In the Superior Court of Fulton County State of Georgia

IN THE SUPERIOR COURT OF FULTON COUNTY STATE OF GEORGIA

EQUITY PRIME MORTGAGE, LLC,

Plaintiff,

Civil Action No. ______v. JURY TRIAL DEMANDED MELISSA ROLFE

and

GREENE FOR CONGRESS, INC.,

Defendants.

COMPLAINT FOR DAMAGES

Plaintiff Equity Prime Mortgage, LLC (“Plaintiff” or “EPM”), for its complaint against

Defendants Melissa Rolfe and Greene for Congress, Inc. (collectively the “Defendants”) states as follows:

NATURE OF THE ACTION

1. This defamation lawsuit arises from a smear campaign launched by a disgruntled

former employee, a Congressional campaign, and a candidate seeking to exploit the death of

Rayshard Brooks for their own personal gain. In the brief time that Melissa Rolfe was employed as the HR Director at EPM, she repeatedly violated company policy and created an uncomfortable and hostile working environment. After securing her position at EPM under false pretenses, she

fostered a hostile work environment at the company by, among other things, calling employees

“savages” and “fucking bitches,” joking about conducting rectal temperature checks in the office,

saying that an employee was a “dumb bitch” who can only attract men because she “must suck

dick really good,” and saying an employee had only gotten hired because she had “big boobs.”

Even worse, she engaged in blatantly racist conduct, telling a Black woman who dates Black men that she needed “to get outside the box and upgrade [her] standards,” and—in response to another

employee’s joke that she liked her coffee black and strong like she liked her men—by retorting

“Black and weak. Don’t no woman want a weak man.” Not surprisingly, Rolfe lost people’s

confidence in her ability to perform her job as an HR Director and was fired.

2. Although Rolfe had been repeatedly reprimanded and was notified—the day before

her stepson shot Rayshard Brooks—that she was under investigation because of multiple

complaints against her, she joined forces with Marjorie Taylor Greene and her Congressional

campaign to launch a national media firestorm, which included televised

appearances on The Glenn Beck Program and Tucker Carlson Tonight, social media posts, and speeches, all to peddle the false narrative that Rolfe had done nothing wrong and that EPM had fired her for fighting for her stepson and being his stepmom.

3. The smear campaign mobilized a furious social media mob and prompted death

threats, a boycott, and enormous reputational and financial harm to EPM.

4. EPM brings this action to vindicate its rights under civil law, to restore its

reputation, and to recover compensatory and punitive damages for the harm the Defendants have caused.

-2-

PARTIES

5. Plaintiff Equity Prime Mortgage, LLC is a limited liability company organized and

existing under the laws of the state of Georgia. Its principal place of business is located at

5 Concourse Parkway, Suite 2250, in Atlanta, Georgia.

6. Defendant Melissa Rolfe is an individual and Georgia resident who was employed

at EPM in—and regularly conducts business in—Fulton County, Georgia. Rolfe conspired with

Greene for Congress, Inc. to publish false and defamatory statements concerning EPM.

7. Defendant Greene for Congress, Inc. (the “Campaign”) is Marjorie Taylor Greene’s

Congressional campaign, and it can be served via its registered agent, Jason D. Boles, at 290 Jayne

Ellen Way, Alpharetta, Georgia, its principal place of business. The Campaign and Greene conspired with Rolfe to publish false and defamatory statements concerning EPM.

JURISDICTION AND VENUE

8. All of the material facts underlying EPM’s claims occurred and arise from activities

in Fulton County, Georgia.

9. Venue in this Court is proper pursuant to O.C.G.A. 14-2-510(b)(4) and (d).

FACTUAL ALLEGATIONS

Eddy Perez Founded EPM in 2008 and Has Since Grown the Company to Become One of the Leading Mortgage Lenders in the United States

10. Eddy Perez is a longtime Fulton County resident who was born and raised in

Atlanta, Georgia. He attended Georgia State University in 1999 and started working in the mortgage industry shortly after completing his studies.

11. After spending several years originating loans, Perez founded

Equity Prime Mortgage in 2005 with approximately $1,000 in capital.

-3-

12. Perez has successfully grown his business, and he continues to serve as the CEO

and President of EPM from the company’s Atlanta-based headquarters.

