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TO: RANDY HORTON, DEFENDANT HEREIN:
YOU ARE HEREBY SUMMONED and required to Answer the Complaint in this action,
a copy of which is herewith served upon you, and to serve a copy of your Answer upon the
subscriber at his office, MOSS, KUHN & FLEMING, P.A., Post Office Drawer 507/1501 North
Street, Beaufort, South Carolina 29901-0507, within thirty (30) days from the date of service
hereof; exclusive of the day of such service; and if you fail to answer the Complaint within
the time aforesaid, the Plaintif in this action will apply to the Court for a judgment by
default and the relief demanded in the attached Complaint.
Beaufort, South Carolina
April j , 2014
MOSS, KUHN & FLEMING, P.A.
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The Plaintiff, complaining of the Defendant, alleges:
FOR A FIRST CAUSE OF ACTION
1. That the Plaintiff is a resident of Jasper County, State of South Carolina.
2. That the Defendant is a resident of Jasper County, State of South Carolina.
3. That the Plaintiff is the Superintendent of Education for the County of Jasper,
State of South Carolina, and has been for a period of over three (3) years. She is
exceedingly proud of her accomplishments over the years, including her obtaining the
position of Superintendent of Education. She has been so certified by the State of South
Carolina.
4. That on or about June, 2011 and continuing up to the date of the filing of this
action, the Defendant slandered and libeled the Plaintiff herein by making oral and written
statements that she falsified documents, conspired to have fraudulent bids filed, and
committed many illegal acts while being the Superintendent of Education for the County
of Jasper, State of South Carolina.
5. That the Defendant has otherwise and continually accused the Plaintiff of a
crime, and has been instrumental in influencing the investigation which occurred by State
and Federal agencies of South Carolina and the United States based on false allegations
from the Defendant.
6. That the Defendant has, since June, 2011, continually made these false and
malicious statements, orally and in writing, up and until September, 2013, and continuing
to date. Thereafter, he has made such statements when he knew, or should have known,
and had previously been shown by correspondence and otherwise, that the statements he
was making were false and malicious.
7. That the Defendant and others made such slanderous and libelous remarks
continually to the newspaper and to other individuals with the intention of damaging and
destroying the Plaintif in her vocation and her reputation.
8. That the Defendant accused the Plaintiff and other individuals of conspiring
to obtain bids fraudulently and falsely by the installation of security systems in the Jasper
County Public School System. He has continued with this malicious, slanderous and
libelous attack, in spite of investigations showing his allegations to be without merit or
foundation.
9. On December 16, 2013, the Defendant told the School Board, in executive
session, "I'm going to show you in 30 days what you are made of." This comment was
referring to this ongoing investigation. The Defendant then stated, after the executive
session, from which he departed early, and in front of members of the community and the
school district, "I'm going to get rid of that bitch." This, in addition to the other statements
made by the Defendant, demonstrate substantial malice and ill will toward this Plaintiff.
10. That also by a blog posting on March 2l
5t
, 2014, The Defendant herein,
identifing himself as "a Jasper County School Board member", stated " ... how to start a
criminal investigation."
11. That the Defendant made false and material statements concerning the
Plaintiff's ability to handle her business by stating she should not be superintendent, as she
does not have a Doctor's Degree, which is not a requirement in South Carolina to be
certified as a superintendent of schools.
12. That, in fact, the Plaintiff herein does have a Doctor's Degree, has completed
all of her courses, and has graduated.
13. That the Defendant has made many false and malicious allegations against
the Plaintiff by indicating she was incompetent, dishonest, fraudulent, and accused her of
filing false documents concerning bids.
14. That the actions of the Defendant also caused other individuals to join in and
make malicious, slanderous and libelous statements about the Plaintiff herein. Those
individuals are unnamed at this time, but may be potential Defendants in this matter.
15. That as a direct and proximate result of the careless and reckless acts and
conduct of the slanderous and libelous remarks made by the Defendant, this Plaintiff has
been damaged in the following particulars, to-wit:
That the actions of the Defendant were slander per se, from which the Plaintiff
is entitled to substantial damages, both actually and punitively, concerning the damage to
her reputation and standing in the community; that she has been distressed and humiliated
as a result of the Defendant's actions and continued actions; that the Jasper County Sheriff's
Department was required on one occasion to pick up the Defendant and take him to the
local hospital as a result of the Defendant's relatives reporting him to the Sheriff's
Department; that the Defendant suffers from some medical problems that do not enable
him to logically conclude the truth of many matters with which he is confronted; that the
Plaintiff is entitled to substantial damages against the Defendant herein, both actually and
punitively, in such amounts as may be awarded by the jury.
WHEREFORE, the Plaintiff prays for judgment against the Defendant in such amounts
as may be awarded by the jury, both actual and punitive damages.
Beaufo outh Carolina
April 2014
MOSS, KUHN & FLEMING, P.A.

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