Cardi B's Lawsuit Against A Celebrity Blogger
Cardi B's Lawsuit Against A Celebrity Blogger
Plaintiff,
v. Case No. 1-19-cv-01301-WMR
Defendants.
Defendant Latasha Transrina Kebe a/k/a Latasha Transrina Howard (“Kebe”) and
alleges as follows:
slander per se, slander, libel per se, and defamation, as a result of Defendants’
false, harmful, and offensive to Plaintiff, as well as invasion of privacy – false light
PARTIES
3. Upon information and belief, Kebe is and at all times during the
pendency of this action has been a citizen and resident of the State of Georgia.
liability company with a principal office address of 3614 Janna Lane SW, Marietta,
Georgia 30008.
5. Upon information and belief, Kebe Studios was formed on April 14,
2018 as an alter ego or mere business conduit for Kebe’s activities alleged herein.
6. This Court has jurisdiction over the subject matter of this action
upon information and belief, Kebe owns, uses, or possesses real property within
the State of Georgia, regularly transacts business as described below within the
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State of Georgia, and committed a tortious act within the State of Georgia,
upon information and belief, Defendants are residents of this District and because,
upon information and belief, the conduct complained of occurred in this District.
FACTUAL BACKGROUND
10. Since the release of her full-length debut mixtape in 2015, Plaintiff’s
musical works have reached peak positions on charts in the United States and
around the world. As a result of the popularity of her music, Plaintiff has millions
of fans in the United States and around the world who follow her work and her
12. In addition to her artistic endeavors, Plaintiff is well known for her
affected by gang violence and performing volunteer work in handing out coats to
underprivileged persons.
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natural person who claims to have known Plaintiff before her musical career.
14. Upon information and belief, Jones currently conducts business in the
belief, in pursuit of this goal, Jones promotes herself and her entertainment
endeavors through social media, where she has about ten thousand followers.
17. Upon information and belief, Kebe produces, hosts, and publishes
18. Upon information and belief, while Kebe calls her site “a celebrity
Kebe to publish and spread malicious rumors, slanderous assertions, and false
information about celebrities, including Plaintiff, for her personal financial gain.
19. Upon information and belief, Kebe does this to draw various
celebrities’ social media followers to her site, including Plaintiff’s social media
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followers, so she can increase what she charges for advertising to third parties that
20. Upon information and belief, in early 2018, Kebe targeted Plaintiff
around April 13, 2018, Kebe published a video where Kebe stated that as a result
disabilities.
22. Upon information and belief, in the months preceding the filing of this
lawsuit, Kebe took her vitriol one step further by making blatantly defamatory
23. Upon information and belief, Kebe became obsessed with slandering
and harassing Plaintiff. In the sixteen months preceding the filing of this lawsuit,
24. Upon information and belief, as set forth below, Kebe’s videos about
Plaintiff attract substantially more viewers than most of her other videos, which is
25. Upon information and belief, to this end, Kebe has published in the
past few months several videos with more false and defamatory statements about
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Plaintiff, who has become the target of Kebe’s malicious campaign to damage and
destroy Plaintiff’s reputation among her fans and the consuming public.
27. The 9/2/18 Video contains at least one false and defamatory statement
about Plaintiff.
28. The 9/2/18 Video contains the false, malicious, and defamatory
29. Upon information and belief, Kebe published the 9/2/18 Video to tens
30. Upon information and belief, around that same time, on or around
September 13, 2018, Jones published a video of herself to her Instagram followers
Instagram Live, which allows users to film live videos that can be watched either
Video”).
31. The Jones Video contains multiple false and defamatory statements
about Plaintiff.
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32. In the Jones Video, Jones made the false, malicious, and defamatory
33. In the Jones Video, Jones also made the false, malicious, and
34. In the Jones Video, Jones also falsely stated that Plaintiff was
they were supposed to have sex, exchange sex for money.” (Jones Video at 15:50.)