As HR Director at EPM, Melissa Rolfe Repeatedly Violated Company Policy and Created an Uncomfortable and Hostile Working Environment

13. In January 2020, Melissa Rolfe submitted her resume to be EPM’s HR Director.

To secure employment at EPM, Rolfe boasted on her resume that she had a B.S. in Human

Resource Management from Columbia Southern University, a SHRM-CP certification, and more

than 15 years of dedication and significant experience managing a full spectrum of human

resources programs and functions.

14. Rolfe began as EPM’s HR Director in February 2020, working in EPM’s Atlanta- based headquarters.

15. After Rolfe was hired, certain people at EPM learned that Rolfe was working toward a bachelor’s degree but did not actually have one yet as her resume represented.

16. Less than a month after she had been hired by EPM, on March 19, 2020, Rolfe was

reprimanded because she had made inappropriate jokes via text message about conducting rectal

temperature checks in the office.

17. About a month later, on April 23, 2020, Rolfe was reprimanded again, this time for

referring to employees as “savages.”

18. Less than two months later, two employees reported Rolfe for calling employees

“fucking bitches,” saying an employee had only been hired because she had “big boobs,” and

making racist comments.

19. So, on June 11, 2020—the day before Rolfe’s stepson shot Rayshard Brooks—

EPM CEO Eddy Perez met with Rolfe to notify her of the latest complaints against her. Upon

hearing she had been accused of making racist comments—and before Perez had brought up

-4-

Rolfe’s inappropriate remark about an employee’s “big boobs”—Rolfe became enraged, saying that she doesn’t see color, but that some people are “idiots.” Because of how upset Rolfe had become, Perez cut the meeting short and told her that he would follow up with her after investigating more.

20. The next day, Friday, June 12, 2020, Rolfe’s stepson shot Rayshard Brooks in the parking lot of an Atlanta Wendy’s, prompting Rolfe to ask to work from home the following

Monday. Although Rolfe was under investigation for serious misconduct, the company nevertheless granted Rolfe eight weeks of paid leave in light of her family situation, while it simultaneously continued its investigation. During the investigation, a flood of employees came forward and reported other instances of Rolfe’s wildly unprofessional and hostile conduct, including:

• Rolfe told an employee that another employee was a “dumb bitch” and that the only reason a man would be interested in her was because she “must suck dick really good.”

• Rolfe told a Black woman who dates Black men that she needed “to get outside the box and upgrade [her] standards.”

• In response to an employee saying she liked her coffee like she liked her men, Black and strong, Rolfe responded, “Black and weak. Don’t no woman want a weak man.”

• Rolfe remarked that an employee wore “little girl ruffle panties.”

• Rolfe shouted at and berated employees, including by using the following language: “stupid bitches,” “dingbats,” “tell that bitch to get a fuckin’ name tag,” “this is bullshit and stupid shit,” and “who fucked up.”

21. In addition, an EPM employee who had previously worked with Rolfe at

Rehabilitation Physicians of Georgia reported that Rolfe had been a “Medical Assistant” there— not an “HR Director” as her resume represented. That person further reported contacting Rolfe’s previous employers and discovering that she had falsified other information as well.

-5-

22. After learning the above, EPM terminated Rolfe the afternoon of June 18, 2020.

Notably, when Rolfe was informed that she was being terminated, she did not ask why; she knew

that she had been repeatedly reprimanded and that—before her stepson shot Brooks—the company

had begun an investigation into multiple complaints against her.

After Being Fired, Rolfe Launched a Smear Campaign Against EPM

23. The same day she was terminated, Rolfe conspired with the Campaign and Greene

to defame EPM and peddle the falsehood that Rolfe had done nothing wrong and that she was fired for fighting for her stepson and being his stepmother.

24. On information and belief, on June 18, 2020, Rolfe, the Campaign, and Greene jointly coordinated the planting of a false story with Tucker Carlson Tonight, authorizing, intending, and expecting that their false claims would be broadcast to a worldwide internet audience.

-6-

25. By planting the false story with Tucker Carlson Tonight and repeating it during various public appearances during the summer of 2020, the Defendants and Greene swiftly mobilized a social media mob, death threats, and a boycott against EPM, and EPM was bombarded with furious messages from people who believed the lie. As Rolfe’s attorney later explained on

Tucker Carlson Tonight, EPM’s “website was overwhelmed, more than 10,000 hits they got that literally shut down their website, it shut down their social media posts and it was overwhelmingly negative.”

