IN UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MISSOURI SPRINGFIELD MISSOURI DIVISION AHMED SALAU, ) Case No. P. O. BOX 6008, ) PRINCETON, WV 24740. ) ) Plaintiff, pro se ) ) vs. ) COMPLAINT ) HANNAH BRACKETT, ) JURY TRIAL DEMANDED 725 NORTHPOINT AVE., ) LIBERTY, MO 64068 ) ) 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. All events giving rise to Plaintiff s cause of action occurred in Missouri, such that Missouri substantive law applies to Plaintiff s claims. 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 Brackett s tortious conduct, and Brackett 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, Hannah Brackett is a natural person and is a resident of Liberty, Missouri.
STATEMENT OF FACTS 3. On or about Friday, September 7 th 2012, Plaintiff exchanged numerous text messages with Defendant. 4. In one of the text messages, Plaintiff and Defendant agree to meet on Saturday, September 8 th 2012 in the afternoon to attend the football game. 5. On Saturday, September 8 th 2012, at/or about 3pm, Plaintiff text messages Defendant that she has arrived on campus and she is ready to be picked up. 6. At/or about 3:15pm, Defendant arrives at Plaintiff s dormitory in company of five of his friends and meet with Plaintiff and two of her friends as they head towards one of Defendant s friend s tailgate. 7. On the way to the Defendant s friend s tailgate, one of the group members Defendant s friend Abby Corkins (hereinafter Abby) recognizes a friend from her University Rowing Team at a different tailgate and we all went with her. 8. The group never made it to Plaintiff s friend s tailgate. 9. While at Abby s friend s tailgate, some members of the group left early for the football game while other members stayed and had alcoholic beverages.
10. At/or about a half hour from our arrival at Abby s friend s tailgate, everyone at the house headed towards the stadium to join the festivities. 11. The members of our group decided to go to Lot X to check out the view and join the rest of the tailgaters at the top level. 12. Some members of the group did not have tickets so at/or about an hour after our arrival at Lot X, the group dispersed with Plaintiff, Abby, and Defendant going to the football game together. The time was about 5:30pm. 13. The group stayed at the football game until the game was decided at/or about 9pm. 14. The group subsequently headed towards the residence halls where Abby headed back to her room. 15. Defendant and Plaintiff proceeded to head downtown to get some food and for some dancing. 16. While downtown, Defendant and Plaintiff go to The Blue Fuque Bar (hereinafter called the bar). 17. Defendant and Plaintiff showed their identification cards to get into the bar. 18. Defendant and Plaintiff ordered drinks and listened to a live band play. 19. At/or about 10pm, Defendant grew bored of the band since they were a crappy band so Defendant and Plaintiff both played several games of Ping-Pong before leaving the bar.
20. Defendant and Plaintiff left the bar and proceeded to the speaker s circle on campus to complete one of the University rituals. 21. Defendant and Plaintiff finished the ritual, shared a few kisses and headed away from the speaker s circle. 22. On the way back to the Defendant s dormitory, Defendant and Plaintiff talked about a previous conversation they had about Chinese tradition, history and Government. During this conversation, Plaintiff s collection of Chinese books and artifacts came up and an excited Defendant requested to check them out. 23. When Defendant and Plaintiff arrived at Plaintiff s office, Defendant checked out the Chinese lore for a few minutes before requesting that the Plaintiff change the music because she did not like the country music that was playing. Plaintiff then subsequently changed the music to The Beatles. 24. Defendant and Plaintiff began to dance to The Beatles and subsequently kissed and had consensual intercourse. 25. After intercourse, they departed Defendant s office as Plaintiff proceeded to walk Defendant back to Defendant s dormitory. Upon arrival at Defendant s dormitory, Defendant invites Plaintiff in and swipes him in the building. Defendant requested to take the stairs up to her room in order to avoid detection by her Residence Assistant.
