VIRGINIA: IN THE FAIRFAX COUNTY CIRCUIT COURT

Campbell v. Gannett

1 HEIDI CAMPBELL, )
2 TALITHA RENEE WILLIAMS, )
3 and JASON MONROE )
4 )
5 Plaintiffs, )
6 )
7 )
8 v. ) Case No.
9 )
10 )
11 )
12 GANNETT CO., INC. )
13 )
14 Defendants. )
15 ___________________________________ )
16
17

18

19 COMPLAINT

20 INTRODUCTION

21 1) Allegations of child sexual abuse by an elected Sheriff and some deputies,

22 drug trafficking, planting of evidence on suspects, destruction of rape kits to protect

23 friends, the Sheriff lying to federal agents, and a Newspaper incomprehensibly

24 determined to protect law enforcement over the citizens of the community are the

25 foundation of this complaint. The Defendant, operating a local newspaper with its

26 primary readership in Augusta County, Virginia, permitted its editors to lie to sources,

27 manipulate evidence, and participate in police harassment of its own reporters in order to

28 protect corrupt local law enforcement from exposure of their criminal activity.

29 2) Plaintiff Heidi Campbell was raped on May 22, 2007, by an employee at a

30 healthcare facility where she was a patient, currently operating as Augusta Medical

31 Center. The Hospital administration covered up the crime committed by their employee.
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Campbell v. Gannett

32 Campbell submitted to rape kit testing and the rape kit was destroyed by Sheriff Donald

33 Smith (then a deputy, now the elected Sheriff). Records show that Donald Smith was the

34 person who was tasked with collecting the evidence of the rape, and preserving it.

35 Records show the kit was destroyed but are silent as to why it was destroyed and why the

36 evidence was not preserved. Campbell has seen no justice for the crimes committed

37 against her and had lost hope that her rapist might ever be held accountable.

38 3) The absence of the rape kit made it difficult to obtain a formal accusation

39 against the predator who raped Campbell. Records are silent as to whether the Perk Test

40 Kit was ever tested, nor do the records show results of testing of buccal swabs from

41 Campbell’s rapist and her husband. Campbell has used her voice for over a decade to call

42 attention to health care sexual assaults, and the corruption in local law enforcement that

43 often covers up such crimes.

44 4) Plaintiff Talitha Williams is a victim of human trafficking at the hands of

45 Augusta County Sheriff Donald Smith and his narcotics deputies. Williams was raped by

46 a Police officer and others while under the control of the Sheriff’s Office. Williams’ rape

47 kit was tossed in the trash by a deputy Sheriff. Williams was forced to buy and give away

48 drugs to entice new drug users, all at the direction of law enforcement. Williams was

49 forced to engage in immoral acts to help Smith and his deputies affect drug deals.

50 Williams was also given drugs by Smith’s deputies with instructions to plant them on

51 known enemies of the Sheriff.

52 5) Plaintiff Jason Monroe is the victim of a complex series of mortgage

53 frauds, committed by a Captain at the Augusta County Sheriff’s Office and covered up by

54 Sheriff Donald Smith. Monroe’s signatures were forged on loan documents with a local
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Campbell v. Gannett

55 bank (Frontier Bank) and the amount of the fraud totaled over $400,000. Monroe was

56 warned that “you have no idea the clout this man has”, referring to the Sheriff’s Office

57 Captain at the center of the fraud, and that he needed to drop his complaints by Augusta

58 County Sheriff Donald Smith.

59 6) Plaintiff Monroe has refused to be silenced about the fraud, and has been

60 subjected to a campaign of intimidation and harassment at the hands of the Sheriff,

61 including an instance at a local fairgrounds where the Sheriff attempted to have him

62 arrested after he asked a question about the fraud.