26. Perez reported the death threats to the FBI and hired a private security firm to protect people working in EPM’s office, his family, and himself.

27. To set the record straight, EPM issued a statement explaining why Rolfe had been terminated:

As an employer, it is imperative to maintain a safe environment for all employees. Melissa Rolfe’s termination was a direct result of her actions in the workplace and violation of company policy. While working with Melissa as she transitioned to a leave of absence granted by our organization, we discovered she violated company policy and created an uncomfortable working environment for many of our employees. As an HR director, she ultimately lost the confidence of her peers, leadership and many employees who no longer felt comfortable engaging with her. We value diversity of thought and respect Melissa’s personal views and the views of all employees; however, when those views create a hostile working environment, we must make difficult decisions to part ways.

28. On information and belief, even though the Defendants and Greene knew—from the multiple prior reprimands Rolfe had received and the investigation she had been placed under

-7-

and from Rolfe’s conversations with Greene and the Campaign—that EPM’s statement was true,

Defendants doubled down in speeches and by securing appearances on The Glenn Beck Program and Tucker Carlson Tonight to repeat their lie and to falsely accuse EPM of defaming Rolfe.

29. Glenn Beck and Tucker Carlson both asked Rolfe whether she had been subject to any complaints for her conduct during her time at EPM. Rolfe responded in the negative, repeatedly insisting that she could not identify anything she had done that could have justified her termination and that she was fired for fighting for her son and being his stepmom.

30. The Campaign and Greene published defamatory statements regarding Rolfe’s termination, and Defendants continued to defame EPM from June 18, 2020, to present.

31. With the televised appearances and other statements to the media and the general public, Defendants and Greene poured gasoline on the media firestorm they had started, causing enormous reputational and financial harm to EPM.

32. On June 30, 2020, EPM requested retraction of Rolfe’s false claims pursuant to

O.C.G.A. 51-5-11 (2010).

33. On July 21, 2020 EPM followed up and asked Rolfe for an apology and correction.

34. Rolfe rejected EPM’s requests and continues to stand by the truth of her false

accusations.

-8-

35. In August of 2020, the Defendants mailed a letter that repeated the Defendants’ lie

about why Rolfe was fired.

36. On August 6, 2020, EPM put the Campaign and Greene on formal written notice of why Rolfe had been terminated and demanded retraction of their false claims pursuant to

O.C.C.G.A. 51-5-11.

37. After receiving EPM’s retraction request, the Campaign and Greene posted a

message on social media doubling down on their false accusation about EPM. The Campaign and

Greene have refused to correct their false statements and have continued to stand by them.

38. Defendants knew that their smear campaign was based on a lie, but they

intentionally disregarded the truth to capitalize on national attention related to Rayshard Brooks’s

death. In addition, Rolfe wanted to punish EPM and extract money from EPM for firing her and

wanted to fraudulently obtain monetary donations from the public: upon information and belief,

Rolfe sanctioned and has accepted or intends to accept money from a GoFundMe fundraiser

predicated on the falsehood that she was terminated “for just one reason alone: she is former

Atlanta officer Garrett Rolfe’s stepmom.”

COUNT ONE: DEFAMATION

39. EPM repeats and re-alleges the foregoing paragraphs as if set forth fully herein.

40. The Defendants and Greene made false and defamatory statements about EPM and

published these statements to numerous people, including EPM’s customers and potential

customers, residents of Fulton County, and untold millions of others beginning on June 18, 2020.

41. Specifically, the Defendants, acting jointly with Greene to harm EPM’s reputation

and with reckless disregard for the truth, made or caused to be made the following false and

defamatory statements of fact of and concerning EPM:

-9-

a. Beginning on or around June 18, 2020, and continuing to present day, Rolfe, the Campaign, and Greene have stated to numerous reporters, media outlets, and others, in words or substance, that “Rolfe did not do anything wrong, that EPM never raised any issues with her about her workplace conduct, and that EPM fired her because Officer Garret Rolfe was her stepson and she was fighting for him.”