35. Shortly after Jones released the Jones Video, on or around September
13, 2018, Jones also published written comments on her Instagram account to third
36. Upon information and belief, continuing her campaign of slander, and
and later published a video of herself interviewing Jones regarding the Jones Video
A Huge Box filled with MONlSTAT & REVEALS More!” (the “9/19/18 Video”).
37. Upon information and belief, Kebe knew that publishing a video
regarding Plaintiff would draw substantially more viewers to her content than she
typically garners.
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38. Upon information and belief, the 9/19/18 Video, has garnered over
four million views. By way of comparison, upon information and belief, the last
full-length video Kebe published prior to the 9/19/18 Video only garnered
39. Upon information and belief, only nine of her approximately 236
videos published prior to the 9/19/18 Video garnered over one million views.
40. The 9/19/18 Video contains multiple false and defamatory statements
about Plaintiff.
41. The 9/19/18 Video contains the false, malicious, and defamatory
statement that Plaintiff was a prostitute (0:40: “(Kebe) You said that Cardi B
42. The 9/19/18 Video contains the false, malicious, and defamatory
statement that Plaintiff used cocaine (0:40: “(Kebe) Was she a drug user?” “(Ms.
43. The 9/19/18 Video also contains the false, malicious, and defamatory
statement that Plaintiff has herpes (0:48: “(Kebe) She has herpes?” “(Jones) Yes”).
44. The 9/19/18 Video contains the false, malicious, and defamatory
statement that Plaintiff also had herpes outbreaks on her mouth in the past (17:25:
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“(Kebe) So you were living with her at the time and she had herpes outbreaks on
45. Upon information and belief, Kebe published the 9/19/18 Video to
Plaintiff was never a prostitute or a user of cocaine. Plaintiff has never, and does
not now, have herpes, nor has she had herpes outbreaks on her mouth.
47. Upon information and belief, Kebe knew or should have known that
48. Upon information and belief, Kebe was subjectively aware of the
probable falsity of the aforementioned statements at the time she published them.
YouTube channel operated by Kebe, Kebe posted a video that acknowledges that
she was aware, prior to her publishing the 9/19/18 Video, that the defamatory
50. Upon information and belief, Kebe further acknowledged and that she
published the 9/19/18 Video a day earlier than she had planned to because
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wanted the 9/19/18 Video to have an opportunity to trend (i.e., gain viewership)
before people saw the information that would “debunk” Jones’ statements.
statements were made and published by Kebe with actual malice, i.e., with
knowledge that the statements were false or with reckless disregard for the fact that
52. On or about September 19, 2018, shortly after Kebe published the
9/19/18 Video, Plaintiff, through her counsel, sent a cease and desist letter to Kebe
53. Upon information and belief, two days after receiving the letter, which
she posted on social media rather than take the video down or issuing a retraction
and/or repudiation, Kebe published a second video that falsely proclaimed the
54. Upon information and belief, on or around September 21, 2018, Kebe
published a second video entitled “Actual PROOF Cardi B. Knew her Ex-
Roommate, Drake, Funky Dineva vs Tamar, Beyonce Black Majic,” where she
unequivocally stated that everything said in the 9/19/18 Video was true (the
“9/21/18 Video”).
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56. Upon information and belief, in the 9/21/18 Video, Kebe claims that
“Everything that we said, that everything that [Jones] said was accurate” (9/21/18
Video at 2:11); that Kebe was “the source” (9/21/18 Video at 4:38).
57. Upon information and belief, Kebe even went so far as to falsely
suggest that she was in possession of undisclosed facts that would support the prior
statements when she further claimed that “[Jones] has shown me some stuff, I said,
okay legit so I’m gonna go ahead and tell your story.” (9/21/18 Video at 8:12.)
58. Since then, Kebe has continued her campaign of defamation and
harassment.
59. Upon information and belief, on or around December 18, 2018, Kebe
Diffimation SUIT & Offset's Dad calling Cardi B. OUT & more” (the “12/18/18
Video”).
60. The 12/18/18 Video contains the false and defamatory statement that
Plaintiff “f***** herself with beer bottles on f****** stripper stages.” (12/18/18
Video at 10:10.)
61. Upon information and belief, on or around December 18, 2018, Kebe
Facebook Post”).