63 7) The constitutional guarantee of a free press "assures the maintenance of

64 our political system and an open society," Time, Inc. v. Hill, 385 U.S. 374, 389 (1967),

65 and secures "the paramount public interest in a free flow of information to the people

66 concerning public officials," Garrison v. Louisiana, 379 U.S. 64, 77 (1964). Defendant

67 has abdicated its responsibility to report on matters of local corruption through their

68 production of The Staunton Newsleader in Staunton, VA.

69 8) The Staunton Newsleader (“Newsleader”) is a daily newspaper located in

70 Staunton, VA and owned by Gannett Co., Inc. In 2021 Defendant hired a “social justice

71 watchdog” reporter named Ayano Nagaishi.

72 9) On June 11, 2021, Plaintiff Campbell first spoke with Reporter Nagaishi,

73 who claimed to be investigating multiple reports of crimes committed by the Augusta

74 County Sheriff, Donald Smith, the former Sheriff, and others within the Department.

75 Plaintiff Campbell agreed to work with Reporter Nagaishi to expose the corruption in the

76 Augusta County Sheriff’s Office for a story she was planning to publish.
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Campbell v. Gannett

77 10) Plaintiffs provided Reporter Nagaishi with sensitive documents

78 concerning their cases, including notes and evidence of communications with Federal

79 investigators. The information shared by Plaintiffs was shared potentially at their

80 detriment and was only shared after Reporter Nagaishi made two commitments to them.

81 One, Reporter Nagaishi had promised them that their information would be treated as

82 confidential until publishing, at which time the Plaintiffs would agree as to what

83 documents if any were published. Second, Reporter Nagaishi had promised that she had

84 enough evidence and would be publishing their stories. While Reporter Nagaishi returned

85 Plaintiffs’ original documents, copies were made and they remain unaccounted for.

86 11) Plaintiffs never would have entered into an agreement with Reporter

87 Nagaishi had she not made both aforementioned commitments.

88 12) On August 22, 2021, Plaintiff Campbell learned that Reporter Nagaishi

89 had left her employment at The Newsleader. Campbell was finally able to reach

90 Nagaishi, who detailed a campaign of terror at the hands of the Augusta County Sheriff’s

91 Office and her supervisors at The Newsleader. Nagaishi told Campbell that the editors

92 killed all of the stories critical of the Sheriff in order to protect their “relationship with

93 law enforcement.”

94 13) Nagaishi believed that the problem was her editor, William Ramsey, and

95 crime reporter Brad Zinn, who Nagaishi speculated may be receiving bribes from the

96 Sheriff.

97 14) Plaintiffs further learned that the newspaper had interfered with or covered

98 up many issues related to corruption in the Sheriff’s office in Augusta County, Virginia,

99 including:
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Campbell v. Gannett

100 i) Augusta County Sheriff Donald Smith and at least two of his deputies are

101 alleged to have engaged in the sexual abuse of three minor boys, one of whom

102 was the son of another County executive.

103 ii) Augusta County Sheriff Donald Smith routinely uses racial epithets to

104 describe suspects of crime and even former President Obama.

105 iii) Augusta County Sheriff Donald Smith lied to federal agents during an

106 investigation related to his “close friend” and convicted human trafficker Felix

107 Chujoy. (See Exhibit 1: Affidavit of DHS Agent)

108 iv) Augusta County Sheriff Donald Smith committed perjury during grand jury

109 testimony in the case of United States v. Chujoy. 207 F. Supp. 3d 626, 207 F.

110 Supp. 3d 660 (W.D. Va. 2016).

111 v) Augusta County Sheriff Donald Smith loaned his car and his personal cell

112 phone to his “close friend” after he had been arrested for sexual solicitation of

113 a minor child and human trafficking. (See Exhibit 1: Affidavit of DHS Agent)

114 Chujoy then used the Sheriff’s phone in the commission of a federal felony,

115 an offense for which he was charged and convicted in the United States

116 District Court for the Western District of Virginia.

117 vi) Augusta County Sheriff Donald Smith and unidentified police officers

118 engaged in a concerted campaign to harass and intimidate Newsleader reporter

119 Ayano Nagaishi, which the editor and newspaper leadership covered up.

120 15) Plaintiffs cooperated with Reporter Nagaishi based upon her

121 representations that Defendant Gannett would do certain things, namely keep certain