b. Upon information and belief, on or about June 18, 2020, Defendants and Greene coordinated to plant a false story by telling or causing someone to tell a producer from Tucker Carlson Tonight that “Rolfe was fired by Equity Prime Mortgage for being Officer Garret Rolfe’s stepmother and she did nothing to warrant termination,” prompting Tucker Carlson to repeat those falsehoods on his June 18, 2020, broadcast as follows: “So we’ve been telling you the story of the police officer charged, Officer Rolfe. Until today, his stepmother, her name is Melissa Rolfe, was the HR Director at a place called Equity Prime Mortgage in Atlanta, Georgia, but today she was let go. Apparently, she was fired, and her only crime was being Officer Rolfe’s stepmother. According to the source familiar with the matter who spoke to this program, Rolfe was promised that her job was safe, but today she was told, and we’re quoting, we have to terminate our relationship with you. No other explanation was offered and honestly, no other explanation was needed. It was obvious what happened…We just told you a moment ago that the stepmother of Officer Rolfe, the Atlanta cop who is facing the death penalty for the shooting of Rayshard Brooks, was just fired from her job today at a place called Equity Prime Mortgage in the Atlanta Area. We told you she was fired with no explanation, obviously because they disapproved of who her stepson was, and in America we don’t do things like that because it’s immoral. … The bottom line is, it seems pretty clear they fired this woman because of who her stepson was.”1

c. During a televised appearance on The Glenn Beck Program on June 22, 2020, Rolfe had the following exchanges with Beck:

ROLFE: We were coming back home and I had missed a phone call and I was returning it, and up until that point I had had full support of my company, so I had no, you know, no reason not to call him back. And when I -- when I called, he answered, said hello and he said, how are you doing? My direct supervisor, how are you doing? I said, well, I’ve had better days, but we’re okay right now. And he said, well I just want to let you know we’re terminating our relationship with you, and I said why? What happened? And he said, I can’t tell you any further. I’m not aware of anything I’ve

1 Fox News, First on ‘Tucker’: Stepmother of ex-Atlanta officer charged in Rayshard Books killing fired from her job (June 19, 2020), https://video.foxnews.com/v/6165648907001.

-10-

done to this company, except, you know, I was -- like I said, up until they fired me, I was – it was my belief that I had their full support. So this has just been – it’s a false statement, that I’ve done anything, but it’s so hurtful.

BECK: So . . . so -- I mean, you’re in charge of HR and you and I both know that unless you did something grievous that was a fireable offense, creating a hostile work environment would be something that you would usually sit somebody down and say, hey, what’s going on? You’ve been a good employee, now this is happening. What’s happening in your life? What’s going on? And you don’t fire somebody and they’re surprised by a charge like that, do they? Do you?

ROLFE: No -- not typically. . . You can’t fire someone for an illegal reason. But they haven’t told me anything. I have no knowledge of anything that I’ve done, and since when I left work on Friday the 12th, everything was great and I haven’t been back to the office yet, so I’m not sure what I did to create a hostile work environment. They won’t tell me anything.

BECK: Is it possible that your hostile work environment was caused just by your presence, because of your son?

ROLFE: That is a possibility. That is a possibility. But again, I can’t confirm or deny. They just haven’t told me anything. So I mean, it’s just kind of strange timing but, you know, it goes along with all of this with Garrett. But like I said, right now it’s just this horrible statement is on their website about me, and it’s false. It’s just completely false.

…

I wasn’t scared into silence because that’s not what’s right. It’s time that we stood up and stood up against what we believe is wrong, and the war that’s on the police officers right now is wrong and we have to stand up, and if it costs me a job to fight for my son, then so be it.2

2 Yahoo Finance, Stepmom of ex-police officer accused of killing Rayshard Brooks speaks out after being fired from her job (June 30, 2020), https://finance.yahoo.com/video/stepmom-ex-police-officer-accused-004616899.html.

-11-

d. On June 23, 2020, the Campaign and Greene published a Facebook post stating that “Melissa herself lost her job as a result of this nonsense,” i.e., events involving her stepson.

e. During a televised appearance on Tucker Carlson Tonight on June 30, 2020, Rolfe and her attorney, David Guldenshuh, had the following exchanges with Carlson:

CARLSON: It’s so distressing to think – because this isn’t North Korea and we don’t believe in blood guilt – that a person could be fired from a job because of who that person is related to. Do you think that’s why Equity Prime Mortgage fired you?

ROLFE: That is my belief. I believe their timing was impeccable, and I believe that was the primary motive behind my being terminated.

