‘STATE OF NORTH CAROLINA FIL COUNTY OF MECKLENBURG = ins "'2 14 THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION et BSS 302. CHRISTINEFCHISHOLM, ) : ) Plaintiff ) COMPLAINT vs. ) ) TAUHEED EPPS, alla 2CHAINZ, and) RO'ZAY RICHIE, a/k/a CAP 1, ) . ) -~..Deferidants ) / Plaintiff, Christina Chisholm, complaining of Defendants, Tauheed Epps, and Ro’Zay Richie, alleges and says: : ES. ISDIC ND VENUE 4. Plaintiff Christina Chisholm (hereinafter, "Mrs. Chisholm" or "Plaintif’) is an adult citizen and resident of Mecklenburg County, North Carolina. 2. Defendant Tayheed: Epps a/k/a 2Chainz (hereinafter, Epps") is an adult citizen and resident of fr 3, Defendant Ro’zay Richie a/k/a Cap-1 (hereinafter, “Richie”) is aii ‘adult citizen and resident of a 4, Venue of this action is proper in Mecklenburg County, North Carolina, because this is where the causes of action arose and it is where Plaintiff resides. i 5, This Court has. subject matter jurisdiction over. the. claims in. this Complaint. 6, This is an action to recover money damages resulting from Defendant's defamation of Plaintiff. FACTUAL ALLEGATIONS: 7. Atall times pertinent to the allegations contained herein, Epps was a rap music artist known as “2Chainz.” Case 3:15-cv-00291-GCM Document 1-1 Filed 07/07/15 Page 3 of 98 On Tuesday, March 20, 2014, Ms. Chisholm attended a show at the ulmore Theater in Charlotte, North Carolina, 9. Ms. Chisholm was. invited to the show by Richie, and was admitted backstage, 10. While backstage Epps recorded a video of Ms. Chisholm 11. Epps'is heard referring to Ms, Chisholm as a "THOT", which Epps and his Intended audience understood to be an acronym for “That Hoe Over There.” 12. “Hoe” as used by Epps, and defined by the Urban Dictionary, means a skank’, ‘whore’, or “promiscuous person.” 18. Epps later posted the video to his blog and other websites, including creating the hashtag “#isthatyothot,” 14. The video has been viewed on multiple websites, with over 10 million views on Youtube and over a milion views Worldstarhiphop.com, since the release of the video the view numbers have been altered and some, videos with over 8 million views or more have been deleted. 18. There have been over a million comments posted by viewers on Youtube and over a.millon views on Worldstarhiphop.com and other numerous sites. Some of the comments are: a. "She was. thirsty ass hell maaaaaan!?IHow the hell can you have fuckin sympathy for this groupie hoe!?!2!71And she was DUMBIIIl" b. "He was nicer to her than she deserved. The hoe went there trying to get some dick, instead she got clowned for being a clown ass hoe and told she should probably step before she clowried some more.” 6. “She deserved to be treated like that. A classless hos, showing how desperate she is... Why should they show her respect when she doesn't respect herself?” d, "Real talk, why respect a women, who don't respect herseff... She deserved it Dumb Bitch." ®, "SHE A STUPID HOE LOL SHE THOUGHT,,.....-.....44STHISYOTHOT.” f. “can tell by her lips she suck alotta dick.” g. “This bitch dumb as fuck." Case 3:15-cv-00291-GCM Document 1-1 Filed 07/07/15 Page 4 of 9h JARHEH, jus enother THOT that thought she was cutel Kill urself J. "@LUVTINAA IS HER ISTAGRAM LOL EVERYONE PUT HER ON BLAST SHES TRYING TO SUE 2 CHAINZ CHECK HER INSTAGRAM #ISTHISYOTHOT.” 16. _ Ms, Chisholm had previously been employed as‘a front desk manager at No Grease Barbershop in Charlotte. 17. On April 3, 2014,.Ms. Chisholm was told by her manager at No Grease not to come back to work. Her manager said the video posted by Epps would cause negative: publicity for No Grease company because the majority male. clientele and males working alongside Ms, Chisholm. 48. Asa direct result of the video being posted online, Ms. Chisholm has been subject to harassment and verbal abuse in public. 19. 20. Epps" publication of false and misleading statements concerning Ms, Chisholm constitute slander. 21. Epps’ made his statements willingly, with the intention to defame, degrade, and humiliate Ms. Chisholm. 22, Epps made his statements in bad faith and with reckless indifference to the damages to Ms. Chisholm. 23, Epps published his statement to the world 24. Epps’ staternents were wilful, wanton, and show a reckless disregard for the rights of Ms, Chistolm’s rights, As a result Ms. Chisholm has suffered and continues to suffer damages, including embarrassment public: ridicule, inability to find employment, and mental anguish, 25. Ms. Chisholm suffered financial loss and emotional damages as a result of Epps' actions. 26. Case 3:15-cv-00291-GCM Document 1-1 Filed 07/07/15 Page 5 of 927. 28. FIRST CLAIM FOR RELIEF [Defamation per se — Libel and Siander] 29. Plaintiff restates and realleges the allegations contained in the preceding paragraphs as if fully set out. 30. Defendants intentionally published false oral and written statements of and concerning Plaintiff, as more specifically described above. Defendant's defamatory statements were published, transmitted, and/or viewed by countless third parties, both known and unknown to Plaintif. 31. Defendant's statements subjected Plaintiff to ridicule, contempt and disgrace. 