122 documents confidential and at least include their allegations on a larger story upon which
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Campbell v. Gannett

123 Reporter Nagaishi was working. In fact, Reporter Nagaishi indicated that Plaintiff

124 Campbell’s story would be its own in a collection of several reports. The Plaintiffs would

125 never have entered into a contract with Gannett, through its reporter Nagaishi, had they

126 known that the “newspaper” was actually serving as a public relations agency for the very

127 racist, abusive Sheriff accused of heinous crimes against them.

128 16) Plaintiffs expected and contracted for providing information and

129 documents to a local news reporter and source that provided “investigative reporting that

130 makes our community a better place to work, live and play.” Engaging in a cover up of

131 sex assaults, racist police violence, and attacks on their own reporters demonstrate that

132 these words are more than hollow – they are actually false and represent one of a myriad

133 of marketing statements from Defendant that create: "(1) a false representation, (2) of a

134 material fact, (3) made intentionally and knowingly, (4) with intent to mislead" that

135 results in "(5) reliance by the party misled, and (6) resulting damage to the party misled."

136 Evaluation Research Corp. v. Alequin, 247 Va. 143, 148, 439 S.E.2d 387, 10 Va. Law

137 Rep. 779 (1994). Such are the elements of fraudulent inducement to contract, and

138 Plaintiffs are entitled to recover damages suffered from Defendants fraud. Further, the

139 Defendant is also liable for breach of contract due to this misrepresentation, and for

140 negligence due to their failure to report the allegations.

141 17) Plaintiffs seek a Declaratory judgment that Defendant’s actions constitute

142 advocacy and not news, and that when Defendant engages in such behavior that the Court

143 order Defendant to disclaim “reports” that are actually opinion or marketing pieces.

144 Further, the Plaintiff also seeks applicable monetary damages stemming from the failure

145 to report on the multiple allegations against the sheriff.

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Campbell v. Gannett

146 FACTS

147 A Fraud induced

148 18) Defendant’s news website heavily encourages readers to subscribe to

149 content. Much of the content available is behind a paywall, and the Defendant encourages

150 visitors to subscribe in multiple places throughout the website.

151 19) Defendant’s marketing materials describe their Staunton newspaper “as a

152 community news and information company for Staunton, Waynesboro and Augusta

153 County, Virginia.”

154 20) Defendant’s website further claims that “The company is a subsidiary of

155 Gannett Co., Inc., of McLean, Va. (NYSE: GCI), an international media and marketing

156 solutions company that informs and engages more than 100 million people every month

157 through its network of broadcast, digital, mobile, and publishing properties.”

158 21) Defendant promises “Investigative reporting that makes our community a

159 better place to work, live and play” when it teases readers with stories and then requires a

160 subscription to read the story.

161 22) Defendant promises “Mobile apps including immersive storytelling” when

162 it teases readers with stories and then requires a subscription to read the story.

163 23) Nowhere does Defendant state that their local news coverage included

164 sponsored content designed to protect the Augusta County Sheriff from investigation or

165 scrutiny.

166 24) Nowhere does Defendant state that their local news coverage is inhibited

167 by the Defendant’s desire to preserve “relationships with law enforcement.”

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Campbell v. Gannett

168 25) Defendant’s statements, coupled with explosive headlines that infer

169 legitimate news reporting, fraudulently induced Plaintiffs to believe that they could trust

170 Reporter Nagaishi’s commitments, made on behalf of Defendant Gannett, to both keep

171 their sensitive documents confidential and to accurately report on the stories of

172 corruption.

173 26) Defendant’s efforts to cover up corruption allegations against the Sheriff

174 from their own employees are entirely inconsistent with the stated mission and assurances

175 offered by Defendant on their public facing webpages.

