that will fairly and reasonably punish Defendant for their conduct, and further ordering Defendant to pay consequential and incidental damages, pre-judgment and post-judgment interest costs of suit and attorney s fees, and further equitable relief as this honorable Court deems just. EIGHTH CLAIM FOR RELIEF (Libel Per Se Accusations of Criminal Conduct) 89. Plaintiff repeats and re-alleges the allegations set forth in paragraphs 1 to 87 as if fully set forth at length herein. 90. Defendant s statements concerned Plaintiff and were false. 91. Defendant s statements were widely published and not privileged in any manner. 92. Defendant s statements were made with reckless disregard of their truth or falsity with malice. 93. Defendant s statements were libelous per se because they allege Plaintiff was engaged in criminal conduct. 94. Defendant s statements accused Plaintiff of engaging in a pattern of behavior that is criminal and punishable with up to 30 years of incarceration at the Missouri Department of Corrections.
95. Defendant falsely and as a matter of fact charged the Plaintiff with raping her asserting as fact, no prior interaction with him, he raped me that night, contrary to and inconsistent with time stamped photographs that show otherwise and her subsequent actions. 96. Defendant falsely and as a matter of fact charged the Plaintiff with raping her asserting as fact, he raped me that night, contrary to and inconsistent with the events that followed and time stamped photographs. 97. Defendant falsely and as a matter of fact charged the Plaintiff with getting her drunk and raping her asserting as fact that, he raped me, contrary to and inconsistent with the statements of the bar manager and her subsequent actions. 98. Defendant s statements forever falsely taint and permanently damage Plaintiff in the eyes of The University of Missouri at large, The Chemistry Department of the University of Missouri, The Psychology Department of the University of Missouri, the Women and Gender Studies Department at the University of Missouri, STOP TRAFFIC, The Baptist Student Union, On the Rock Church, PSI CHI, and Green Dot. In addition individuals will be less likely to associate with Plaintiff as a result of his tainted reputation. In addition individuals will be less likely to associate with Plaintiff as a result of his tainted reputation.
WHEREFORE, Plaintiff prays this honorable Court to enter a judgment against Defendant awarding compensatory damages in the amount of $1,100,000.00 plus punitive damages in an amount that will fairly and reasonably punish Defendant for their conduct, pre-judgment and postjudgment interest and further ordering Defendant to pay consequential and incidental damages, costs of suit and attorney s fees, and further equitable relief as this honorable Court deems just. NINTH CLAIM FOR RELIEF (Libel By Implication) 99. Plaintiff repeats and re-alleges the allegations set forth in paragraphs 1 to 98 as if fully set forth at length herein. 100. Defendant s Statements concerned Plaintiff and indicates the existence of other facts which are defamatory. 101. Defendant s Statements were widely published and not privileged in any manner. 102. Defendant s Statements were made with reckless disregard of their truth or falsity and/or with malice. 103. Defendant has no reasonable grounds for believing the truth of her Statements. 104. Defendant falsely and as a matter of fact charged the Plaintiff with raping her asserting as fact, no prior interaction with him, he raped
me that night, contrary to and inconsistent with time stamped photographs that show otherwise and her subsequent actions. 105. Defendant falsely and as a matter of fact charged the Plaintiff with raping her asserting as fact, he raped me that night, contrary to and inconsistent with the events that followed and time stamped photographs. 106. Defendant falsely and as a matter of fact charged the Plaintiff with getting her drunk and raping her asserting as fact that, he raped me, contrary to and inconsistent with the statements of the bar manager and her subsequent actions. 107. Defendant s statements forever falsely taint and permanently damage Plaintiff in the eyes of The University of Missouri at large, The Chemistry Department of the University of Missouri, The Psychology Department of the University of Missouri, the Women and Gender Studies Department at the University of Missouri, STOP TRAFFIC, The Baptist Student Union, On the Rock Church, PSI CHI, and Green Dot. In addition individuals will be less likely to associate with Plaintiff as a result of his tainted reputation. In addition individuals will be less likely to associate with Plaintiff as a result of his tainted reputation. WHEREFORE, Plaintiff prays this honorable Court to enter a judgment against Defendant awarding compensatory damages in the amount of