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Diddy & Cassie, Toni & Birdman, Tiffany Haddish, R. Kelly & More.” (the
“1/4/19 Video”).
63. The 1/4/19 Video contains the false and defamatory statement that
64. On or around January 25, 2019, Kebe Tweeted that Plaintiff had
65. Upon information and belief, the 1/25/19 Tweet was published to
66. Upon information and belief, shortly after it was posted, knowing it
was not true, Kebe deleted the post. However, as set forth below, she has failed and
refused to repudiate and take down the other instances of defamatory statements in
67. Upon information and belief, on or around March 25, 2019, Kebe
temporarily unlisted and/or took down the 9/19/18 Video and 9/21/18 Video from
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68. Upon information and belief, on or around March 26, 2019, Kebe re-
listed and/or re-posted the 9/19/18 Video and 9/21/18 Video on her YouTube
69. Upon information and belief, on or around April 23, 2019, Kebe
70. The 4/23/19 Video contains a false and defamatory statement that
Plaintiff “stuck beer bottles up her vagina, she actually took beer bottles from
pedestrians. This is on video, she took the beer bottle from the pedestrian . . . stuck
it in her cooch, drank the beer bottle and gave it back to him.” (4/23/19 Video at
22:40.)
71. Upon information and belief, on or around April 25, 2019, Kebe
published a recording of a phone call that Kebe had with another YouTube blogger
72. Upon information and belief, the Lovelyti Call was originally
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73. Upon information and belief, the Lovelyti Call was originally
recorded prior to the publication of the 9/19/18 Video and 9/21/18 Video and prior
to their re-publication.
74. Upon information and belief, the Lovelyti Call demonstrates that
Kebe was aware of the likelihood that she was circulating false information and
75. Upon information and belief, in the Lovelyti Call, Kebe states that
Jones “told some truths, she didn’t tell all truths” (Lovelyti Call at 16:04).
76. Upon information and belief, in the Lovelyti Call, Kebe states, “I still
believe [Jones] . . . now as far as the herpes and shit, I don’t know.” (Lovelyti Call
at 24:06.)
77. Upon information and belief, in the Lovelyti Call, Kebe states, “Cardi
has an entire team to protect her, if people defame her or anything, that’s Cardi’s
78. Upon information and belief, in the Lovelyti Call, Kebe states, “. . .
here’s my thing, all of these strippers are lying . . .” referring to Jones, Plaintiff and
79. Upon information and belief, on or around July 19, 2019, Kebe
published a video on YouTube entitled “Exclusives| Lala & Carmelo, Cardi &
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Offset, Megan The Stallion, Dwight Howard, Kevin Spacey & More!” (the
“7/19/19 Video”).
80. The 7/19/19 Video contains a false and defamatory statement that
REVEALED, Whitney Houston, Ti, Evelyn & O.G., Cardi B., & more!” (the
“11/8/19 Video”).
82. The 11/8/19 Video contains a false and defamatory statement that
83. Upon information and belief, on or around December 30, 2019, Kebe
84. The 12/30/19 Video contains a false and defamatory statement that
Plaintiff “was sitting on beer bottles, she was taking pedestrian’s beer bottles, they
was drinking and they could have had some cold sores and she sat on the f******
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85. Upon information and belief, on or around April 24, 2020, Kebe
“4/24/20 Video”).
86. The 4/24/20 Video contains a false and defamatory statement that
87. Upon information and belief, on or around September 18, 2020, Kebe
Divorce?, Kylie Jenner, Andrew Gillum, August Alsina, Nicki Minaj” (the
“9/18/20 Video”).
88. The 9/18/20 Video contains the following false and defamatory
statements that Plaintiff was a prostitute (1:07:50), that Plaintiff has HPV
(1:16:11), and that Plaintiff committed infidelity (1:15:37, 1:16, 1:16:29, 1:19:17,
1:19:45, 1:21:31).
89. Upon information and belief, on or around September 21, 2020, Kebe
published a video on YouTube entitled “Cardi BABY girl. I MEAN baby Bird!”