26. This revelation troubled Plaintiff so he questions Defendant as to why she was trying to avoid her Residence Assistant to which she responds that her Residence Assistant is always nosy and she wanted to avoid coming in contact with her. 27. Upon arrival at Defendant s room, Plaintiff s roommate Rachel Ouellette (hereinafter called Rachel) is laying on the bed asleep. Defendant and Plaintiff subsequently kiss and have intercourse as they fell asleep in Defendant s bed. 28. On Sunday, September 9 th 2012, at/or about 9am, Defendant and Plaintiff wake up, get dressed, and head downtown for breakfast at Ernie s café. 29. During breakfast, Defendant and Plaintiff had general conversations about politics, and the large number of patrons present for breakfast with their server Brooke. During breakfast, Defendant bragged about owning and using a fake identification card which she showed Plaintiff. 30. Plaintiff noticed a friend of his Peter Conn (hereinafter called Peter) come in to meet his parents as they took the seat next to Plaintiff and Defendant s. 31. After finishing breakfast, Plaintiff paid for both meals and acknowledged Peter and his parents as he and Defendant left Ernie s café.
32. While Defendant and Plaintiff were walking back, Defendant asked Plaintiff if he was clean to which Plaintiff responded in the affirmative even adding that he was a regular blood and plasma donor for the Red Cross. 33. When Defendant and Plaintiff arrived at Defendant s dormitory they bade each other goodbye. 34. At/or about 5pm on Sunday, September 9 th, 2012, Plaintiff was conducting research at his office in the Chemistry Building when the University Police Department came to inquire about an incident that occurred in an office in the Chemistry Building. 35. Plaintiff co-operated with the University Police Department and went down to the Police Station to talk about it. 36. Plaintiff was interrogated for a few hours and was escorted back to his Office for a search of his Office. 37. Plaintiff complied with the search and detectives confiscated Plaintiff s computer, phones, memory card, among other items for analysis. 38. On/or about Tuesday, September 11 th, 2012, Defendant applies for an Order of Protection against Plaintiff in which she falsely, states as fact that the Plaintiff stalked her, got her drunk, and raped her. 39. On/or about Tuesday, September 25 th, 2012, Plaintiff received information from the University Office of Student Conduct that they had received a report stating as facts that Plaintiff, continued to
give alcohol to a person in a drunken state, provided alcohol to a minor, got her into the bar, had nonconsensual sexual behavior with a person all attributed to Defendant. 40. On/or about Wednesday, September 19 th, 2012, Plaintiff s Advisor in the Women and Gender Studies Department learns about the incidents. 41. On/or about Friday, September 28 th, 2012, Plaintiff s Advisor in the Chemistry Department and Principal Investigator on his research projects Dr. Rainer Glaser (hereinafter called Chemistry Advisor) learns about the incidents. 42. On/or about 5:10pm on September 26 th, 2012, Plaintiff attends a previously scheduled Stronger against relationship and sexual violence (STARS) event called What is a Clothesline Project? 43. On/or about September 26 th, 2012, Plaintiff finds out that Defendant has continued to state as facts her distorted, false, and diabolical version of the events to the public knowledge of everyone at the STARS Program and at the Relationship and Sexual Violence Prevention (RSVP) thereby sharing this information with third parties.
