Constance Agregaard Defamation Lawsuit

8/10/2019 Constance Agregaard Defamation Lawsuit

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IN UNITED STATES DISTRICT COURT FOR THE DISTRICT OF

ARIZONA

PHOENIX ARIZONA DIVISION

AHMED SALAU, ) Case No.

P. O. BOX 6008, )

PRINCETON, WV 24740. )

)

Plaintiff, pro se )

)

vs. ) COMPLAINT

)

CONSTANCE AGREGAARD, ) JURY TRIAL DEMANDED

C/O MG Robert Ashley, Jr.,448 Christy Avenue,

)

Building 22408,

Fort Huachuca, AZ 85613)

)

Defendant

Constance

Agregaard.

)

COMPLAINT

Plaintiff Ahmed Salau, pro se, for his complaint alleges as follows:


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NATURE OF THE CAUSE

This is an action for defamation, intentional infliction of emotional distress

arising out of defamatory Statements made by the Defendant Constance Agregaard

about Defendant Constance Agregaards dealings with Plaintiff. As detailed herein,

Plaintiff is entitled to actual damages, compensatory and punitive damages,

damages for pain and suffering as a result of Defendant Constance Agregaard s

actions, exemplary damages, special damages and other damages. Substantial parts

of the events alleged herein took place in Arizona. The most recent and substantial

events took place in Arizona and as such Arizona law applies herein. Plaintiff

requests a jury decide these claims.

JURISDICTION AND VENUE

This Court has subject matter jurisdiction over this action based on

diversity of citizenship pursuant to 28 U.S.C 1332(a).

Venue is proper pursuant to 28 U.S.C 1391(b) because a substantial

part of the events or actions giving rise to Salaus claims arose in this district.

Salau has incurred harm in this district as a result of Agregaards tortious

conduct, and Agregaard expressly aimed her tortious conduct at this district.


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THE PARTIES

1. Plaintiff, Ahmed Salau is a natural person and is a resident of

Princeton, West Virginia. Plaintiff majored in chemistry and psychology

and had a minor in women and gender studies. Plaintiff is also a

professional research associate, co-author, co-investigator on a number

of ongoing scientific projects that have been published in peer-reviewed

journals published by reputable organizations like the American

Chemical Society among others. Plaintiff also had another job as a

student customer service assistant at the University of Missouri Campus

Dining Services. Plaintiff was also involved and/or is a member of

numerous groups on campus including but not limited to STOP

TRAFFIC, BAPTIST STUDENT UNION, ON THE ROCK, AUTISM

SPEAKS, PSI CHI, THE FOOD BANK, GREEN DOT, Foundation for the

International Medical Relief of Children (FIMRC),among other

organizations. Plaintiff is also the Founder, President and Chief Executive

Officer of PARIS Angels a mentoring program for at-risk youth.

2. Defendant Constance Agregaard, Constance Agregaard is a natural

person and is a resident of Sierra Vista, Arizona.


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STATEMENT OF FACTS

3. On or about August 2012, Plaintiff and the Defendant Constance

Agregaard started working at Integral Resources Incorporated.

4. On or about September 1st2012, Plaintiff and the Defendant

Constance Agregaard start a consensual romantic relationship & move

in together.

5. On or about September 15th2012, Petitioner and Defendant Constance

Agregaard meet Plaintiffs family and Defendant Constance

Agregaards family.

6. On or about September 30th2012, Plaintiff and Defendant Constance

Agregaard visit the Family Health Center together and are informed

that the Defendant Constance Agregaard is pregnant.

7. On or about October 1st2012, the Plaintiff and the Defendant

Constance Agregaard visit Plaintiffs attorney friend Olayinka Hamza

for the weekend.

8. On or about October 12th2012, Plaintiff and the Defendant Constance

Agregaard decide to break up.

9. On or about October 14th2012, the Defendant Constance Agregaard

falsely reports to the Police Department that she had been raped by

the Plaintiff. To with: Ahmed Raped me

10. On or about October 19th2012, the Plaintiff is arrested by the Police

Department and is in jail for seven months.


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11. In May 2013, the Defendant Constance Agregaard recanted her

statement to the police, after being confronted with insurance

receipts, phone records and time stamped photographs that disproved

her rape allegation.