-12-

CARLSON: Had you been in trouble with them? Was there any indication that they were going to fire you, before you received the message saying you were terminated?

ROLFE: No.

…

CARLSON: Is it legal in this country to fire someone because you don’t like one of her relatives?

DAVID GULDENSCHUH: Well, Tucker, in the state of Georgia, the answer to that, as a general rule, would probably be you can fire them for that very, very arbitrary reason. It’s not unlawful to do it under those circumstances, but it’s certainly immoral, and I’ve handled many cases like this over 40 years. What you can’t do, which is what they did do in this case, was after you graciously ran the story Thursday, a week ago, their website was overwhelmed, more than 10,000 hits they got that literally shut down their website, it shut down their social media posts and it was overwhelmingly negative, and the result of that was they went on and they made a post which was absolutely horrendous. It was terribly defamatory. It accused Melissa of engaging in conduct that created a hostile work environment at the facility. When she left on Friday, before Garrett’s incident, she was held in high esteem there. Four days later, after telling her that she was being totally supported, the district attorney brought charges against Garrett, and suddenly she was terminated. They got hammered by it, by -- spontaneously by the public, and so they went on and tried to blame it on Melissa, and we look forward to having a jury of peers at some point correct this very egregious wrong.

-13-

CARLSON: It’s almost beyond belief, Melissa. It’s hard to know what kind of monster would do this. Not only did they fire you for something you had nothing to do with, something a relative was accused of, but then after they fired you, they smeared you – and let’s just be honest about what they were saying – for being a racist. That was the implication. I read it, and that was clearly what they were saying, you’re a racist. How do you feel about that?

ROLFE: Flabbergasted might be a word I would use. Extremely hurt is another one because it couldn’t be further from the truth. It’s such a false statement. And so it’s caused worldwide embarrassment because we’ve had people from other countries reach out and ask, what on earth did you do? And we’re not able to tell ‘em anything.3

3 A rebroadcast of the June 30, 2020 interview from Tucker Carlson Tonight is available online at https://www.youtube.com/watch?v=uYsyvOW97eA.

-14-

f. In a June 30, 2020 publication to news media, Rolfe stated “Nothing I did was a fireable offense and I have not gotten any guidance from EPM about what exactly they had an issue with. It was a political move.”4

g. In a June 30, 2020 interview to Fox News, Rolfe stated that she was:

Just stunned that it was such– false statements about me. Nothing was true and when I spoke because like I said I’ve not been back to the office. And in the week following this when I would speak with my direct manager and the president, I was being assured that everything was fine in the office. Continually through the phone calls and text messages that I was receiving. Everything’s fine. My job was fine. Don’t worry about it. We’re not getting any negative feedback. So I was very surprised how I was able to create a hostile work environment. I hadn’t been back, so I don’t know how I lost the confidence of my peers, again, just being the stepmother.5

h. In a June 30, 2020 statement to news media, Rolfe stated that EPM had “completely defamed me.”6

4 Maria Schutlz, Stepmom of ex-Atlanta cop Garrett Rolfe ‘stunned’ by firing after Rayshard Brooks Shooting. Melissa Rolfe says in Fox News interview her termination was a ‘political move,’ (June 30, 2020), https://www.foxnews.com/us/stepmom-of-ex-atlanta-cop-garrett-rolfe-stunned-she-was-fired-from-job-after- rayshard-brooks-shooting. 5 Id. 6 Marlene Lenthang, Stepmother of Atlanta cop Garrett Rolfe breaks her silence to defend him and reveals she was fired from her HR director job over the phone after he shot Rayshard Brooks dead (June 30, 2020), https://www.dailymail.co.uk/news/article-8476955/Stepmother-Atlanta-cop-Garrett-Rolfe-defends-saying-war- police-needs-end.html.

