UNITED STATE DISTRICT COURT PHAEDRA C. PARKS, · PDF fileUNITED STATE DISTRICT COURT NORTHERN...
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UNITED STATE DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION PHAEDRA C. PARKS, ) ) Plaintiff, ) ) Case No. ___________________ v. ) ) TRIAL BY JURY DEMANDED VIBE HOLDINGS, LLC, ) ) Defendant. ) COMPLAINT FOR DEFAMATION COMES NOW Plaintiff, Phaedra C. Parks, and respectfully states her Complaint for Defamation against Defendant, Vibe Holdings, LLC, as follows: INTRODUCTION 1. This Complaint arises from publication by Defendant of multiple false and defamatory statements of and concerning Phaedra C. Parks. 2. The false and defamatory statements published by Defendant conveyed to the average listener or reader that Plaintiff is a criminal, guilty of active participation in numerous felony crimes. 3. The false and defamatory accusations were published online to generate interest in, and increase sales of, a subsequently published book by Defendant that would repeat and expand on the online statements. Case 1:12-mi-99999-UNA Document 1024 Filed 05/22/12 Page 1 of 29
