Documenti di Didattica
Documenti di Professioni
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Date: 9/24/2020 11:38 AM
Cathelene Robinson, Clerk
Plaintiff,
Civil Action No. 2020CV339285
v.
JURY TRIAL DEMANDED
MELISSA ROLFE,
and
Defendants.
Plaintiff Equity Prime Mortgage, LLC (“Plaintiff” or “EPM”), for its complaint against
Defendants Melissa Rolfe, Marjorie Taylor Greene, and Greene for Congress, Inc. (collectively
former employee, a Congressional campaign, and a candidate seeking to exploit the death of
Rayshard Brooks for their own personal gain. In the brief time that Melissa Rolfe was employed
as the HR Director at EPM, she repeatedly violated company policy and created an uncomfortable
and hostile working environment. After securing her position at EPM under false pretenses, she
fostered a hostile work environment at the company by, among other things, calling employees
“savages” and “fucking bitches,” joking about conducting rectal temperature checks in the office,
saying that an employee was a “dumb bitch” who can only attract men because she “must suck
dick really good,” and saying an employee had only gotten hired because she had “big boobs.”
Even worse, she engaged in blatantly racist conduct, telling a Black woman who dates Black men
that she needed “to get outside the box and upgrade [her] standards,” and—in response to another
employee’s joke that she liked her coffee black and strong like she liked her men—by retorting
“Black and weak. Don’t no woman want a weak man.” Not surprisingly, Rolfe lost people’s
confidence in her ability to perform her job as an HR Director and was fired.
2. Although Rolfe had been repeatedly reprimanded and was notified—the day before
her stepson shot Rayshard Brooks—that she was under investigation because of multiple
complaints against her, she joined forces with Marjorie Taylor Greene and her Congressional
campaign to launch a national media firestorm, which included televised appearances on The
Glenn Beck Program and Tucker Carlson Tonight, social media posts, and speeches, all to peddle
the false narrative that Rolfe had done nothing wrong and that EPM had fired her for fighting for
3. The smear campaign mobilized a furious social media mob and prompted death
4. EPM brings this action to vindicate its rights under civil law, to restore its
reputation, and to recover compensatory and punitive damages for the harm the Defendants have
caused.
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PARTIES
5. Plaintiff Equity Prime Mortgage, LLC is a limited liability company organized and
existing under the laws of the state of Georgia. Its principal place of business is located at
6. Defendant Melissa Rolfe is an individual and Georgia resident who was employed
at EPM in—and regularly conducts business in—Fulton County, Georgia. Rolfe conspired with
Marjorie Taylor Greene and her campaign, Greene for Congress, Inc., to publish false and
7. Defendant Marjorie Taylor Greene is a resident of Fulton County, Georgia, and she
operates Taylor Commercial, Inc. in Alpharetta, Georgia. Marjorie Taylor Greene and her
campaign, Green for Congress, Inc., conspired with Rolfe to publish false and defamatory
8. Defendant Greene for Congress, Inc. (the “Campaign”) is Marjorie Taylor Greene’s
Congressional campaign, and it can be served via its registered agent, Jason D. Boles, at 290 Jayne
Ellen Way, Alpharetta, Georgia, its principal place of business. The Campaign and Greene
conspired with Rolfe to publish false and defamatory statements concerning EPM.
9. All of the material facts underlying EPM’s claims occurred and arise from activities
10. Venue in this Court is proper pursuant to O.C.G.A. 14-2-510(b)(4) and (d).
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FACTUAL ALLEGATIONS
Eddy Perez Founded EPM in 2008 and Has Since Grown the Company
to Become One of the Leading Mortgage Lenders in the United States
11. Eddy Perez is a longtime Fulton County resident who was born and raised in
Atlanta, Georgia. He attended Georgia State University in 1999 and started working in the
13. Perez has successfully grown his business, and he continues to serve as the CEO
14. In January 2020, Melissa Rolfe submitted her resume to be EPM’s HR Director.
To secure employment at EPM, Rolfe boasted on her resume that she had a B.S. in Human
Resource Management from Columbia Southern University, a SHRM-CP certification, and more
than 15 years of dedication and significant experience managing a full spectrum of human
15. Rolfe began as EPM’s HR Director in February 2020, working in EPM’s Atlanta-
based headquarters.
16. After Rolfe was hired, certain people at EPM learned that Rolfe was working
toward a bachelor’s degree but did not actually have one yet as her resume represented.