176 27) Defendant’s coverage of local news, related to the Augusta County

177 Sheriff’s Office, is promotional in nature. In fact, the editors of the Newsleader operate as

178 a sort of “crisis management” public relations firm for the Sheriff.

179 28) When Defendant hired a reporter who authored stories critical of the

180 Sheriff, the Defendant participated in a campaign by the Sheriff to harass, intimidate, and

181 frighten the reporter into leaving her job and ceasing her reporting.

182 29) Defendant employed reporter Ayano Nagaishi as a “social justice

183 watchdog” reporter, a description listed on Defendant’s website.

184 30) Reporter Nagaishi began investigating several stories about the Augusta

185 County Sheriff, including allegations of racism, racist violence, lying under oath, human

186 trafficking, and child sexual assault.

187 31) Reporter Nagaishi spoke with several victims of the Augusta County

188 Sherrif’s Office harmful conduct. One such victim, Plaintiff Campbell, was raped at

189 Augusta Medical Center and Sheriff Donald Smith (a patrol officer at the time) was

190 responsible for destroying her rape kit and covering up the crime.
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Campbell v. Gannett

191 32) Reporter Nagaishi induced Plaintiffs, as an agent of Defendant Gannett, to

192 enter an agreement with Defendant to provide certain sensitive documents and their

193 stories by promising the safekeeping of those documents and a commitment that the story

194 would publish

195 33) Plaintiffs were further induced to enter the agreement with Defendant

196 Gannett by representations made on the Staunton Newsleader website, and in its web-

197 based marketing materials, of its mission focused commitment to engage in investigative

198 reporting.

199 34) Defendant Gannett failed to mention that its editors would use the results

200 of that investigative reporting to protect racist and violent local law enforcement from

201 public exposure.

202 35) Reporter Nagaishi was forced to leave her job as a result of harassment

203 and intimidation by the Augusta County Sheriff. After leaving her position Nagaishi

204 called Mrs. Campbell and spoke at length about her departure. Campbell recorded the

205 conversation, and a copy of the recording was sent to the Plaintiff. The Nagaishi

206 recordings are attached to this complaint as Exhibits 2-8.

207 The Nagaishi Recordings

208 36) Speaking to Plaintiff Campbell after her departure from The Newsleader,

209 Nagaishi noted that she received no support from the Defendant in doing her job. “The

210 whole company did not support me.”

211 37) Speaking about stories she was writing critical of the Sheriff; Nagaishi

212 stated: “My editor was trying to destroy the story in any possible way.”
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Campbell v. Gannett

213 38) Nagaishi said the Defendant’s editors told her that “Maintaining

214 relationships [with police] is important.”

215 39) When discussing stories potentially negative that were about the Sheriff,

216 the Defendant’s reporter was told that it was “not something we report on.”

217 40) When addressing her departure from Gannett, Nagaishi claimed that “The

218 Newsleader obviously is corrupt. I’m ashamed to have worked there.”

219 41) Nagaishi also noted specific articles involving police misconduct that

220 editors of the Defendant disliked. Specifically, she claimed of her editors: "they didn't

221 like the article I wrote about body cameras".

222 42) Nagaishi claimed that another reporter, Brad Zinn, responsible for

223 covering police and the Courts for the Defendant at the Staunton Newsleader, was

224 enraged about her body camera story. "When I published that, like not a big deal body

225 camera story, Brad Zinn was mad as hell at me. I mean he was like you’re going to like,

226 you know, basically abuse my relationship with law enforcement."

227 43) Regarding Reporter Brad Zinn, Nagaishi stated: "the former secretary

228 from Augusta County Sheriff’s Office, you know, she told me that Brad and Donald

229 Smith, they have a tight relationship. and I don’t know what that means. Bribes? What

230 does that mean?”

