IN THE COURT OF COMMON PLEAS FOR SANDUSKY COUNTY, OHIO

MELISSA ACKISON :
13597 Leeper Perkins Road :
Marysville, OH 43040 : Case No.
:
Plaintiff, :
:
-vs- :
: Judge
GARY CLICK :
1473 County Road 268 :
Vickery, OH 43464 :
:
Defendant. :

COMPLAINT

1. This is an action for damages in excess of Twenty-Five Thousand Dollars

($25,000.00), exclusive of costs and interest.

2, At all times mentioned herein, the Plaintiff, Melissa Ackison (hereinafter

“Plaintiff”) was a resident of Union County, Ohio.

3. At all times mentioned herein, the Defendant, Gary Click (hereinafter

“Defendant”) was a resident of in Sandusky, Ohio.

4. This Court has subject matter jurisdiction and personal jurisdiction over the

parties because of the following: (1) some of the incidents giving rise to this Complaint occurred

within Sandusky County, Ohio, and (2) the Defendant is a resident of Sandusky County, Ohio.

5. Venue is proper under the following Rules of Civil Procedure: (1) under Civ.R.

3(C)(1) the Defendant is a resident of Sandusky County, Ohio; (2) under Civ.R. 3(C)(2) as the

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County in which the Defendant has his principal place of business is Sandusky County, Ohio;

and/or (3) under Civ.R. 3(C)(3) and Civ.R. 3(C)(6) as some of the incidents giving rise to this

Complaint occurred in Sandusky County, Ohio.

FACTUAL ALLEGATIONS

6. Plaintiff reincorporates by reference each and every allegation contained in

Paragraphs One (1) through Five (5) as if fully rewritten.

7. The Plaintiff is an individual that owns a small business in Union County, Ohio.

She is married and has four children, with two small children still at home.

8. On or about April 24, 2019, the Plaintiff announced her decision to seek the

Republican Nomination for the Ohio State Senate District 26.

9. The Ohio State Senate District 26 is comprised of Crawford, Marion, Morrow,

Sandusky, Seneca, Wyandot, and Union Counties.

10. The Plaintiff, as an individual seeking the Republican Nomination for the Ohio

State Senate District 26 has actively started her political campaign across District 26 in every

county mentioned above. Said Republican State Senate Primary is March 17, 2020.

11. The Defendant is an individual, who is the Pastor of the Fremont Baptist Temple

in Fremont, Ohio, Sandusky County, Ohio.

12. The Defendant is the State of Ohio Republican Central Committeeman presiding

over the 26th District of Ohio.

13. The Defendant lost the May 2016 primary for Sandusky County Commissioner.

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 14. On September 5, 2019, the Defendant resigned from the Governor’s Faith

Advisory Council.

15. The Defendant is also the former National Legislative Director for the Buckeye

Christian School Organization.

16. On or about August 12, 2019, the Defendant announced his candidacy to seek the

Republican Nomination for the Ohio House of Representatives District 88, encompassing

Sandusky and Seneca Counties, currently held by the Plaintiff’s opponent for the Ohio State

Senate District 26.

17. On or about August 2019, the Defendant ambushed the Plaintiff at the Republican

Party Booth at the Union County Fair in Marysville, Ohio. The Defendant stated to the Plaintiff

that she was trash, that no one liked her, that she was a liar, a lunatic, a liberal, that she doesn’t

act Christian, that she was fake, and she was a phony. The Defendant stated the above to the

Plaintiff in front of her husband and at least one of Plaintiff’s supporters as well as both of her

children, ages nine (9) and two (2). The incident was recorded and made statewide news.

18. Since the above stated incident, the Defendant has repeatedly sought to disparage

and/or harm the Plaintiff and/or Plaintiff’s reputation by intentionally seeking out supporters of

the Plaintiff, fellow Republicans, Plaintiff’s donors, and County Republican Central Committee

Members located in the 26th district.

19. Further, the Defendant has sought to intentionally disparage and/or harm the

Plaintiff and/or Plaintiff’s reputation by meeting with organizations that offer endorsements to

political candidates, such as Ohio Value Voters.

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 20. The Defendant has sought to intentionally disparage and/or harm the Plaintiff

and/or the Plaintiff’s reputation by telling various individuals and organizations mentioned above

any one and/or all of the following: that the Plaintiff is Anti-Semitic, that the Plaintiff is a

Muslim Sympathizer, that the Plaintiff and/or her husband is in financial despair, that the

Plaintiff and/or husband has filed bankruptcy, and that the Plaintiff is a criminal and/or the

Plaintiff has a criminal record, all of which are false and untrue.

21. As a result of the named Defendant’s actions in speaking to the above-mentioned

individuals and/or organizations, the Plaintiff has lost supporters, financial donors, endorsers,

voters, and/or party resources at the State and County level.

22. Also, as a result of the named Defendant’s actions, the Plaintiff has to answer

questions about the Defendant’s outrageous conduct and false and defamatory statements to not

only her supporters, donors, endorsers, and/or organizations, but also to the Ohio Republican

Party. In fact, the Ohio Republican Party has withdrawn their support and/or resources for the

Plaintiff as determined by the Executive Director, Rob Secaur.