17. Less than a month after she had been hired by EPM, on March 19, 2020, Rolfe was
reprimanded because she had made inappropriate jokes via text message about conducting rectal
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18. About a month later, on April 23, 2020, Rolfe was reprimanded again, this time for
19. Less than two months later, two employees reported Rolfe for calling employees
“fucking bitches,” saying an employee had only been hired because she had “big boobs,” and
20. So, on June 11, 2020—the day before Rolfe’s stepson shot Rayshard Brooks—
EPM CEO Eddy Perez met with Rolfe to notify her of the latest complaints against her. Upon
hearing she had been accused of making racist comments—and before Perez had brought up
Rolfe’s inappropriate remark about an employee’s “big boobs”—Rolfe became enraged, saying
that she doesn’t see color, but that some people are “idiots.” Because of how upset Rolfe had
become, Perez cut the meeting short and told her that he would follow up with her after
investigating more.
21. The next day, Friday, June 12, 2020, Rolfe’s stepson shot Rayshard Brooks in the
parking lot of an Atlanta Wendy’s, prompting Rolfe to ask to work from home the following
Monday. Although Rolfe was under investigation for serious misconduct, the company
nevertheless granted Rolfe eight weeks of paid leave in light of her family situation, while it
simultaneously continued its investigation. During the investigation, a flood of employees came
forward and reported other instances of Rolfe’s wildly unprofessional and hostile conduct,
including:
• Rolfe told an employee that another employee was a “dumb bitch” and that the only
reason a man would be interested in her was because she “must suck dick really good.”
• Rolfe told a Black woman who dates Black men that she needed “to get outside the box
and upgrade [her] standards.”
• In response to an employee saying she liked her coffee like she liked her men, Black and
strong, Rolfe responded, “Black and weak. Don’t no woman want a weak man.”
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• Rolfe remarked that an employee wore “little girl ruffle panties.”
• Rolfe shouted at and berated employees, including by using the following language:
“stupid bitches,” “dingbats,” “tell that bitch to get a fuckin’ name tag,” “this is bullshit
and stupid shit,” and “who fucked up.”
22. In addition, an EPM employee who had previously worked with Rolfe at
Rehabilitation Physicians of Georgia reported that Rolfe had been a “Medical Assistant” there—
not an “HR Director” as her resume represented. That person further reported contacting Rolfe’s
previous employers and discovering that she had falsified other information as well.
23. After learning the above, EPM terminated Rolfe the afternoon of June 18, 2020.
Notably, when Rolfe was informed that she was being terminated, she did not ask why; she knew
that she had been repeatedly reprimanded and that—before her stepson shot Brooks—the company
24. The same day she was terminated, Rolfe conspired with the Campaign and Greene
to defame EPM and peddle the falsehood that Rolfe had done nothing wrong and that she was fired
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25. On information and belief, on June 18, 2020, Rolfe, the Campaign, and Greene
jointly coordinated the planting of a false story with Tucker Carlson Tonight, authorizing,
intending, and expecting that their false claims would be broadcast to a worldwide internet
audience.
26. By planting the false story with Tucker Carlson Tonight and repeating it during
various public appearances during the summer of 2020, the Defendants and Greene swiftly
mobilized a social media mob, death threats, and a boycott against EPM, and EPM was bombarded
with furious messages from people who believed the lie. As Rolfe’s attorney David Guldenschuh
later explained on Tucker Carlson Tonight, EPM’s “website was overwhelmed, more than 10,000
hits they got that literally shut down their website, it shut down their social media posts and it was
overwhelmingly negative.”
27. Perez reported the death threats to the FBI and hired a private security firm to
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28. To set the record straight, EPM issued a statement explaining why Rolfe had been
terminated:
29. On information and belief, even though the Defendants knew—from the multiple
prior reprimands Rolfe had received and the investigation she had been placed under and from
Rolfe’s conversations with Greene and the Campaign—that EPM’s statement was true, Defendants
doubled down in speeches and by securing appearances on The Glenn Beck Program and Tucker
Carlson Tonight to repeat their lie and to falsely accuse EPM of defaming Rolfe.
30. Glenn Beck and Tucker Carlson both asked Rolfe whether she had been subject to
any complaints for her conduct during her time at EPM. Rolfe responded in the negative,
repeatedly insisting that she could not identify anything she had done that could have justified her
termination and that she was fired for fighting for her son and being his stepmom.
31. The Campaign and Greene published defamatory statements regarding Rolfe’s
termination, and Defendants continued to defame EPM from June 18, 2020, to present.
