Case 1:16-cv-04642 Document1 Filed 06/20/16 Page 8 of 9

Case 1:16-cv-04642 Document1 Filed 06/20/16 Page 8 of 9 framed to solicit media attention or, perhaps, are simply politically motivated. There is absolutely no merit to these allegations. Period.” The statement provided for publication by Defendant Trump was published by said website and has been republished elsewhere in whole or in part numerous times (and similar statements of an attorney for Defendant Trump were also published). The statement provided for publication by Defendant Trump and that was published by said websites is false as it pertains to Plaintiff. 28. The published statement is libelous on its face, and clearly exposes Plaintiff to hatred, contempt, ridicule and obloquy. 29. As a proximate result of the above-described publication, Plaintiff has suffered loss of her reputation, shame, mortification, and injury to her feelings, all to her damage in an amount to be established by proof at trial. 30. The above-described publication was not privileged because it was published by Defendant Trump with malice, hatred and ill will toward Plaintiff and the desire to injure her. 31. As a direct and proximate result of Defendant Trump’s defamation of Plaintiff, Plaintiff has been subjected to public scorn, hatred, and ridicule and has suffered other injury. PRAYER FOR RELIEF WHEREFORE, Plaintiff prays for judgment against Defendants and for the following relief: A. That judgment be entered against Defendants for special damages, compensatory damages, and punitive damages in an amount which shall be shown to be reasonable and just by the evidence and in excess of Seventy Five Thousand Dollars ($75,000.00), exclusive of interests and costs; HOUSE_OVERSIGHT_026391