23. As a further result of the named Defendant’s actions, news reports have been

published in various local newspapers and/or online news reporting sites, and/or broadcast on the

internet that contained the news of the Defendant’s untrue statements, which were false,

defamatory, and/or gave innuendos that were false and defamatory in nature. In fact, the Ohio

Executive Director of the Republican Party, Rob Secaur told the Plaintiff that he felt it was

completely disingenuous for the Plaintiff to play the victim, while feeding negative stories to a

liberal blog, aka TiffinOhio.net.

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 24. The Plaintiff has tried to resolve these issues with the Defendant on numerous

occasions through many platforms including but not limited to the following: the Plaintiff has

tried to talk to the Defendant personally, had other individuals talk to the Defendant, had an

attorney send a cease and desist letter to the Defendant, had a private investigator talk to the

Defendant, and even tried to have the Ohio Republican Party intervene. All these efforts to get

Defendant to stop his defamatory language and/or actions about the Plaintiff have failed.

FIRST CAUSE OF ACTION - DEFAMATION

25. Plaintiff reincorporates the allegations contained in Paragraphs One (1) through

Twenty-Four (24) as if fully rewritten herein.

26. The statements and/or actions of Defendant as to the Plaintiff are defamatory,

false and untrue, and diminishes the respect, esteem, and/or goodwill toward the Plaintiff and

deters others from association with the Plaintiff.

27. The defamatory language and/or statements herein described is of or concerning

the Plaintiff and holds her up to scorn or ridicule in the eyes of a substantial number of

respectable members of the community as well as the people of the 26 th Ohio Senate District.

28. Defendant had actual knowledge that the statements were false and/or with

reckless disregard of whether they were false and/or with actual malice published these

statements to third parties who understood the defamatory nature of the above-mentioned

statements and/or communications. Moreover, the Defendant caused these defamatory

statements and this defamatory language to be published and broadcasted. Further, Defendant

knew and/or should have known that his defamatory language and/or statements would be

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published by several newspapers and broadcasted over the internet within the Sandusky County

area as well as the counties of the 26th Ohio Senate District. Defendant’s actions are done with

malicious intent.

29. Plaintiff and Defendant are both public figures.

30. As a direct result and proximate cause of the above described untrue and false

defamatory statements, behaviors, actions, and malicious lies told by the Defendant, Plaintiff has

lost supporters, financial donors, endorsers, and/or voters and continues to lose supporters,

financial donors, endorsers, and/or voters as the Defendant continues his defamatory actions.

31. As a further proximate result of the above-described behaviors, actions, and/or

untrue and false defamatory statements, Plaintiff has suffered damage to her personal,

professional, and/or occupational reputation, all to her injury, and is entitled to general and

special damages in an amount exceeding $25,000.

32. As further proximate result of the above-described behaviors, actions, and untrue

and false and defamatory statements by the Defendant, which were spoken by Defendant with

actual malice and/or Defendant had knowledge that the statements were false and untrue and/or

with reckless disregard of whether they were false and untrue, were made with a conscious

disregard to Plaintiff’s reputation and rights, the Plaintiff is entitled to an award of exemplary

and punitive damages in the an amount to be established at the time of trial.

SECOND CAUSE OF ACTION - DEFAMATION BY INNUENDO

33. Plaintiff reincorporates the allegations contained in Paragraphs One (1) through

Thirty-Two (32) as if fully rewritten herein.

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 34. By the foregoing false, malicious, and/or defamatory communication(s),

Defendant intended to convey the meaning and was understood to mean by the public, local

media, and/or by other persons to whom the above stated actions, statements, and/or

communication(s) were made that Plaintiff had a criminal record and/or committed crimes.

35. Plaintiff is a public figure and the Plaintiff has not been guilty of any criminal

offenses and/or charged with any criminal offenses. Said Defendant’s above stated actions,

statements, and/or communication(s) mentioned above are defamatory and wholly false.

36. Plaintiff, before and at the time of Defendant’s innuendos and/or statements

mentioned above, possessed a good name and character amongst her neighbors, peers,

supporters, donors, endorsers, voters, staff, and acquaintances and was known for her moral

worth and integrity, and was never suspected of any criminal activity and/or any crime.

37. As a direct result and proximate cause of the above described innuendos of

Defendant’s behaviors, actions, and/or statements by the Defendant, Plaintiff has lost supporters,

donors, endorsers, and/or voters and continues to lose supporters, financial backers, endorsers,

and/or voters as the Defendant continues his defamatory actions.

38. As a further proximate result of the above-described innuendos of Defendants’

behaviors, actions, and/or statements, Plaintiff has suffered damage to her personal, professional,

and/or occupational reputation, all to her injury, and is entitled to general and special damages in

an amount exceeding $25,000.