44. On/or about Wednesday, October 3 rd, 2012, Plaintiff received information from the University Office of Student Conduct summarily expelling him and permanently separating him from the University. 45. On/or about Thursday, October 4 th, 2012, at about 5pm Plaintiff was working at the Rollins Dining Hall when Defendant showed up at his work station and called him a rapist loud enough for third parties to hear. 46. Plaintiff subsequently alerted a co-worker to witness the incident that followed. 47. Defendant got on the phone to call the University Police Department to try to get Plaintiff arrested for violating an Order of Protection. 48. During the ensuing incidents, Plaintiff alerts his supervisor Jeffrey J. Lee (hereinafter called supervisor) to these incidents. 49. At/or about 5:30pm, the Defendant continues to state as fact that the Plaintiff raped her. These utterances were loud enough for Plaintiff s friends to hear her and loud enough for Defendant s co-workers to hear her. 50. Plaintiff s supervisor advises him that Plaintiff would no longer work at Rollins Dining Hall and that we would try to find you another location. 51. On/or about 9:53am, Friday, October 5 th, 2012, Plaintiff is notified by his Supervisor that,...this morning we received word from our administration that we have to terminate you
52. On/or around, Friday, October 5 th, 2012, Plaintiff noticed that his access to the Chemistry Building had been restricted and that his key card could not access it. 53. On/or about 2:30pm on Wednesday, October 10 th, 2012, Plaintiff is approached by Detective Kingsbury after Plaintiff s Women and Gender Studies meeting with Plaintiff s Women and Gender Studies Advisor. 54. On/or about 2:30pm on Wednesday, November 28 th, 2012, Defendant continued to repeat her false and disproved defamatory statements at Room 232, Memorial Union North at the University of Missouri. 55. Plaintiff is informed by Detective Kingsbury that he is barred from the Hudson/Rollins/Gillette Residence Halls and Dining Hall for a period of One Year. Plaintiff is further informed that he has been expelled. 56. Several members of STOP TRAFFIC and Women and Gender Studies students have heard Defendant s Statements. 57. Several members of Plaintiff s church The Baptist Student Union have heard Defendant s Statements. 58. Several co-workers and supervisors have heard Defendant s Statements. 59. Plaintiff s Advisors have heard Defendant s Statements. 60. Members of PSI CHI have heard Defendant s Statements. 61. Members of Green Dot have heard Defendant s Statements.
62. Members of On the Rock have heard Defendant s Statements. 63. Plaintiff never stalked or attempted to stalk Defendant at any time. 64. Plaintiff never provided alcohol to minor. 65. Plaintiff never provided alcohol to Defendant in a drunken state. 66. Plaintiff never got her into the bar with regards to Defendant. 67. Plaintiff never engaged in nonconsensual sexual behavior with Defendant. 68. Plaintiff never raped Defendant. CLAIMS FOR RELIEF FIRST CLAIM FOR RELIEF (Slander Per Se Injury to Professional Reputation) 68. Plaintiff repeats and re-alleges the allegations set forth in paragraphs 1 to 67 as if fully set forth at length herein. 69. Defendant s Statements and publications described herein (hereinafter called Statements) concerned Plaintiff and were false. 70. Defendant s Statements were widely published and not privileged in any manner. 71. Defendant s Statements were made with reckless disregard of their truth or falsity and/or with malice.
72. Defendant s Statements were slanderous per se because they injure Plaintiff s professional reputation. 73. Defendant falsely and as a matter of fact charged the Plaintiff with stalking her asserting as fact, no prior interaction with him, he stalked me that night, contrary to and inconsistent with time stamped photographs that show otherwise and her subsequent actions. 74. 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. 75. Defendant falsely and as a matter of fact charged the Plaintiff with getting her drunk and raping her asserting as fact that, he kept refilling my drinks at the bar and raped me while me judgment was impaired, contrary to and inconsistent with the statements of the bar manager and her subsequent actions. 76. 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) 77. Plaintiff repeats and re-alleges the allegations set forth in paragraphs 1 to 76 as if fully set forth at length herein. 78. Defendant s Statements concerned Plaintiff and was false as a matter of fact. 79. Defendant s Statements were widely published and not privileged in any manner. 80. Defendant s Statements were made with reckless disregard of their truth or falsity and/or with malice.
81. Defendant s Statements were slanderous per se because they injure Plaintiff s personal reputation. 82. Defendant falsely and as a matter of fact charged the Plaintiff with stalking her asserting as fact, no prior interaction with him, he stalked me that night, contrary to and inconsistent with time stamped photographs that show otherwise and her subsequent actions. 83. 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. 84. Defendant falsely and as a matter of fact charged the Plaintiff with getting her drunk and raping her asserting as fact that, he kept refilling my drinks at the bar and raped me while me judgment was impaired, contrary to and inconsistent with the statements of the bar manager and her subsequent actions. 85. 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) 86. Plaintiff repeats and re-alleges the allegations set forth in paragraphs 1 to 85 as if fully set forth at length herein.