32. - Defendant's statements accuse Plaintiff of having low moral character and repeatedly engaging in immoral and illegal activities. 33, The statements made by Defendant's have no reasonable basis: in fact and there was no justification for Defendant's misconduct in publishing the statements. 34. No privilege of any type protects the statements made by Defendants. 35. Defendants’ published such statements. with actual. malice, that is, with knowledge that they were false, or with a reckless disregard for their truth. 36. Defendants published the statements _ willfully, wantonly and/or maliciously, warranting an award of punitive damages in.an amount sufficient to punish them and to deter each of them and others similarly situated from engaging in such misconduct in the future. 37. Defendants statements constitute libel per se and slander per se. 38. As a direct and proximate cause of Defendant's per se defamatory statements, all of which are false, Plaintiff has. suffered actual damages, including without limitation metal suffering, injury fo her reputation, and injury to her ability to carry out her trade, business, or profession, In an amount not yet. fully determined, but believed to be in excess of $%000,000,/10 4 Case 3:15-cv-00291-GCM Document 1-1 Filed 07/07/15 Page 6 of 9SECOND CLAIM FOR RELIEF [Defamation — Libel and Slander] 39. Plaintiff realleges and incorporates by reference the preceding paragraphs as if fully set forth herein, 40, _Defendants intentionally published false oral and written statements of and conceming Plaintiff, as more specifically described above. Defendants defamatory statements were published, transmitted, and/or viewed by countless third parties, both known and unknown to Plaintiff. 41, Defendants’ statements impeach Plaintiff in her trade or profession, and/or otherwise subject Plaintiff to ridicule, contempt, or disgrace. 42. Defendants’ statements accuse Plaintiff of committing a heinous crime or ‘one involving moral turpitude. 43, The statements made by Defendants have no reasonable basis In fact and there was no justification for Defendants’ misconduct in publishing the statements. 44. _ No privilege of any type protects the statements made by Defendants. 45. Defendants published such statements with actual malice, that is, with knowledge that they were false or with a reckless disregard of their truth. 46. Defendants published the statements wilfully, wantonly and/or maliciously, warranting an award of punitive damages in an amount sufficlent to. punish them and to deter each of them and others similarly situated from engaging in such misconduct in the future. 47. As adirect and proximate result of Defendants’ defamatory statements, all ‘of which are false, Plaintiff has suffered actual damages, including without imitation mental suffering, injury to her reputation, and injury to her ability to carty out her trade, business, or profession, in an amount not yet finally determined, but believed to. be in excess of $5000,00000 THIRD CLAIM FOR RELIEF [Punitive Damages] 48. Plaintiff restates and realleges the allegations contained in the preceding paragraphs as if fully set out. 49. Defendants’ actions described herein were malicious, intentional, wilful, wanton, and done with a reckless disregard for the. rights of the Plaintiff. Pursuant to N.C.G.S. § 1D-1, ef seq., to prevent Defendants from future bad acts, and to prevent Case 3:15-cv-00291-GCM Document 1-1 Filed 07/07/15 Page 7 of 9others engaging in similar wrongful conduct, Plaintiff is entitled to recover punitive damages from Defendants. URTH CLAIM FOR RELI IINTENTIONAL/RECKLESS INFLICTION OF SEVERE EMOTIONAL DISTRESS] 50. Plaintiff restates and realleges the allegations contained in the preceding paragraphs as if fully set out. 51. Defendants’ conduct was extreme and outrageous in that it exceeded all bounds usually tolerated by decent society. 52. Defendants’ conduct was intended to cause, or was recklessly indifferent to the likelihood that it would cause, severe emotional distress to Plaintif. 53. Defendants’ conduct in fact caused severe emotional distress to Plaintiff 54, As a direct and proximate result of Defendants’ Intentional. or reckless infliction of severe emotional. distress, Plaintiff suffered damages, emotionally and physically. Fifth claim N.C, Gen, Stat § 75-1.1: Unfalr & Deceptive Trade Practices PRAY! JE WHEREFORE, Plaintiff prays the Cou 1. Award Plaintiff damages against Defendants, jointly and severally, in an amount to be proven at trial, for their assault, battery, false imprisonment, and intentional infliction of emotional distress of Plaintiff immediately. 2. Grant Plaintiff punitive damages against Defendants for their malicious, and willful and wanton conduct, pursuant to N.C. Gen. Stat. §§ 1D-1, ef seq immediately. 3. _ That Plaintiff have and recover her attomeys' fees to the fullest extent allowed by law; 4. Tax the costs of this action against Defendants; and 5. Grant Plaintiff any other remedy which this Court deems just and equitable under the circumstances, Case 3:15-cv-00291-GCM Document 1-1 Filed 07/07/15 Page 8 of 9¢ : c GS.§10B-41 NOTARIAL CERTIFICATE FOR ‘ACKNOWLEDGMENT to me that he or she signed the: » _ Unristing Chichole pees “Case 3:15-cv-00291-GCM Document 1-1 Filed 07/07/15 Page 9 of 9