39. As further proximate result of the above-described innuendos of Defendant’s

behaviors, actions, and/or statements all of which were false and untrue, and that were spoken by

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Defendant with actual malice and/or Defendant had knowledge that the statements were false

and untrue and/or with reckless disregard of whether they were false and untrue, were made with

a conscious disregard to Plaintiff’s reputation and rights, or with a conscious disregard to

Plaintiff’s reputation and rights, and as such the Plaintiff is entitled to an award of exemplary and

punitive damages in an amount to be established at the time of trial.

THIRD CAUSE OF ACTION – SLANDER

40. Plaintiff reincorporates the allegations contained in Paragraphs One (1) through

Thirty-Nine (39) as if fully rewritten herein.

41. The statements of Defendant were false and untrue and defamatory and/or

statements that diminish the respect, esteem, and/or goodwill toward the Plaintiff and/or deters

others from association with the Plaintiff.

42. The defamatory language and/or statements herein described is of or concerning

the Plaintiff and holds her up to scorn or ridicule in the eyes of a substantial number of

respectable members of the community as well as the people of the 26 th Ohio Senate District.

43. Defendant had knowledge that the statements were untrue false and untrue and/or

with reckless disregard of whether they were false and untrue, and/or were made with actual

malice published to third parties who understood the defamatory nature of the above-mentioned

communications.

44. As a direct result and proximate cause of the above described statements by the

Defendant, Plaintiff has lost supporters, donors, endorsers, and/or voters and continues to lose

supporters, donors, endorsers, and/or voters as the Defendant continues his defamatory actions.

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 45. As a further proximate result of the above-described statements, Plaintiff has

suffered damage to her personal, professional, and/or occupational reputation, all to her injury,

and is entitled to general and special damages in an amount exceeding $25,000.

46. As further proximate result of the above-described statements by the Defendant

that are all false and untrue, were spoken by Defendant with actual malice and/or Defendant had

knowledge that the statements were false and untrue and/or with reckless disregard of whether

they were false and untrue, were made with a conscious disregard to Plaintiff’s reputation and

rights, or with a conscious disregard to Plaintiff’s reputation and rights, and as such the Plaintiff

is entitled to an award of exemplary and punitive damages in an amount to be established at the

time of trial.

FOURTH CAUSE OF ACTION – SLANDER Per Se

47. Plaintiff reincorporates the allegations contained in Paragraphs One (1) through

Forty-Six (46) as if fully rewritten herein.

48. The statements of Defendant were defamatory language and/or statements that

were false and untrue and diminish the respect, esteem, and/or goodwill toward the Plaintiff

and/or deter others from association with the Plaintiff.

49. The defamatory language and/or statements herein described is of or concerning

the Plaintiff and holds her up to scorn and/or ridicule in the eyes of a substantial number of

respectable members of the community and/or voters of the Ohio Senate District 26.

50. Defendant’s actions and/or statements concerning the Plaintiff were false and

untrue, were spoken by Defendant with actual malice and/or Defendant had knowledge that the

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statements were false and untrue and/or with reckless disregard of whether they were false and

untrue published to third parties who understood the defamatory nature of the above-mentioned

communications.

51. As a direct result and proximate cause of the above described statements by the

Defendants, Plaintiff has lost supporters, donors, endorsers, and/or voters and continues to lose

supporters, donors, endorsers, and/or voters as the Defendant continues his defamatory actions.

52. As a further proximate result of the above-described statements, Plaintiff has

suffered damage to her personal, professional, and/or occupational reputation, all to her injury,

and is entitled to general and special damages, as the damages are presumed, in an amount

exceeding $25,000.

53. As further proximate result of the above-described statements by the Defendants

that were false and untrue, and were spoken by Defendant with actual malice and/or Defendant

had knowledge that the statements were false and untrue and/or with reckless disregard of

whether they were false with a conscious disregard to Plaintiff’s reputation and rights, the

Plaintiff is entitled to an award of exemplary and punitive damages in the an amount to be

established at the time of trial.

54. In regards as to all of the above mentioned false and untrue statements and claims,

the Defendant acted willfully, maliciously, wantonly, recklessly, and in utter disregard of the

truth.

WHEREFORE, the Plaintiffs pray for judgment against Defendant in a sum in excess of

Twenty-Five Thousand Dollars ($25,000.00) for compensatory and special damages as is

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reasonable and proper and commensurate with her full losses, and any and all punitive or

exemplary damages, and any other reasonable damages, plus costs and for such other and further

relief as the Court may deem just and proper.

____________________________________
J.C. Ratliff (#0027898)
Jeff Ratliff (#0083818)
Rocky Ratliff (#0089781)
Edwin M. Bibler (#0097668)
Attorneys for Plaintiff
200 W. Center St.
Marion, OH 43302
Telephone: 740/383-6023
Fax: 740/383-2066
Email: attorney.ratliff@gmail.com

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 INSTRUCTIONS FOR SERVICE

TO THE CLERK:

Please issue Summons and a certified copy of the foregoing Complaint upon the

following named Defendant, via certified mail, return receipt requested:

Gary Click
1473 County Road 268
Vickery, OH 43464

___________________________________
J.C. Ratliff (#0027898)
Jeff Ratliff (#0083818)
Rocky Ratliff (#0089781)
Edwin M. Bibler (#0097668)
Attorneys for Plaintiff

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