The statements by Stephanopoulos are false, misleading, disparaging and defamatory towards Plaintiff. As a proximate result, Plaintiff suffered substantial special, general and exemplary damages, including but not limited to loss of personal and business reputations and lost business opportunity, emotional distress, embarrassment and personal humiliation. Plaintiff realleges paragraphs 1 through 19 as if fully set forth herein. The statements also place Plaintiff in a false light that is highly offensive to a reasonable person. As a proximate result, Plaintiff suffered substantial damages including but not limited to loss of personal and business reputations and lost business opportunity, emotional distress, embarrassment and personal humiliation.
Plaintiff demands trial by jury on all issues so triable.
Larry Klayman, Esq. Paul J. Orfanedes, Esq.