87. Defendant s statements concerned Plaintiff and were false. 88. Defendant s statements were widely published and not privileged in any manner. 89. Defendant s statements were made with reckless disregard of their truth or falsity with malice. 90. Defendant s statements were slanderous per se because they allege Plaintiff was engaged in criminal conduct. 91. 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. 92. Defendant falsely and as a matter of fact charged the Plaintiff with stalking her asserting as fact, no prior interaction with him, he stalked me that night, contrary to and inconsistent with time stamped photographs that show otherwise and her subsequent actions. 93. 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. 94. Defendant falsely and as a matter of fact charged the Plaintiff with getting her drunk and raping her asserting as fact that, he kept refilling my drinks at the bar and raped me while me judgment was
impaired, contrary to and inconsistent with the statements of the bar manager and her subsequent actions. 95. 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) 96. Plaintiff repeats and re-alleges the allegations set forth in paragraphs 1 to 95 as if fully set forth at length herein. 97. Defendant s Statements concerned Plaintiff and indicates the existence of other facts which are defamatory. 98. Defendant s Statements were widely published and not privileged in any manner. 99. Defendant s Statements were made with reckless disregard of their truth or falsity and/or with malice. 100. Defendant has no reasonable grounds for believing the truth of her Statements. 101. Defendant falsely and as a matter of fact charged the Plaintiff with stalking her asserting as fact, no prior interaction with him, he stalked me that night, contrary to and inconsistent with time stamped photographs that show otherwise and her subsequent actions. 102. 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.
103. Defendant falsely and as a matter of fact charged the Plaintiff with getting her drunk and raping her asserting as fact that, he kept refilling my drinks at the bar and raped me while me judgment was impaired, contrary to and inconsistent with the statements of the bar manager and her subsequent actions. 104. 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) 105. Plaintiff repeats and re-alleges the allegations set forth in paragraphs 1 to 104 as if fully set forth at length herein. 106. Defendant s Statements concerned Plaintiff and was false. 107. Defendant s Statements were widely published and not privileged in any manner. 108. Defendant s Statements were made with reckless disregard of their truth or falsity and/or with malice. 109. Defendant falsely and as a matter of fact charged the Plaintiff with stalking her asserting as fact, no prior interaction with him, he stalked me that night, contrary to and inconsistent with time stamped photographs that show otherwise and her subsequent actions. 110. 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. 111. Defendant falsely and as a matter of fact charged the Plaintiff with getting her drunk and raping her asserting as fact that, he kept
refilling my drinks at the bar and raped me while my judgment was impaired contrary to and inconsistent with the statements of the bar manager and the Defendant s subsequent actions. 112. 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) 113. Plaintiff repeats and re-alleges the allegations set forth in paragraphs 1 to 112 as if fully set forth at length herein. 114. Defendant s Statements concerned Plaintiff and was false. 115. Defendant s Statements were widely published and not privileged in any manner. 116. Defendant s Statements were made with reckless disregard of their truth or falsity and/or with malice. 117. Defendant s Statements were libelous per se because they injure Plaintiff s professional reputation. 118. Defendant falsely and as a matter of fact charged the Plaintiff with stalking her asserting as fact, no prior interaction with him, he stalked me that night, contrary to and inconsistent with time stamped photographs that show otherwise and her subsequent actions. 119. 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. 120. Defendant falsely and as a matter of fact charged the Plaintiff with getting her drunk and raping her asserting as fact that, he kept refilling my drinks at the bar and raped me while me judgment was impaired, contrary to and
inconsistent with the statements of the bar manager and her subsequent actions. 121. 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)
122. Plaintiff repeats and re-alleges the allegations set forth in paragraphs 1 to 121 as if fully set forth at length herein. 123. Defendant s Statements concerned Plaintiff and was false as a matter of fact. 124. Defendant s Statements were widely published and not privileged in any manner. 125. Defendant s Statements were made with reckless disregard of their truth or falsity and/or with malice. 126. Defendant s Statements were libelous per se because they injure Plaintiff s personal reputation. 127. Defendant falsely and as a matter of fact charged the Plaintiff with stalking her asserting as fact, no prior interaction with him, he stalked me that night, contrary to and inconsistent with time stamped photographs that show otherwise and her subsequent actions. 128. 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. 129. Defendant falsely and as a matter of fact charged the Plaintiff with getting her drunk and raping her asserting as fact that, he kept refilling
my drinks at the bar and raped me while me judgment was impaired, contrary to and inconsistent with the statements of the bar manager and her subsequent actions. 130. 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) 131. Plaintiff repeats and re-alleges the allegations set forth in paragraphs 1 to 130 as if fully set forth at length herein. 132. Defendant s statements concerned Plaintiff and were false. 133. Defendant s statements were widely published and not privileged in any manner. 134. Defendant s statements were made with reckless disregard of their truth or falsity with malice. 135. Defendant s statements were libelous per se because they allege Plaintiff was engaged in criminal conduct. 136. 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. 137. Defendant falsely and as a matter of fact charged the Plaintiff with stalking her asserting as fact, no prior interaction with him, he stalked me that night, contrary to and inconsistent with time stamped photographs that show otherwise and her subsequent actions. 138. 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.
