Plaintiff in such derogatory terms as being a “disgrace” and telling
Plaintiff that he in profanity that Plaintiff should have sex with himself.Defendant then continued to use profanity to claim that Plaintiff was a liarand a sack of defecation.16.
On October 29, 2011, Defendant sent Plaintiff an e-mail in whichDefendant made a series of extremely derogatory, inflammatory, anddistressing comments about Plaintiff. As part of that e-
mail entitled “MYREGRET,” Defendant referred to Plaintiff as a “pitiful pieve (sic) of sh**t.” Additionally, Defendant claimed that Plaintiff was a “lonely,nasty, grumpy excuse for a human and a waste of skin.”
On October 30, 2011, Defendant sent Plaintiff an e-mail in which
Defendant referred to the Plaintiff as a “spineless piece of sh**t(expletive)” in the subject line, along with a comment inquiring of Plaintiff “(j)ust checking to see if you got my message.”
dant continued on to again contend that Plaintiff was a “sorry pieceof sh**t.”
Then, Defendant went on to claim that Plaintiff was a “bitter,selfish, evil person to the core.”
Defendant further struck an even more sore spot for Plaintiff by claiming
hat is why your brother (with whom Plaintiff had an incredibly strong
bond) hating you.” Defendant knew that such comments would be
incredibly devastating to Plaintiff, as Defendant had known that Plaintiff had mourned the death of his twin brother for the previous decade and hadeven written a book and published the book regarding the specialconnection between Plaintiff and his twin brother, Barry.20.
In the same e-
mail, Defendant claimed that Plaintiff was simply “made of sh**t,”“ sh**t to the core,” and a “dirt bag.”
In conclusion, Defendantspecifically threatened that if Defendant ever saw Plaintiff again that
Plaintiff “would not like the results,” which Plaintiff understandably and
reasonably took as being a threat that Defendant would physically assaultPlaintiff.21.
Throughout Defendant’s conduct towards Plaintiff, Defendant specifically
intended to cause emotional distress to Plaintiff. Defendant
conduct was intentional and malicious and done for the purpose of causingPlaintiff to suffer humiliation, mental anguish, and emotional and physicaldistress.22.
As a proximate result of Defendant's extreme and outrageous conductdirected towards Plaintiff, Plaintiff has suffered severe humiliation, mentalanguish, and emotional and physical distress, and has been
mind and body to such an extent that Plaintiff’s depression has worsened