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VIRGINIA: a Fg IN THE CIRCUIT COURT FOR THE COUNTY oF STAFFORD Ra oo w BRYCE E, REEVES ge ‘3 ae Plaintiff ; = 3 Ee v ‘Case Number_CL(p LOX MARTHA MCDANIEL No Service of Process COMPLAINT COMES NOW the Plaintiff, Bryce B, Reevée (hereinafter the “Plaintif?’), by counsel, and for his complaint against Martha McDaniel (hereinafter “Defendant”, states as follows: 1, The Plaintif?is a resideit of Virginia *eving is professional place of busines located in Stafford County, Virginia, 2 tec te tom inn ait 3. 030 September 2015 the Defendant sent an email to Travis Witt which is attached hereto at Exhibit 1. 4, The email from the Defendant states in part that ~ Reeves is carrying ori an open and obvious adulterous relationship with his campign state nd constant ompanion.” Or words to that effect, 3. ‘The Sateen contained in Eeibit | made by te Defendant fe 6. ‘The Saement was published by the Defendant third pry, 1. ‘essen cones dination persia hy nutes sto, impute moral turpitude to the Plaintiff, ascribe immoral and or illegal activity to the Plaintiff, and injures the reputation and character of the Plaintiff in the. community, 8. The statement made by the Defendant was done maliciously when the Plaintiff knew the statement to be false, 9. The Defendant intended ‘o harm the Plaintiff by making the false statement, 10. The Defendant's action of publishing the defamatory statement ‘was done for the sole Purpose of harming the Plaintiff WHEREFORE the Plaintiff seks damages under defamation per se in the amount of $500,000.00, interest at’ the judgment rate until paid, reasonable attomey’s fees, cost ‘of court, RE LY SUBMITTED Pelt Jazon M, Pelt GOODALL, PELT, & CARPER, P.c, 1259 Courthouse Rd., Suite 101 Stafford, VA 22554-0177 (540) 659:3130- Fax :(540)659-0291 ‘VSB#72585 Fant Friday, September 30, 2016 at 12:49 pM From: "Martha MeDantel* “ Tor Subject: No Subject Pastor barring to you today concerning your public deep ote candidacy of Sen, Bryce Reeves to be People ereutenant governor, As a Christian, 1 om Gceply troubled by Sen, Reeves parsons conduct, People around the commonwealth hove Jonny ahs oe DOU the fact that Sen, Reena tying comporion, ne,cbWoUS adulterous relationship wet ne campaign staffer and constant Sompanion. This has now risen beyon: ‘and I can not abide ntradiction of those ‘a leader and as lor