90. The 9/21/20 Video contains the false and defamatory statements that
Plaintiff was a prostitute (7:10) and that Plaintiff is engaging in adultery (7:54).
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she knew her stories about Plaintiff were false and she published them anyway.
(“You know what’s funny, I make up stories out of thin air, Tasha just makes up
stories.” (2:20); “I knew the sh** was fake.” (3:24); “I knew they was
m************ fake— I told Kyle ‘I’m going to put the bull**** out anyway.’”
(6:40); “I knew it was fake, I still made that s*** go m************ viral okay.”
(8:38); ““If you continue to send me fake stories on you, I’m going to air them as
they are hoe.” (10:50); “So keep sending me the lies, and I’m going to keep
emotional distress.
repeated by Kebe have also caused damage to Plaintiff’s reputation and character
within her profession and industry, including but not limited to among her fans and
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defamatory statements.
97. Despite written demands for repudiation and the passing of at least
seven (7) days in each instance, Kebe has as of the date of filing of this Complaint
statements.
98. As of this day, Kebe has not issued any sort of retraction or
COUNT I
(Slander Per Se Against Defendants)
100. Upon information and belief, as set forth above, Kebe published
multiple false and defamatory statements about Plaintiff, including that Plaintiff
was a prostitute, that Plaintiff was a user of cocaine, that Plaintiff had and still has
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herpes, that Plaintiff has had herpes outbreaks on her mouth, that Plaintiff had and
still has HPV, that Plaintiff engaged in a debasing act with a beer bottle, and that
true.
102. Upon information and belief, Kebe knew these statements to be false
at the time she published them, or Kebe was subjectively aware of the probable
YouTube channel operated by Kebe, Kebe posted a video that acknowledges she
was aware, prior to her publishing the 9/19/18 Video, that the defamatory
104. Upon information and belief, Kebe further acknowledged that she
published the 9/19/18 Video a day earlier than she had planned to because
wanted the 9/19/18 Video to have an opportunity to trend (i.e., gain viewership)
before people saw the information that would “debunk” Jones’ statements.
105. Nevertheless, upon information and belief, after receiving a cease and
desist letter demanding she take down the defamatory statements about Plaintiff in
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the 9/19/18 Video, Kebe published another video on September 21, 2018 that
referred to the 9/19/18 Video and the Jones Video and falsely stated that
“Everything that we said, that everything that [Jones] said was accurate” (9/21/18
Video at 2:11); that Kebe was “the source” (9/21/18 Video at 4:38).
106. Upon information and belief, Kebe did not make reasonable attempts
to verify the false and defamatory statements that were made about Plaintiff before
were published.
107. Upon information and belief, prior to publication, Kebe was aware of
the likelihood that she was circulating false information and/or she entertained
serious doubts as to the truth of the statements that were published in the
Defamatory Videos.
108. Upon information and belief, on or around March 25, 2019, Kebe
temporarily unlisted and/or took down the 9/19/18 Video and 9/21/18 Video from
109. Upon information and belief, on or around March 26, 2019, Kebe re-
listed and/or re-posted the 9/19/18 Video and 9/21/18 Video on her YouTube
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110. Upon information and belief, Kebe knew the statements made in the
Defamatory Videos were false or Kebe acted with reckless disregard of whether
occasions that she knew her stories about Plaintiff were false and she published
them anyway. (“You know what’s funny, I make up stories out of thin air, Tasha
just makes up stories.” (2:20); “I knew the sh** was fake.” (3:24); “I knew they
was m************ fake— I told Kyle ‘I’m going to put the bull**** out
anyway.’” (6:40); “I knew it was fake, I still made that s*** go m************
viral okay.” (8:38); ““If you continue to send me fake stories on you, I’m going to
air them as they are hoe.” (10:50); “So keep sending me the lies, and I’m going to
112. Upon information and belief, Kebe published these false statements
via YouTube and identified Plaintiff by her professional name, her occupation, and
showed photos of Plaintiff during the videos so that individuals who watched them
would know the statements made in the videos were about Plaintiff.