231 44) Nagaishi then stated concerns about surveillance, stating that she “started

232 getting followed and I found out my work phone was being tapped" after writing the

233 story about body cameras.

234 45) Nagaishi was afraid of the police actions. "I was like scared. I went to my

235 editor, and I was like this is what’s happening and you know I need some support. I mean
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Campbell v. Gannett

236 I felt, and you know, he said I’m overthinking and he's like do you think that the Augusta

237 County Sheriff’s office is smart enough to do that. and I flat out said you don't have to be

238 smart to be powerful."

239 46) After stating her concerns, Nagaishi was told: "We don't believe you.

240 Don't make this shit up."

241 47) After coming to Defendant’s management for help, Nagaishi claims:

242 "They would check in every single 15 minutes on what story I am working on and stuff."

243 48) Nagaishi states that "The Newsleader wasn't supportive at all for me, and

244 they just didn't believe what I went through, I guess." She continues… “The whole

245 company did not support me.”

246 49) It wasn’t just the Defendant who turned on Reporter Nagaishi. She claims

247 “at the same time in August the police started showing up at like my apartment.”

248 50) Nagaishi’s apartment was searched without evidence in an effort to

249 intimidate her. She claims the police told her “they were like there’s a noise complaint.

250 There has to be a man in your house.” Upon information and belief no actual call for a

251 noise complaint exists, and that officers with the Augusta County Sheriffs Office, and not

252 the Staunton Police Department, engaged in the search of Nagaishi’s apartment. Nagaishi

253 lived in the independent City of Staunton.

254 51) Nagaishi continues: “they came into my house, I had nothing to hide, but

255 they came in and they opened every single closet. and drawers. I was scared they planted

256 something. I like recorded everything and went to my editor. He said that might just

257 happen because of where you live. I really lost it.”

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Campbell v. Gannett

258 52) After being told by their reporter that her phone was tapped, that police

259 were following her, and that her house was searched without a warrant, her editor implied

260 she should live in a better part of town.

261 53) Nagaishi claimed her editors were aware of the fact that she had spoken to

262 three separate victims; three young men who claimed they were sexually assaulted by

263 Sheriff Donald Smith and a few of his deputies when they were minors. "The sexual

264 assault, the underage one, that was like its own separate story. it happened... I’m sure it’s

265 happening to this day. all three of them said they weren't comfortable, and obviously my

266 editor was trying to push me..."

267 54) Regarding the victims, Nagaishi claimed “they aren’t a minor now. this

268 happened when they were a minor, but now they are above. all three of them, they live

269 out of state.”

270 55) Nagaishi claims the victims were afraid. This is why newspapers across

271 the country (including newspapers operated by the Defendant) have policies around not

272 identifying victims of sexual assault by name. It appears this policy does not apply when

273 the offender is alleged to be the Augusta County Sheriff.

274 56) Thus, it is necessary in this case to ensure that Defendant properly and

275 legally sells its services in the future. Defendant should not be precluded from operating a

276 local news publication in Augusta County, they simply should not be able to call their

277 law enforcement marketing operation a news publication and should be held liable for

278 their failure to accurately report news related to the Augusta County Sheriff’s office. The

279 Defendant should be required to disclaim any article where the Defendant is actually
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Campbell v. Gannett

280 providing marketing services for the subject of the story and when the story itself is a

281 marketing piece and not a legitimate news story.

282 THE PARTIES, JURISDICTION, AND VENUE

283 57) Plaintiffs reincorporate by reference the facts alleged in paragraphs

284 through 44, above.

285 58) Plaintiff Heidi Campbell is a resident of Augusta County, Virginia.

286 Plaintiff Campbell was raped at a facility managed by Augusta Medical Center, a crime

287 which was covered up by Augusta County Sheriff Donald Smith when he destroyed her

288 rape kit.

289 59) Plaintiff Talitha Williams is a resident of Augusta County, Virginia.