12. The Defendant Constance Agregaard continues to make these false

and defamatory statements and remade them in June 2014 to Mr.

Lowe specifically stating that, Ahmed raped me

13. Plaintiff was informed by Mr. Lowe that the Defendant Constance

Agregaard made the statements.

14. The Defendant Constance Agregaards statements have been widely

distributed on the internet and in newspapers world wide.

15. The Plaintiff is forever damaged by these statements.

16. The Plaintiff has lost multiple jobs and business and educational

opportunities because of the Defendant Constance Agregaards lies.

The Defendant Constance Agregaard lost the jobs he had when he was

arrested and every job ever since because everyone thinks he raped

the Defendant Constance Agregaard which he IN FACT did not.

17. The stigma caused by her statements has completely destroyed the

Plaintiffs image and caused him intense emotional distress.

18.

The Defendant Constance Agregaard ended up keeping the child and

has subsequently kept the Plaintiff from having anything to do with


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his child. The Plaintiff believes upon true belief that the Defendant

Constance Agregaard sold the child for money.

19. Several members of STOP TRAFFIC and Women and Gender Studies

students have heard Defendant Constance Agregaards Statements.

20. Several members of Plaintiffs church The Baptist Student Union have

heard Defendant Constance Agregaards Statements.

21. Several co-workers and supervisors have heard Defendant Constance

Agregaards

Statements.

22. Plaintiffs Advisors have heard Defendant Constance Agregaards

Statements.

23. Members of PSI CHI have heard Defendant Constance Agregaards

Statements.

24. Members of Green Dot have heard Defendant Constance Agregaards

Statements.

25.

Members of On the Rock have heard Defendant Constance AgregaardsStatements.

26. Plaintiff never raped Defendant Constance Agregaard.

CLAIMS FOR RELIEF

FIRST CLAIM FOR RELIEF

(Slander Per Se Injury to Professional Reputation)

27. Plaintiff repeats and re-alleges the allegations set forth in paragraphs

1 to 25 as if fully set forth at length herein.


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28. Defendant Constance Agregaards Statements and publications

described herein

(hereinafter called Statements) concerned Plaintiff and were false.

29.

Defendant Constance Agregaards Statements were widely published

and not privileged in any manner.

30. Defendant Constance Agregaards Statements were made with

reckless disregard of their truth or falsity and/or with malice.

31. Defendant Constance Agregaards Statements were slanderous per se

because they injure

Plaintiffs professional reputation.

32. Defendant Constance Agregaard falsely and as a matter of fact charged

the Plaintiff with raping her asserting as fact, no prior interaction with

him, he raped me that night, contrary to and inconsistent with time

stamped photographs that show otherwise and her subsequent

actions.


the Plaintiff with raping her asserting as fact, he raped me that

night, contrary to and inconsistent with the events that followed and

time stamped photographs.

34. Defendant Constance Agregaards statements forever falsely taint and

permanently damage Plaintiff in the eyes of The University of Missouri

at large, The Chemistry Department of the University of Missouri, The

Psychology Department of the University of Missouri, the Women and


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Gender Studies Department at the University of Missouri, STOP

TRAFFIC, The Baptist Student Union, On the Rock Church, PSI CHI, and

Green Dot. In addition individuals will be less likely to associate with

Plaintiff as a result of his tainted reputation. In addition individuals

will be less likely to associate with

Plaintiff as a result of his tainted reputation.

WHEREFORE, Plaintiff prays this honorable Court to enter a judgment

against Defendant Constance Agregaard awarding compensatory damages in

the amount of $1,100,000.00 plus punitive damages in an amount that will

fairly and reasonably punish Defendant Constance Agregaard for their

conduct, and further ordering Defendant Constance Agregaard to pay

consequential and incidental damages, pre-judgment and post-judgment

interest costs of suit and attorneys fees, and further equitable relief as this

honorable Court deems just.

SECOND CLAIM FOR RELIEF

(Slander Per Se Injury to Personal Reputation)



36. Defendant Constance Agregaards Statements concerned Plaintiff and

was false as a matter of fact.


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37. Defendant Constance Agregaards Statements were widely published




39. Defendant Constance Agregaards Statements were slanderous per se

because they injure

Plaintiffs personal reputation.





actions.