113. Upon information and belief, Kebe’s false stories were generated and
communicated with actual malice, total disregard for the truth, and in the complete
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114. Upon information and belief, Kebe had no basis for in the 9/21/18
115. Upon information and belief, the 9/2/18 Video has been viewed by
116. Upon information and belief, the 9/19/18 Video and 9/21/18 Video
117. Upon information and belief, the 9/2/18 Video, 9/19/18 Video, and
9/21/18 Video and the other Defamatory Videos are still available to be viewed by
the public.
119. Upon information and belief, Kebe’s false and defamatory statements
made and published in the Defamatory Videos were disparaging and have
distributed by Kebe have also caused damage to Plaintiff’s reputation and character
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within her profession and industry, including but not limited to among her fans and
122. Upon information and belief, the actions or omissions of Kebe set
123. Upon information and belief, such actions or omissions by Kebe were
undertaken with reckless disregard of the falsity of the speech and its effects on
Plaintiff.
punitive damages and attorneys’ fees and litigation expenses beyond and in excess
Kebe’s conduct.
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other persons acting for, with, by, through, or under authority from Defendants, or
herpes or HPV; that Plaintiff uses or has used cocaine; that Plaintiff engaged in a
debasing act with a beer bottle; that Plaintiff committed infidelity; and/or that
remove, and repudiate in full all defamatory and disparaging statements made
regarding Plaintiff.
COUNT II
(Slander Against Defendants)
130. Upon information and belief, Kebe’s false and defamatory statements
made during the Defamatory Videos were disparaging, and have produced damage
131. Upon information and belief, Kebe was subjectively aware of the
probable falsity of the statements made during the above-referenced videos at the
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132. Upon information and belief, the actions or omissions of Kebe set
133. Upon information and belief, such actions or omissions by Kebe were
undertaken with reckless disregard of the falsity of the speech and its effects on
Plaintiff.
occasions that she knew her stories about Plaintiff were false and she published
them anyway. (“You know what’s funny, I make up stories out of thin air, Tasha
just makes up stories.” (2:20); “I knew the sh** was fake.” (3:24); “I knew they
was m************ fake— I told Kyle ‘I’m going to put the bull**** out
anyway.’” (6:40); “I knew it was fake, I still made that s*** go m************
viral okay.” (8:38); ““If you continue to send me fake stories on you, I’m going to
air them as they are hoe.” (10:50); “So keep sending me the lies, and I’m going to
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distributed by Kebe have also caused damage to Plaintiff’s reputation and character
within her profession and industry, including but not limited to among her fans and
punitive damages and attorneys’ fees and litigation expenses beyond and in excess
Kebe’s conduct.
other persons acting for, with, by, through, or under authority from Defendants, or
herpes or HPV; that Plaintiff uses or has used cocaine; that Plaintiff engaged in a
debasing act with a beer bottle; that Plaintiff committed infidelity; and/or that
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remove, and repudiate in full all defamatory and disparaging statements made
regarding Plaintiff.
COUNT III
(Libel Per Se Against Defendants)
142. Upon information and belief, Kebe published the 12/18/18 Facebook
143. Upon information and belief, Kebe published this false statement via
144. Upon information and belief, Kebe published the 1/25/19 Tweet on or
145. Upon information and belief, Kebe published this false statement via
Twitter.
146. As set forth above, the statements made in the 12/18/18 Facebook
Post and the 1/25/19 Tweet that Plaintiff has herpes is false, defamatory, and
libelous.
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147. Upon information and belief, Kebe knew these statements to be false
at the time she published them or acted with reckless disregard of whether they
148. Upon information and belief, Kebe was subjectively aware of the
probable falsity of the aforementioned statements at the time she published them.
149. Upon information and belief, Kebe’s false stories were generated and
communicated with actual malice, total disregard for the truth, and in the complete
150. Upon information and belief, Kebe had no basis for claiming the
151. Upon information and belief, the 12/18/18 Facebook Post was
152. Upon information and belief, the 1/25/19 Tweet was published to
154. Upon information and belief, Kebe’s false and defamatory statements
made in the 12/18/18 Facebook Post and the 1/25/19 Tweet were disparaging and
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reputation.
also caused damage to Plaintiff’s reputation and character within her profession
and industry, including but not limited to among her fans and with prospective
business relations.