290 Plaintiff Williams was a victim of human trafficking at the hands of Augusta County

291 Sheriff Donald Smith and his “deputies.”

292 60) Plaintiff Jason Monroe is a resident of Augusta County, Virginia. Plaintiff

293 Monroe was a victim of a nearly half million-dollar financial fraud committed by the

294 Captain of the Augusta County Sheriff’s office and covered up by Augusta County

295 Sheriff Donald Smith, who threatened him that the Captain was “very powerful”.

296 61) Defendant Gannett, an international publisher of news content, owns and

297 operates The Staunton Newsleader in Staunton, Virginia. Defendant is a Corporation

298 registered to do business in the Commonwealth of Virginia, and is headquartered in

299 Fairfax County, Virginia.

300 62) This Court has personal jurisdiction over Defendant Gannett because

301 Gannett is headquartered within the jurisdiction of this Court.

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Campbell v. Gannett

302 63) The Court’s jurisdiction is based on § 17.1-513, et seq., and § 8.01-328.1,

303 et seq., of the Code of Virginia.

304 64) Venue is proper pursuant to § 8.01-262(4) of the Code of Virginia.

305 COUNT ONE

306 FRADULENT INDUCEMENT TO CONTRACT

307 65) Plaintiffs reincorporate by reference the facts alleged in paragraphs 1

308 through 51, above.

309 66) During the time of the Plaintiff’s cooperation the Defendant’s Reporter

310 Nagaishi, Defendant engaged in a concerted effort to prevent the publication of stories

311 that would be negative to the Sheriff of Augusta County or that would call attention to his

312 corruption.

313 67) Engaging in a cover up of sex assaults, racist police violence, and attacks

314 on their own reporters demonstrate that Defendant’s representation of The Staunton

315 Newsleader as a legitimate source for unbiased local news are patently false and create:

316 "(1) a false representation, (2) of a material fact, (3) made intentionally and knowingly,

317 (4) with intent to mislead" that results in "(5) reliance by the party misled, and (6)

318 resulting damage to the party misled." Evaluation Research Corp. v. Alequin, 247 Va.

319 143, 148, 439 S.E.2d 387, 10 Va. Law Rep. 779 (1994). Such are the elements of

320 fraudulent inducement to contract, and Plaintiffs are entitled to recover damages suffered

321 from Defendants fraud.

322 68) Defendant’s representation that they are a legitimate source of local news

323 and a promise to bring investigative reporting to make the community better are false
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Campbell v. Gannett

324 representations. Further, the Defendant represents that subscribers to their newspaper will

325 have access to this investigative reporting.

326 69) The false representations are a subject of a material fact, mainly that

327 Plaintiffs can depend upon Defendant as an unbiased source for local news and will

328 conduct accurate and comprehensive investigative reporting in the local community.

329 70) The representations are made knowingly and intentionally in Defendant’s

330 advertising to entice people to subscribe. In fact, they appear several times before and

331 during the subscription process.

332 71) The representations are made with the intent to mislead. The Defendant

333 identifies ad-based content and disclaiming “paid for news” ad placements regularly. The

334 fact that they continue to present this “policy” of identifying ad content in news to the

335 public to entice subscribers yet chose to ignore them to protect the Augusta County

336 Sheriff, shows that their representations were made with the intent to mislead.

337 72) Plaintiffs have suffered damages as a result of the Defendant’s fraudulent

338 inducement. Plaintiff Campbell was forced to relive her traumatic experience of being

339 raped and that rape being covered up. Plaintiff Williams was forced to relive her

340 experiences as a human trafficking victim by Sheriff Smith and his “narcotics division”

341 when she was forced to commit immoral acts in furtherance of the deputies’ objectives to

342 traffic more narcotics and when she was forced to agree to plant drug evidence on

343 innocent suspects. Plaintiff Monroe was forced to relive the experience of losing

344 everything from a fraud committed by law enforcement, the only people he could turn to

345 as a victim of crime. The Plaintiffs have suffered greatly, only to be abandoned and

346 potentially be further exposed for harassment without any publication of their allegations.
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347 COUNT II

348 BREACH OF CONTRACT

349 73) Plaintiffs reincorporate by reference the facts alleged in paragraphs

350 through 59, above.