41. Defendant Constance Agregaard false and as a matter of fact charged




42.Defendant Constance Agregaard falsely and as a matter of fact charged

the Plaintiff with raping her asserting as fact that, he raped me,

contrary to and inconsistent with the statements of the bar manager

and her subsequent actions.


permanently damage Plaintiff in the eyes of The University of

Missouri, The Chemistry Department of the University of Missouri,


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The Psychology Department of the University of Missouri, The Women

and Gender Studies Department at the University of Missouri, STOP



Plaintiff as a result of his tainted reputation. The Defendant Constance

Agregaard had dedicated significant time and effort into to the City

and community of Columbia. Defendant Constance Agregaards

statements permanently damage Plaintiffs reputation in Missouri and

all over the world. Plaintiff will soon have to leave the world of

academia and will likely face difficulties in obtaining employment at

another university as a result of Defendant Constance Agregaards

false and defamatory statements.





conduct, and further ordering

Defendant Constance Agregaard to pay consequential and incidental

damages, pre-judgment and post-judgment interest costs of suit and

attorneys fees, and further equitable relief as this honorable Court deems

just.


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THIRD CLAIM FOR RELIEF

(Slander Per Se Accusations of Criminal Conduct)



45. Defendant Constance Agregaards statements concerned Plaintiff and

were false.

46. Defendant Constance Agregaards statements were widely published


47. Defendant Constance Agregaards statements were made with

reckless disregard of their truth or falsity with malice.

48. Defendant Constance Agregaards statements were slanderous per se

because they allege Plaintiff was engaged in criminal conduct.

49.

Defendant Constance Agregaards statements accused Plaintiff of

engaging in a pattern of behavior that is criminal and punishable with

up to 30 years of incarceration at the Missouri Department of

Corrections.





actions.


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contrary to and inconsistent with the statements of our roommates

and coworkers.

53.

Defendant Constance Agregaards statements forever falsely taint and


at large, The Chemistry Department of the University of Missouri, The

Psychology Department of the University of Missouri, the Women and

Gender Studies Department at the University of Missouri, STOP



Plaintiff as a result of his tainted reputation. In addition individuals

will be less likely to associate with






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FOURTH CLAIM FOR RELIEF

(Slander By Implication)

54.

Plaintiff repeats and re-alleges the allegations set forth in paragraphs



indicates the existence of other facts which are defamatory.





58. Defendant Constance Agregaard has no reasonable grounds for

believing the truth of her Statements.


the Plaintiff with stalking her asserting as fact, no prior interaction

with him, he raped me that night, contrary to and inconsistent with


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time stamped photographs that show otherwise and her subsequent

actions.








and co-workers.



at large,

The Chemistry Department of the University of Missouri, The Psychology

Department of the University of Missouri, the Women and Gender

Studies Department at the University of Missouri, STOP TRAFFIC, The

Baptist Student Union, On the Rock Church, PSI CHI, and Green Dot. In

addition individuals will be less likely to associate with Plaintiff as a

result of his tainted reputation. In addition individuals will be less likely

to associate with Plaintiff as a result of his tainted reputation.


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conduct, and further ordering


damages, pre-judgment and post-judgment interest costs of suit and

attorneys fees, and further equitable relief as this honorable Court deems

just.

FIFTH CLAIM FOR RELIEF

(Slander Reckless Disregard/Malice)




was false.



66.

Defendant Constance Agregaards Statements were made with





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actions.






the Plaintiff with getting her drunk and raping her asserting as fact

that, he raped me contrary to and inconsistent with the statements

of the bar manager and the Defendant Constance Agregaards

subsequent actions.



at large, The Chemistry Department of University of Missouri,

The Psychology Department of University of Missouri, the Women and

Gender Studies program at the University of Missouri,

STOP TRAFFIC, The Baptist Student Union, On the Rock Church, PSI CHI,

and Green Dot. In addition individuals will be less likely to associate with

Plaintiff as a result of his tainted reputation. In addition individuals will


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75. Defendant Constance Agregaards Statements were libelous per se

because they injure Plaintiffs professional reputation.





actions.










permanently damage

Plaintiff in the eyes of The University of Missouri at large, The Chemistry

Department of the University of Missouri, The Psychology Department of

the University of Missouri, the Women and Gender Studies Department at

the University of Missouri, STOP TRAFFIC, The Baptist Student Union, On

the Rock Church, PSI CHI, and Green Dot. In addition individuals will be


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less likely to associate with Plaintiff as a result of his tainted reputation.