157. Upon information and belief, the actions or omissions of Kebe set
158. Upon information and belief, such actions or omissions by Kebe were
undertaken with reckless disregard of the falsity of the speech and its effects on
Plaintiff.
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punitive damages and attorneys’ fees and litigation expenses beyond and in excess
Kebe’s conduct.
other persons acting for, with, by, through, or under authority from Defendants, or
herpes or HPV; that Plaintiff uses or has used cocaine; that Plaintiff engaged in a
debasing act with a beer bottle; that Plaintiff committed infidelity; and/or that
remove, and repudiate in full all defamatory and disparaging statements made
regarding Plaintiff.
COUNT IV
(Invasion of Privacy – False Light Against Defendants)
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164. Upon information and belief, by publishing the false statements in the
manner described above, Kebe portrayed Plaintiff in a false light intending to cause
Plaintiff injury.
165. Upon information and belief, Kebe knew these statements to be false.
166. Upon information and belief, Kebe made no attempt to verify the
167. Upon information and belief, Kebe knew the statements made in the
9/2/18 Video, 9/19/18 Video, 9/21/18 Video, and the other Defamatory Videos,
probable falsity of the statements made in the 9/2/18 Video, 9/19/18 Video,
9/21/18 Video, and the other Defamatory Videos, and the 1/25/19 Tweet, at the
169. Upon information and belief, Kebe’s false statements were generated
and communicated with actual malice, total disregard for the truth, and in the
occasions that she knew her stories about Plaintiff were false and she published
them anyway. (“You know what’s funny, I make up stories out of thin air, Tasha
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just makes up stories.” (2:20); “I knew the sh** was fake.” (3:24); “I knew they
was m************ fake— I told Kyle ‘I’m going to put the bull**** out
anyway.’” (6:40); “I knew it was fake, I still made that s*** go m************
viral okay.” (8:38); ““If you continue to send me fake stories on you, I’m going to
air them as they are hoe.” (10:50); “So keep sending me the lies, and I’m going to
171. Upon information and belief, as set forth above Kebe has intentionally
intruded upon the solitude and/or seclusion of Plaintiff and her private affairs
and/or concerns, and this intrusion, which falsely portrays Plaintiff in a manner
prostitute, that Plaintiff was a user of cocaine, that Plaintiff had and still has
herpes, that Plaintiff has had herpes outbreaks on her mouth, that Plaintiff had and
still has HPV, that Plaintiff engaged in a debasing act with a beer bottle, and that
172. Upon information and belief, Kebe knew or should have known the
statements alleged herein would create a false impression about Plaintiff and acted
173. Upon information and belief, Kebe did not engage in any of the
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governed by reasonable and ministerial conduct according to any job duty, but did
effects that their actions would have on Plaintiff, and with willful and deliberate
174. Upon information and belief, the actions or omissions of Kebe set
forth in this Complaint demonstrate malice, egregious defamation, and insult. Such
punitive damages and attorneys’ fees and litigation expenses beyond and in excess
Kebe’s conduct.
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other persons acting for, with, by, through, or under authority from Defendants, or
herpes or HPV; that Plaintiff uses or has used cocaine; that Plaintiff engaged in a
debasing act with a beer bottle; that Plaintiff committed infidelity; and/or that
remove, and repudiate in full all defamatory and disparaging statements made
regarding Plaintiff.