32. With the televised appearances and other statements to the media and the general
public, Defendants poured gasoline on the media firestorm they had started, causing enormous
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33. On June 30, 2020, EPM requested retraction of Rolfe’s false claims pursuant to
34. On July 21, 2020 EPM followed up and asked Rolfe for an apology and correction.
35. Rolfe rejected EPM’s requests and continues to stand by the truth of her false
accusations.
36. In August of 2020, the Defendants mailed a letter that repeated the Defendants’ lie
37. On August 6, 2020, EPM put the Campaign and Greene on formal written notice
of why Rolfe had been terminated and demanded retraction of their false claims pursuant to
O.C.C.G.A. 51-5-11.
38. After receiving EPM’s retraction request, the Campaign and Greene posted a
message on social media doubling down on their false accusation about EPM. The Campaign and
Greene have refused to correct their false statements and have continued to stand by them.
39. Defendants knew that their smear campaign was based on a lie, but they
intentionally disregarded the truth to capitalize on national attention related to Rayshard Brooks’s
death. In addition, Rolfe wanted to punish EPM and extract money from EPM for firing her and
wanted to fraudulently obtain monetary donations from the public: upon information and belief,
Rolfe sanctioned and has accepted or intends to accept money from a GoFundMe fundraiser
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predicated on the falsehood that she was terminated “for just one reason alone: she is former
COUNT ONE:
DEFAMATION
40. EPM repeats and re-alleges the foregoing paragraphs as if set forth fully herein.
41. The Defendants made false and defamatory statements about EPM and published
these statements to numerous people, including EPM’s customers and potential customers,
residents of Fulton County, and untold millions of others beginning on June 18, 2020.
42. Specifically, the Defendants, acting jointly to harm EPM’s reputation and with
reckless disregard for the truth, made or caused to be made the following false and defamatory
a. Beginning on or around June 18, 2020, and continuing to present day, Rolfe,
the Campaign, and Greene have stated to numerous reporters, media outlets,
and others, in words or substance, that “Rolfe did not do anything wrong,
that EPM never raised any issues with her about her workplace conduct, and
that EPM fired her because Officer Garret Rolfe was her stepson and she
was fighting for him.”
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because they disapproved of who her stepson was, and in America we don’t
do things like that because it’s immoral. … The bottom line is, it seems
pretty clear they fired this woman because of who her stepson was.” 1
1 Fox News, First on ‘Tucker’: Stepmother of ex-Atlanta officer charged in Rayshard Books killing fired from her
job (June 19, 2020), https://video.foxnews.com/v/6165648907001.
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anything. So I mean, it’s just kind of strange timing but, you
know, it goes along with all of this with Garrett. But like I
said, right now it’s just this horrible statement is on their
website about me, and it’s false. It’s just completely false.
d. On June 23, 2020, the Campaign and Greene published a Facebook post
stating that “Melissa herself lost her job as a result of this nonsense,” i.e.,
events involving her stepson.
2Yahoo Finance, Stepmom of ex-police officer accused of killing Rayshard Brooks speaks out after being fired from
her job (June 30, 2020), https://finance.yahoo.com/video/stepmom-ex-police-officer-accused-004616899.html.
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e. During a televised appearance on Tucker Carlson Tonight on June 30, 2020,
Rolfe and her attorney, David Guldenschuh, had the following exchanges
with Carlson:
ROLFE: No.
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overwhelmingly negative, and the result of that was they
went on and they made a post which was absolutely
horrendous. It was terribly defamatory. It accused Melissa
of engaging in conduct that created a hostile work
environment at the facility. When she left on Friday, before
Garrett’s incident, she was held in high esteem there. Four
days later, after telling her that she was being totally
supported, the district attorney brought charges against
Garrett, and suddenly she was terminated. They got
hammered by it, by -- spontaneously by the public, and so
they went on and tried to blame it on Melissa, and we look
forward to having a jury of peers at some point correct this
very egregious wrong.
3 A rebroadcast of the June 30, 2020 interview from Tucker Carlson Tonight is available online at
https://www.youtube.com/watch?v=uYsyvOW97eA.
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f. In a June 30, 2020 publication to news media, Rolfe stated “Nothing I did
was a fireable offense and I have not gotten any guidance from EPM about
what exactly they had an issue with. It was a political move.” 4
g. In a June 30, 2020 interview to Fox News, Rolfe stated that she was:
h. In a June 30, 2020 statement to news media, Rolfe stated that EPM had
“completely defamed me.” 6
4 Maria Schutlz, Stepmom of ex-Atlanta cop Garrett Rolfe ‘stunned’ by firing after Rayshard Brooks Shooting.
Melissa Rolfe says in Fox News interview her termination was a ‘political move,’ (June 30, 2020),
https://www.foxnews.com/us/stepmom-of-ex-atlanta-cop-garrett-rolfe-stunned-she-was-fired-from-job-after-
rayshard-brooks-shooting.