In addition individuals will be less likely to associate with










SEVENTH CLAIM FOR RELIEF

(Libel Per Se Injury to Personal Reputation)




was false as a matter

of fact.




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84. Defendant Constance Agregaards Statements were libelous per se

because they injure Plaintiffs personal reputation.





actions.



night, contrary to andinconsistent with the events that followed and




that, he raped me, contrary to and inconsistent with the statements

of the bar manager and her subsequent actions.


permanently damage Plaintiff in the eyes of The University of

Missouri, The Chemistry Department of the University of Missouri,

The Psychology Department of the University of Missouri, The Women

and Gender Studies Department at the University of Missouri, STOP


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Plaintiff as a result of his tainted reputation. The Defendant Constance

Agregaard had dedicated significant time and effort into to the City

and community of Columbia. Defendant Constance Agregaards

statements









EIGHTH CLAIM FOR RELIEF

(Libel Per Se Accusations of Criminal Conduct)



90.

Defendant Constance Agregaards statements concerned Plaintiff and

were false.

91. Defendant Constance Agregaards statements were widely published



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92. Defendant Constance Agregaards statements were made with

reckless disregard of their truth or falsity with malice.

93. Defendant Constance Agregaards statements were libelous per se

because they allege Plaintiff was engaged in criminal conduct.

94. Defendant Constance Agregaards statements accused Plaintiff of

engaging in a pattern of behavior that is criminal and punishable with

up to 30 years of incarceration at the Missouri Department of

Corrections.

95.

Defendant Constance Agregaard falsely and as a matter of fact charged




actions.







that, he raped me , contrary to and inconsistent with the statements



permanently damage


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conduct, pre-judgment and postjudgment interest and further ordering


damages, costs of suit and attorneys fees, and further equitable relief as this


NINTH CLAIM FOR RELIEF

(Libel By Implication)

99.

Plaintiff repeats and re-alleges the allegations set forth in paragraphs



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indicates the existence of other facts which are defamatory.





103. Defendant Constance Agregaard has no reasonable grounds for

believing the truth of her Statements.

104.

Defendant Constance Agregaard falsely and as a matter of fact charged




actions.







that, he raped me, contrary to and inconsistent with the statements



permanently damage


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damages, costs of suit and attorneys fees, and further equitable relief as this


TENTH CLAIM FOR RELIEF

(Libel Reckless Disregard/Malice)




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was false.









actions.









115.

Defendant Constance Agregaards statements forever falsely taint andpermanently damage




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damages, costs of suit and attorneys fees, and further equitable relief as th is


ELEVENTH CLAIM FOR RELIEF

(Intentional Infliction of Emotional Distress)



117. Defendant Constance Agregaards Statements and conduct were

extreme and outrageous. So outrageous as to shock any marginally

literate persons sensibilities.


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118. Defendant Constance Agregaards Statements and conduct have

caused Plaintiff to suffer severe emotional stress.





actions.








and our coworkers.

122. Defendant Constance Agregaard knew and intended that Plaintiff

would suffer severe emotional distress as a result of her Statements

and conduct.



the amount of


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$1,100,000.00 plus punitive damages in an amount that will fairly and

reasonably punish Defendant Constance Agregaard for their conduct, pre-

judgment and post-judgment interest and further ordering Defendant

Constance Agregaard to pay consequential and incidental damages, costs of

suit and attorneys fees, special damages, exemplary damages and injunctive

relief that the Defendant Constance Agregaard refrain from further defaming

Salau and further equitable relief as this honorable Court deems just.

Respectfully submitted,

___________________________

Ahmed Salau

Plaintiff Pro Se

P O Box 6008

Princeton, WV 24740Phone) 5403151147 Fax) 5403016034 [email protected]

Dated : Princeton, West Virginia November 27th, 2014.
mailto:[email protected]:[email protected]:[email protected]

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Constance Agregaard Defamation Lawsuit