$1,100,000.00 plus punitive damages in an amount that will fairly and reasonably punish Defendant for their conduct, pre-judgment and postjudgment interest and further ordering Defendant to pay consequential and incidental damages, costs of suit and attorney s fees, and further equitable relief as this honorable Court deems just. TENTH CLAIM FOR RELIEF (Libel Reckless Disregard/Malice) 108. Plaintiff repeats and re-alleges the allegations set forth in paragraphs 1 to 106 as if fully set forth at length herein. 109. Defendant s Statements concerned Plaintiff and was false. 110. Defendant s Statements were widely published and not privileged in any manner. 111. Defendant s Statements were made with reckless disregard of their truth or falsity and/or with malice. 112. Defendant falsely and as a matter of fact charged the Plaintiff with raping her asserting as fact, no prior interaction with him, he raped me that night, contrary to and inconsistent with time stamped photographs that show otherwise and her subsequent actions. 113. Defendant false and as a matter of fact charged the Plaintiff with raping her asserting as fact, he raped me that night, contrary to
and inconsistent with the events that followed and time stamped photographs. 114. Defendant falsely and as a matter of fact charged the Plaintiff with raping her asserting as fact that, he raped me, contrary to and inconsistent with the statements of the bar manager and her subsequent actions. 115. Defendant s statements forever falsely taint and permanently damage Plaintiff in the eyes of The University of Missouri at large, The Chemistry Department of the University of Missouri, The Psychology Department of the University of Missouri, the Women and Gender Studies Department at the University of Missouri, STOP TRAFFIC, The Baptist Student Union, On the Rock Church, PSI CHI, and Green Dot. In addition individuals will be less likely to associate with Plaintiff as a result of his tainted reputation. In addition individuals will be less likely to associate with Plaintiff as a result of his tainted reputation. WHEREFORE, Plaintiff prays this honorable Court to enter a judgment against Defendant awarding compensatory damages in the amount of $1,100,000.00 plus punitive damages in an amount that will fairly and reasonably punish Defendant for their conduct, pre-judgment and postjudgment interest and further ordering Defendant to pay consequential
and incidental damages, costs of suit and attorney s fees, and further equitable relief as this honorable Court deems just. ELEVENTH CLAIM FOR RELIEF (Intentional Infliction of Emotional Distress) 116. Plaintiff repeats and re-alleges the allegations set forth in paragraphs 1 to 114 as if fully set forth at length herein. 117. Defendant s Statements and conduct were extreme and outrageous. So outrageous as to shock any marginally literate person s sensibilities. 118. Defendant s Statements and conduct have caused Plaintiff to suffer severe emotional stress. 119. Defendant falsely and as a matter of fact charged the Plaintiff with raping her asserting as fact, no prior interaction with him, he raped me that night, contrary to and inconsistent with time stamped photographs that show otherwise and her subsequent actions. 120. Defendant falsely and as a matter of fact charged the Plaintiff with raping her asserting as fact, he raped me that night, contrary to and inconsistent with the events that followed and time stamped photographs. 121. Defendant falsely and as a matter of fact charged the Plaintiff with raping her asserting as fact that, he raped me, contrary to and inconsistent with the statements of our roommates and our coworkers.
122. Defendant knew and intended that Plaintiff would suffer severe emotional distress as a result of her Statements and conduct. WHEREFORE, Plaintiff prays this honorable Court to enter a judgment against Defendant awarding compensatory damages in the amount of $1,100,000.00 plus punitive damages in an amount that will fairly and reasonably punish Defendant for their conduct, pre-judgment and postjudgment interest and further ordering Defendant to pay consequential and incidental damages, costs of suit and attorney s fees, special damages, exemplary damages and injunctive relief that the Defendant refrain from further defaming Salau and further equitable relief as this honorable Court deems just. Respectfully submitted, Ahmed Salau Plaintiff Pro Se P O Box 6008 Princeton, WV 24740 Phone) 5403151147 Fax) 5403016034 ahmed@ahmedsalau.com Dated : Princeton, West Virginia November 27 th, 2014.