COUNT V
(Intentional Infliction of Emotional Distress)
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181. Upon information and belief, Kebe’s conduct was intentional, as Kebe
knew these statements were false and made no attempt to verify the truth of any
182. Upon information and belief, Kebe knew the statements made in the
9/2/18 Video, 9/19/18 Video, 9/21/18 Video, and the other Defamatory Videos,
and the 1/25/19 Tweet, were extreme and outrageous and would cause Plaintiff
emotional distress.
occasions that she knew her stories about Plaintiff were false and she published
them anyway. (“You know what’s funny, I make up stories out of thin air, Tasha
just makes up stories.” (2:20); “I knew the sh** was fake.” (3:24); “I knew they
was m************ fake— I told Kyle ‘I’m going to put the bull**** out
anyway.’” (6:40); “I knew it was fake, I still made that s*** go m************
viral okay.” (8:38); ““If you continue to send me fake stories on you, I’m going to
air them as they are hoe.” (10:50); “So keep sending me the lies, and I’m going to
184. Upon information and belief, Kebe has published over thirty videos in
her campaign against the Plaintiff, including the Defamatory Videos, which were
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Plaintiff.
185. Upon information and belief, Kebe’s conduct was extreme and
outrageous as Kebe purposely published statements that she knew would cause
severe emotional distress, including but not limited to stating that Plaintiff’s then-
unborn child would have mental deficiencies, that Plaintiff was a prostitute, that
Plaintiff was a user of cocaine, that Plaintiff had and still has herpes, that Plaintiff
has had herpes outbreaks on her mouth, that Plaintiff had and still has HPV, that
Plaintiff engaged in a debasing act with a beer bottle, and that Plaintiff committed
infidelity.
186. Upon information and belief, Kebe’s conduct was intentional as Kebe
187. Upon information and belief, since Kebe began her campaign against
188. Upon information and belief, Kebe conduct was intentional as Kebe
intended to increase what she could charge from advertisers, and, as a result of her
campaign of outrageous and harassing conduct against the Plaintiff, has now been
able to do so.
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emotional distress.
punitive damages and attorneys’ fees and litigation expenses beyond and in excess
Kebe’s conduct.
other persons acting for, with, by, through, or under authority from Defendants, or
herpes or HPV; that Plaintiff uses or has used cocaine; that Plaintiff engaged in a
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debasing act with a beer bottle; that Plaintiff committed infidelity; and/or that
remove, and repudiate in full all defamatory and disparaging statements made
regarding Plaintiff.
COUNT VI
(Punitive Damages Pursuant to O.C.G.A. § 51-12-5.1)
actions.
occasions that she knew her stories about Plaintiff were false and she published
them anyway. (“You know what’s funny, I make up stories out of thin air, Tasha
just makes up stories.” (2:20); “I knew the sh** was fake.” (3:24); “I knew they
was m************ fake— I told Kyle ‘I’m going to put the bull**** out
anyway.’” (6:40); “I knew it was fake, I still made that s*** go m************
viral okay.” (8:38); ““If you continue to send me fake stories on you, I’m going to
air them as they are hoe.” (10:50); “So keep sending me the lies, and I’m going to
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197. Upon information and belief, Kebe acted with a specific intent to
$250,000.
COUNT VII
(Attorneys’ Fees and Litigation Expenses Pursuant to O.C.G.A. § 13-6-11)
200. Kebe has acted in bad faith by publishing defamatory statements she
knew to be false and would cause harm to Plaintiff and has been stubbornly
litigious and has caused Plaintiff unnecessary trouble and expense by refusing to
201. Plaintiff seeks her attorneys’ fees and expenses of litigation against
in her favor and against Defendants, each of them jointly and severally, as follows:
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determined at trial, but not less than $75,000, including general, special,
agents, representatives, successors, assigns and employees, and any and all persons
shareholders, managers, representatives, consultants, and any and all other persons,
behalf of any of the foregoing, and each of them, from: making, disseminating,
broadcasting, or publishing any statements that Plaintiff has or had herpes or HPV;
that Plaintiff uses or has used cocaine; that Plaintiff engaged in a debasing act with
a beer bottle; that Plaintiff committed infidelity; and/or that Plaintiff was or is a
prostitute;
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Plaintiff;
(g) Granting Plaintiff such other and further relief as the Court deems just
and proper.
Plaintiff hereby demands a trial by jury on all claims for relief and issues
triable by jury.
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CERTIFICATE OF SERVICE
TRIAL with the Clerk of the Court using the CM/ECF system, which will
automatically send email notification of such filing to all of the attorneys of record.
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