139. Defendant falsely and as a matter of fact charged the Plaintiff with getting her drunk and raping her asserting as fact that, he kept refilling my drinks at the bar and raped me while me judgment was impaired, contrary to and inconsistent with the statements of the bar manager and her subsequent actions. 140. 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) 141. Plaintiff repeats and re-alleges the allegations set forth in paragraphs 1 to 140 as if fully set forth at length herein. 142. Defendant s Statements concerned Plaintiff and indicates the existence of other facts which are defamatory. 143. Defendant s Statements were widely published and not privileged in any manner. 144. Defendant s Statements were made with reckless disregard of their truth or falsity and/or with malice. 145. Defendant has no reasonable grounds for believing the truth of her Statements. 146. Defendant falsely and as a matter of fact charged the Plaintiff with stalking her asserting as fact, no prior interaction with him, he stalked me that night, contrary to and inconsistent with time stamped photographs that show otherwise and her subsequent actions. 147. 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.
148. Defendant falsely and as a matter of fact charged the Plaintiff with getting her drunk and raping her asserting as fact that, he kept refilling my drinks at the bar and raped me while me judgment was impaired, contrary to and inconsistent with the statements of the bar manager and her subsequent actions. 149. 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) 150. Plaintiff repeats and re-alleges the allegations set forth in paragraphs 1 to 149 as if fully set forth at length herein. 151. Defendant s Statements concerned Plaintiff and was false. 152. Defendant s Statements were widely published and not privileged in any manner. 153. Defendant s Statements were made with reckless disregard of their truth or falsity and/or with malice. 154. Defendant falsely and as a matter of fact charged the Plaintiff with stalking her asserting as fact, no prior interaction with him, he stalked me that night, contrary to and inconsistent with time stamped photographs that show otherwise and her subsequent actions. 155. 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. 156. Defendant falsely and as a matter of fact charged the Plaintiff with getting her drunk and raping her asserting as fact that, he kept refilling my drinks at the bar and raped me while me judgment was
impaired, contrary to and inconsistent with the statements of the bar manager and her subsequent actions. 157. 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) 158. Plaintiff repeats and re-alleges the allegations set forth in paragraphs 1 to 157 as if fully set forth at length herein. 159. Defendant s Statements and conduct were extreme and outrageous. So outrageous as to shock any marginally literate person s sensibilities. 160. Defendant s Statements and conduct have caused Plaintiff to suffer severe emotional stress. 161. Defendant falsely and as a matter of fact charged the Plaintiff with stalking her asserting as fact, no prior interaction with him, he stalked me that night, contrary to and inconsistent with time stamped photographs that show otherwise and her subsequent actions. 162. 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. 163. Defendant falsely and as a matter of fact charged the Plaintiff with getting her drunk and raping her asserting as fact that, he kept refilling my drinks at the bar and raped me while me judgment was
impaired, contrary to and inconsistent with the statements of the bar manager and her subsequent actions. 164. 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 24 th, 2014.