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IN THE CIRCUIT COURT OF TENNESSEE FOR THE
THIRTIETH JUDICIAL DISTRICT AT MEMPHIS
GEORGE L. GREER,
Plaintiff,
vs.
No.
EVELYN THOMAS,
Defendant.
COMPLAINT FOR MONEY DAMAGES FOR LIBEL,
SLANDER, AND CONVERSION OF PROPERTY
COMES NOW your plaintiff, George L. Greer, through his
undersigned counsel of record, and for cause of action would
show unto the Court as follows:
PARTIES
.
Your plaintiff, George L. Greer, is a resident citizen
of Memphis, Shelby County, Tennessee.
.
Your defendant, Evelyn Thomas, is a resident citizen
of Shelby County, Tennessee, currently residing at 3373
Charlotte, Memphis, Tennessee 38109.
JURISDICTION AND VENUE
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.
All acts complained of in this complaint were
committed in Shelby County, Tennessee.
.
This Court has subject matter jurisdiction pursuant to
T.C.A. '16-10-106; and venue is proper pursuant to T.C.A. '20-4-
107.
FACTS
.
Defendant resided in the same residence as did
plaintiff at 1497 Fields Road, until September 28, 1993.
.
On September 28, 1993, plaintiff was moving out of the
residence at 1497 Fields Road.
.
While he was moving out, defendant's boyfriend, Nick
Jefferies, accused plaintiff of packing a telephone that
Jefferies asserted belonged to Jefferies.
.
Jefferies then produced a pistol, and pointed it at
plaintiff. To defend himself, plaintiff grabbed at the pistol,
and in the struggle, Jefferies shot himself.
.
On or about September 18, 1993, defendant published in
writing to the Memphis Police Department a statement asserting
that George Greer produced a pistol and killed Jefferies with
the pistol.
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.
Defendant knew that this aforesaid statement was
false, and defamatory. Furthermore, the aforesaid statement was
published to Sgt. Fields of the Memphis Police Department.
.
On or about September 28, 1993, and continuing until
the present time, defendant has orally published false
statements, asserting that George Greer produced a pistol and
killed Jefferies with the pistol.
.
Defendant knew that the aforesaid statements were
false and defamatory. Furthermore, the aforesaid statements
were published to third persons.
.
Because of these statements, plaintiff was wrongfully
arrested and charged with murder.
.
Furthermore, on or about September 28, 1993, defendant
took all of plaintiff's property from the residence at 1497
Fields Road, without plaintiff's consent, and has refused to
tell plaintiff where said property is, or allow plaintiff access
to his property.
COUNT I.
LIBEL
.
Defendant has intentionally published false, written
statements, which are defamatory in nature and known to be false
at the time they were published, causing plaintiff damage,
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including, but not limited to, being incarcerated in the Shelby
County Jail and charged with a crime he did not commit.
As a direct and proximate cause of the aforementioned
libelous statements, plaintiff has suffered damages including,
but not limited to, loss of liberty, loss of income, and
emotional distress.
COUNT II.
SLANDER
.
Defendant has intentionally published false oral
statements, known to be false by defendant at the time they were
published, which are defamatory in nature, causing plaintiff
damage, including, but not limited to being incarcerated in the
Shelby County Jail and being charged with a crime he did not
commit.
As a direct and proximate cause of the aforementioned
slanderous statements, plaintiff has suffered damages including,
but not limited to, loss of liberty, loss of income, and
emotional distress.
COUNT III.
CONVERSION
.
Defendant has intentionally interfered with
plaintiff's enjoyment of all his property which was located at
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1497 Fields Road by removing same, and concealing its
whereabouts without plaintiffs' consent.
As a direct and proximate cause of the aforementioned
conversion of plaintiff's property, plaintiff has lost the full
value and enjoyment of all property plaintiff owns.
WHEREFORE, PREMISES CONSIDERED, YOUR PLAINTIFF PRAYS FOR:
1.
Damages to be awarded in the amount of Two Hundred
Thousand Dollars ($200,000.00).
2.
For such other and further relief as this Court deems
necessary.
Respectfully submitted,
GLANKLER BROWN
1700 One Commerce Square
Memphis, Tennessee 38103
901/525-1322
By:
Robert L. Hutton (#15496)