5 Id.
6 Marlene Lenthang, Stepmother of Atlanta cop Garrett Rolfe breaks her silence to defend him and reveals she was
fired from her HR director job over the phone after he shot Rayshard Brooks dead (June 30, 2020),
https://www.dailymail.co.uk/news/article-8476955/Stepmother-Atlanta-cop-Garrett-Rolfe-defends-saying-war-
police-needs-end.html.
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i. On June 30, 2020, the Campaign and Greene published a tweet stating that
“Melissa’s employer caved to the mob and wrongfully fired her!” and
republished a Daily Caller article saying “Melissa Rolfe, stepmother of the
ex-Atlanta police officer charged in the killing of Rayshard Brooks, joins
Tucker Carlson to talk about being fired from her job over her relation to
her stepson” and “I believe that was the primary motive behind my being
terminated:”
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j. In early August of 2020, the Campaign, Greene, and Rolfe published and
circulated a letter signed by Rolfe and funded by the Campaign, which
contains the following false and defamatory statements about EPM:
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43. These statements are false. Before Rolfe’s stepson shot Brooks, Rolfe had been
reprimanded three times—in just over four months of employment—for workplace misconduct.
The day before Rolfe’s stepson shot Brooks, EPM notified Rolfe that she was under investigation
because of multiple complaints against her. Rolfe was terminated because she repeatedly violated
company policy and created an uncomfortable and hostile working environment by, among other
things, calling employees “savages” and “fucking bitches,” joking about conducting rectal
temperature checks in the office, saying that an employee was a “dumb bitch” who can only attract
men because she “must suck dick really good,” saying an employee had only gotten hired because
she had “big boobs,” telling a Black woman who dates Black men that she needed “to get outside
the box and upgrade [her] standards,” and—in response to another employee’s joke that she liked
her coffee black and strong like she liked her men—by retorting “Black and weak. Don’t no
concerning EPM and were actually understood to be statements of fact and of and concerning
EPM.
45. These statements are defamatory and defamatory per se because they subject EPM
to public hatred, contempt, and ridicule; because they were published in connection with—and
made specifically to injure—EPM’s business and charge the company with being unfit for carrying
on its business; because they charge EPM with dishonest conduct and other debasing acts that may
46. Defendants had no applicable privilege or legal authorization to make these false
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47. Defendants made these false and defamatory statements intentionally, willfully,
maliciously, and in conscious disregard of EPM’s rights and reputation and of the truth.
48. Defendants acted with actual malice, showing intentional or reckless disregard for
the falsity of their statements about EPM. Defendants’ disregard for the truth is demonstrated by
their actions and omissions including but not limited to the following:
a. Rolfe knew from her personal experience that she had repeatedly made
inappropriate remarks to and about EPM employees and that she had been
reprimanded by EPM’s CEO on three separate occasions for that workplace
conduct before her stepson shot Rayshard Brooks; upon information belief,
Greene and her Campaign knew about the circumstances of Rolfe’s
termination from communications with Rolfe on the day of her termination
and thereafter;
d. After EPM demanded a retraction and put the Campaign and Greene on
formal written notice of Rolfe’s previous reprimands and the employee
complaints regarding Rolfe’s misconduct, the Campaign and Greene
published a Facebook post doubling down on the lie;
f. Defendants made their defamatory accusations with the intent to harm, and
out of hostility toward, EPM.
49. Just as Defendants authorized, expected, and intended, their false and defamatory
statements have been foreseeably repeated, republished, and disseminated to a worldwide internet
audience.
50. As a direct and foreseeable result of Defendants’ false and defamatory statements,
EPM’s professional standing in relation to its business and trade has been substantially impugned.
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51. As a direct and foreseeable result of Defendants’ false and defamatory statements,
EPM’s relationships with community members, employees, peers, customers, potential customers,
52. As a direct and foreseeable result of Defendants’ false and defamatory statements,
53. As a direct and foreseeable result of Defendants’ false and defamatory statements,
EPM has been forced to make substantial expenditures of money to remedy the defamation and
54. In view of the foregoing, EPM is entitled to actual, presumed, punitive, and other
COUNT TWO:
FALSE LIGHT INVASION OF PRIVACY
55. EPM repeats and re-alleges the foregoing paragraphs as if set forth fully herein.
56. Defendants created false publicity that depicts EPM as something that it is not.
57. The false light in which Defendants placed EPM would be highly offensive to a
reasonable person.