351 74) The Defendant and the Plaintiff had a valid contract for the Defendant to

352 keep their sensitive documents secure and to investigate and report on their allegations.

353 The contract was entered between the Plaintiffs and the Defendant through Defendant’s

354 reporter, Ayano Nagaishi. Nagaishi confirmed that her investigation proved the Plaintiff’s

355 allegations (see audio recordings attached as exhibits to this complaint) and Plaintiffs had

356 a reasonable expectation that Defendant would honor its terms of the agreement. This

357 contract had an offer of investigating corruption claims and reporting on them that was

358 accepted by the Plaintiff, and consideration in the form of keeping the documents secure

359 and reporting on the allegations if they were verified was provided. The Defendant

360 accepted the documents and information, confirmed the veracity of the allegations, then

361 systemically sought to cover up the allegations in direct contradiction to their agreement

362 with the Plaintiffs.

363 75) Defendant violated material terms of the contract through their conduct as

364 detailed above.

365 76) Because the Defendant breached the contract with the Plaintiff, the

366 Plaintiff is entitled to damages from the breach.

367 COUNT III

368 NEGLIGENCE
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369 77) Plaintiffs reincorporate by reference the facts alleged in paragraphs

370 through 63, above.

371 78) In Virginia, “the failure to use the degree of care an ordinary person would

372 exercise to avoid injury to another” constitutes simple negligence. Harris v. Harman, 486

373 S.E.2d 99, 101, 253 Va. 336, 340 (Va.,1997).

374 79) As demonstrated above, the Defendant knew that Sheriff Smith had

375 committed several instances of corruption and other derelictions of duty during his time

376 as Sheriff, yet took steps to prevent reporting on this issue. The Defendant owes a duty of

377 care to their readers and to the local public as a newspaper that “makes our community a

378 better place to work, live and play”. If they do not owe such a duty to their subscribers or

379 the general public, they certainly owe it to sources they induce to contract with their news

380 team to provide documents and information for news investigations.

381 80) However, the Defendant newspaper failed to use the degree of care that an

382 ordinary person would use to avoid injury to another. By actively covering up the

383 Sheriff’s rampant abuses of office, the Defendant breached the degree of care that an

384 ordinary person would use when confronted with such violations. As a result of this

385 negligent conduct, the Plaintiffs, as victims of the police corruption and as members of

386 the local community, suffered an injury in their failure to learn about the harmful conduct

387 of the Sheriff’s department in their area, increasing their chances of being subject to such

388 harmful conduct.

389 81) Therefore, the Defendant is liable for negligence.

390 PRAYER FOR RELIEF

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391 WHEREFORE Plaintiffs respectfully pray for judgment in their favor and against the

392 Defendant, as well as the following equitable relief and award of damages:

393 a. Actual damages, in an amount to be determined at trial;

394 b. Punitive damages against Defendant;

395 c. Attorneys’ fees and costs; and

396 d. Any and all such other and further legal and equitable relief as the Court

397 deems necessary, just, and proper.

398 REQUEST FOR TRIAL BY JURY

399 Plaintiffs respectfully request trial by jury for all issues so triable.

400 Dated: June 2, 2022

401 Respectfully Submitted,

402
403
404 By: ____________________________
405 Amina Matheny-Willard, VSB# 43566
406 Amina Matheny-Willard, PLLC
407 999 Waterside Drive, Suite 2525
408 Norfolk, Virginia 23510
409 Cell: 757-652-6462
410 Firm Tel.: 757-777-3441
411 Firm Text: 757-239-3961
412 Firm Fax: 757-282-7808
413 Email: amina@aminalaw.com
414 Counsel for Plaintiffs