-15-

i. On June 30, 2020, the Campaign and Greene published a tweet stating that “Melissa’s employer caved to the mob and wrongfully fired her!” and republished a Daily Caller article saying “Melissa Rolfe, stepmother of the ex-Atlanta police officer charged in the killing of Rayshard Brooks, joins Tucker Carlson to talk about being fired from her job over her relation to her stepson” and “I believe that was the primary motive behind my being terminated:”

-16-

j. In early August of 2020, the Campaign, Greene, and Rolfe published and circulated a letter signed by Rolfe and funded by the Campaign, which contains the following false and defamatory statements about EPM:

After initially being told by my employer that my job was safe and to take care of my family, I was FIRED the day after charges were announced against Garrett. They blamed me for creating a hostile work environment when I wasn’t even at work. … You may have seen me on Tucker Carlson’s Fox News show talking about Garrett’s situation, and my firing.7

k. On August 6, 2020 at 9:19 p.m., after receiving EPM’s retraction demand letter and being put on formal written notice of why Rolfe had been terminated, the Campaign and Greene published a Facebook post saying that “Melissa Rolfe, the stepmother of Atlanta of Officer Garret Rolfe…lost her job as a result of this nonsense,” i.e., the events involving her son.

7 This letter is attached and incorporated as Exhibit A (emphasis added).

-17-

42. These statements are false. Before Rolfe’s stepson shot Brooks, Rolfe had been

reprimanded three times—in just over four months of employment—for workplace misconduct.

The day before Rolfe’s stepson shot Brooks, EPM notified Rolfe that she was under investigation because of multiple complaints against her. Rolfe was terminated because she repeatedly violated company policy and created an uncomfortable and hostile working environment by, among other things, calling employees “savages” and “fucking bitches,” joking about conducting rectal

temperature checks in the office, saying that an employee was a “dumb bitch” who can only attract

men because she “must suck dick really good,” saying an employee had only gotten hired because

she had “big boobs,” telling a Black woman who dates Black men that she needed “to get outside

the box and upgrade [her] standards,” and—in response to another employee’s joke that she liked

her coffee black and strong like she liked her men—by retorting “Black and weak. Don’t no

woman want a weak man.”

43. These statements are reasonably understood to be statements of fact of and

concerning EPM and were actually understood to be statements of fact and of and concerning

EPM.

44. These statements are defamatory and defamatory per se because they subject EPM

to public hatred, contempt, and ridicule; because they were published in connection with—and

made specifically to injure—EPM’s business and charge the company with being unfit for carrying

on its business; because they charge EPM with dishonest conduct and other debasing acts that may exclude it from society.

45. Defendants had no applicable privilege or legal authorization to make these false and defamatory statements, or, if they did, they abused it.

-18-

46. Defendants made these false and defamatory statements intentionally, willfully, maliciously, and in conscious disregard of EPM’s rights and reputation and of the truth.

47. Defendants acted with actual malice, showing intentional or reckless disregard for the falsity of their statements about EPM. Defendants’ disregard for the truth is demonstrated by their actions and omissions including but not limited to the following:

a. Rolfe knew from her personal experience that she had repeatedly made inappropriate remarks to and about EPM employees and that she had been reprimanded by EPM’s CEO on three separate occasions for that workplace conduct before her stepson shot Rayshard Brooks; upon information belief, the Campaign knew about the circumstances of Rolfe’s termination from communications with Rolfe on the day of her termination and thereafter;

b. In reckless disregard of the truth, the Campaign purposefully avoided contacting EPM before launching the defamatory smear campaign and misrepresenting why Rolfe had been fired;

c. Rolfe seized on the opportunity to obtain money from a GoFundMe fundraiser predicated on the falsehood that she was terminated “for just one reason alone: she is former Atlanta officer Garrett Rolfe’s stepmom;”

d. After EPM demanded a retraction and put the Campaign and Greene on formal written notice of Rolfe’s previous reprimands and the employee complaints regarding Rolfe’s misconduct, the Campaign and Greene published a Facebook post doubling down on the lie;

e. Despite receiving retraction demand letters from EPM, Defendants have refused to retract their false accusations or to apologize; and

f. Defendants made their defamatory accusations with the intent to harm, and out of hostility toward, EPM.

48. Just as Defendants authorized, expected, and intended, their false and defamatory statements have been foreseeably repeated, republished, and disseminated to a worldwide internet audience.

49. As a direct and foreseeable result of Defendants’ false and defamatory statements,

EPM’s professional standing in relation to its business and trade has been substantially impugned.

-19-

50. As a direct and foreseeable result of Defendants’ false and defamatory statements,

EPM’s relationships with community members, employees, peers, customers, potential customers,

and associates have been damaged and destroyed.

51. As a direct and foreseeable result of Defendants’ false and defamatory statements,

EPM has been exposed to public hatred, contempt, and ridicule.

