Plaintiff repeats, realleges, and incorporates herein by this reference the allegations hereinabove inclusively as though set forth at length and in full herein.
Plaintiff is a homeowner in good standing of Sun City Anthem since 2/20/04.
Defendants, and each of them, made at least one false statement of fact to a third party that interferes with the Plaintiff’s quiet enjoyment of her property, her good name in the community, and her rights as a Sun City Anthem homeowner (each a “Defamatory Statement”).
Each Defamatory Statement constitutes a non-privileged publication to a third party. Each Defamatory Statement was made with malice. Plaintiff suffered special damages due to each Defamatory Statement. As a direct, proximate, and foreseeable result of Defendants’ acts, Plaintiff has been damaged in excess of $15,000, and in an amount to be determined at the time of trial.
Defendants’ acts were committed with fraud, oppression, and/or malice, entitling Plaintiff to punitive damages pursuant to NRS 42.005 in an amount to be determined at the time of trial.
As a direct, proximate, and foreseeable result of the Defendants’ acts, it has become necessary for Plaintiff to secure the services of an attorney, and Plaintiff is entitled to recover fees and costs incurred herein as damages.
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