59. Defendants caused the false implication with actual malice and reckless disregard
60. Defendants acted with actual malice, showing intentional or reckless disregard for
the falsity of their statements about EPM. Defendants’ disregard for the truth is demonstrated by
their actions and omissions including but not limited to the following:
a. Rolfe knew from her personal experience that she had repeatedly made
inappropriate remarks to and about EPM employees and that she had been
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reprimanded by EPM’s CEO on three separate occasions for that workplace
conduct before her stepson shot Rayshard Brooks; upon information belief,
Greene and her Campaign knew about the circumstances of Rolfe’s
termination from communications with Rolfe on the day of her termination
and thereafter;
d. After EPM demanded a retraction and put the Campaign and Greene on
formal written notice of Rolfe’s previous reprimands and the employee
complaints regarding Rolfe’s misconduct, the Campaign and Greene
published a Facebook post doubling down on the lie;
f. Defendants made their defamatory accusations with the intent to harm, and
out of hostility toward, EPM.
61. Just as Defendants authorized, expected, and intended, their false and defamatory
statements have been foreseeably repeated, republished, and disseminated by a worldwide internet
audience.
62. Defendants had no applicable privilege or legal authorization to make these false
63. In view of the foregoing, EPM is entitled to actual, presumed, punitive, and other
DEFENDANTS’ CONDUCT
WARRANTS PUNITIVE DAMAGES
64. EPM repeats and realleges the paragraphs set forth above as if set forth fully herein.
65. Defendants’ conduct warrants the imposition of punitive damages. The factors
justifying punitive damages include, but are not limited to, the following:
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a. Rolfe knew from her personal experience that she had repeatedly made
inappropriate remarks to and about EPM employees and that she had been
reprimanded by EPM’s CEO on three separate occasions for that workplace
conduct before her stepson shot Rayshard Brooks; upon information belief,
Greene and her Campaign knew about the circumstances of Rolfe’s
termination from communications with Rolfe on the day of her termination
and thereafter;
d. After EPM demanded a retraction and put the Campaign and Greene on
formal written notice of Rolfe’s previous reprimands and the employee
complaints regarding Rolfe’s misconduct, the Campaign and Greene
published a Facebook post doubling down on the lie;
f. Defendants made their defamatory accusations with the intent to harm, and
out of hostility toward, EPM;
WHEREFORE, Plaintiff Equity Prime Mortgage, LLC respectfully requests that the Court
enter judgment in its favor against Defendants Melissa Rolfe, Marjorie Taylor Greene, and Greene
(2) All costs, disbursements, fees, and interest as authorized by law; and
(3) Such other additional remedies as the Court may deem just and proper.
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Dated: September 24, 2020 Respectfully Submitted,
s/ Brent L. Wilson
Brent L. Wilson
Georgia Bar No. 767667
Timothy J. Holdsworth
Georgia Bar No. 730986
Elarbee, Thompson, Sapp & Wilson LLP
800 International Tower
229 Peachtree Street, NE
Atlanta, Georgia 30303
Telephone: (404) 582-8427
Email: bwilson@elarbeethompson.com
Email: holdsworth@elarbeethompson.com
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IN THE SUPERIOR COURT OF FULTON COUNTY
STATE OF GEORGIA
Plaintiff,
Civil Action No. 2020CV339285
v.
JURY TRIAL DEMANDED
MELISSA ROLFE,
and
Defendants.
CERTIFICATE OF SERVICE
I hereby certify that I served a true and correct copy of Plaintiff's AMENDED
COMPLAINT FOR DAMAGES on counsel for Defendants Melissa Rolfe and Greene For
Congress, Inc. via e-mail and U.S. Mail, postage pre-paid, to the following addresses:
s/ Brent L. Wilson
Brent L. Wilson
Georgia Bar No. 767667
Timothy J. Holdsworth
Georgia Bar No. 730986
Elarbee, Thompson, Sapp & Wilson LLP
800 International Tower
229 Peachtree Street, NE
Atlanta, Georgia 30303
Telephone: (404) 582-8427
Email: bwilson@elarbeethompson.com
Email: holdsworth@elarbeethompson.com
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Exhibit A