52. As a direct and foreseeable result of Defendants’ false and defamatory statements,

EPM has been forced to make substantial expenditures of money to remedy the defamation and suffered other economic and special damages.

53. In view of the foregoing, EPM is entitled to actual, presumed, punitive, and other damages in an amount to be specifically determined at trial.

COUNT TWO: FALSE LIGHT INVASION OF PRIVACY

(In the Alternative)

54. EPM repeats and re-alleges the foregoing paragraphs as if set forth fully herein.

55. Defendants created false publicity that depicts EPM as something that it is not.

56. The false light in which Defendants placed EPM would be highly offensive to a reasonable person.

57. Defendants publicly disclosed falsehoods concerning EPM.

58. Defendants caused the false implication with actual malice and reckless disregard for the truth.

59. Defendants acted with actual malice, showing intentional or reckless disregard for the falsity of their statements about EPM. Defendants’ disregard for the truth is demonstrated by their actions and omissions including but not limited to the following:

a. Rolfe knew from her personal experience that she had repeatedly made inappropriate remarks to and about EPM employees and that she had been

-20-

reprimanded by EPM’s CEO on three separate occasions for that workplace conduct before her stepson shot Rayshard Brooks; upon information belief, the Campaign knew about the circumstances of Rolfe’s termination from communications with Rolfe on the day of her termination and thereafter;

b. In reckless disregard of the truth, the Campaign purposefully avoided contacting EPM before launching the defamatory smear campaign and misrepresenting why Rolfe had been fired;

e. Despite receiving retraction demand letters from EPM, Defendants have refused to retract their false accusations or to apologize.

f. Defendants made their defamatory accusations with the intent to harm, and out of hostility toward, EPM.

60. Just as Defendants authorized, expected, and intended, their false and defamatory

statements have been foreseeably repeated, republished, and disseminated by a worldwide internet audience.

61. Defendants had no applicable privilege or legal authorization to make these false depictions, or, if they did, they abused it.

62. In view of the foregoing, EPM is entitled to actual, presumed, punitive, and other damages in an amount to be specifically determined at trial.

DEFENDANTS’ CONDUCT WARRANTS PUNITIVE DAMAGES

63. EPM repeats and realleges the paragraphs set forth above as if set forth fully herein.

64. Defendants’ conduct warrants the imposition of punitive damages. The factors

justifying punitive damages include, but are not limited to, the following:

-21-

b. In reckless disregard of the truth, the Campaign purposefully avoided contacting EPM before launching the defamatory smear campaign and misrepresenting why Rolfe had been fired;

e. Despite receiving retraction demand letters from EPM, Defendants have refused to retract their false accusations or to apologize;

f. Defendants made their defamatory accusations with the intent to harm, and out of hostility toward, EPM;

g. Defendants have harassed EPM and caused the company to suffer oppression with an entire want of care, subjecting the company to threats, a boycott, and reputational and financial harm; and

h. Defendants acted with specific intent to cause harm.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff Equity Prime Mortgage, LLC respectfully requests that the Court enter judgment in its favor against Defendants Melissa Rolfe and Greene for Congress, Inc. as follows:

(1) Actual, presumed, and punitive damages in an amount to be determined at trial;

(2) All costs, disbursements, fees, and interest as authorized by law; and

(3) Such other additional remedies as the Court may deem just and proper.

-22-

Dated: August 11, 2020 Respectfully Submitted,

s/ Brent L. Wilson Brent L. Wilson Georgia Bar No. 767667 Timothy J. Holdsworth Georgia Bar No. 730986 Elarbee, Thompson, Sapp & Wilson LLP 800 International Tower 229 Peachtree Street, NE Atlanta, Georgia 30303 Telephone: (404) 582-8427 Email: [email protected] Email: [email protected]

Thomas A. Clare, P.C. (of counsel) (pro hac vice forthcoming) Elizabeth M. Locke, P.C. (of counsel) (pro hac vice forthcoming) Megan L. Meier. Esq. (of counsel) (pro hac vice forthcoming) Daniel P. Watkins, Esq. (of counsel) (pro hac vice forthcoming) CLARE LOCKE LLP 10 Prince Street Alexandria, VA 22314 Telephone: (202) 628-7400 Email: [email protected] Email: [email protected] Email: [email protected] Email: [email protected]

Attorneys for Plaintiff Equity Prime Mortgage, LLC

1748176-1

-23- Exhibit A