LUCAS COUNTY COMMON PLEAS COURT OREGON OHIO CIVIL DIVISION, LUCAS COUNTY

Bradley Harper	___05-02-00396_________________ (Case I.D. Number)
Complainant -vs-	For: Violation of Ohio Revised Code 2739.01 Libel.
Sheila O'Fay
Respondent

COMPLAINT-AFFIDAVIT

1. COMES NOW, Plaintiff Bradley Harper ("Harper"), by and through his attorneys, Scott and Free, P.A., and for his Complaint against Defendant Sheila O'Fay ("O'Fay"), alleges as follows:

PARTIES

1. Plaintiff Bradley Harper is an individual residing in Lucas County, Ohio.

1. Defendant Sheila O'Fay is an individual residing in Lucas County, Ohio.

JURIDICTION AND VENUE

1. This court has jurisdiction over this matter pursuant to Ohio Rev. Code 2739.02, as the alleged defamatory publication occurred within Lucas County, Ohio and the parties are residents of Lucas County, Ohio.

1. Venue is proper in Lucas County, Ohio, pursuant to Ohio Revised Code 2739.01, as the events giving rise to the claims asserted herein occurred within Lucas County, Ohio.

FACTUAL ALLEGATIONS

1. Harper is a university football coach at Clay University located in Lucas County, Ohio.
2. O'Fay is a reporter for the university-funded newspaper at Clay University.

1. On February 23^rd, 2024, O'Fay published an article in the Clay Eagles Tribune alleging that Harper made his players shoot steroids.

1. O'Fay's article cited two unnamed sources, who were purportedly football players at Clay University, as the basis for her defamatory statements against Harper.

1. The article further implied that Harper engaged in unethical and illegal conduct by administering steroids to his players, which has caused irreparable harm to Harper's personal and professional reputation.

CAUSE OF ACTION

1. Harper asserts a cause of action against O'Fay for defamation.

1. O'Fay's publication of false and defamatory statements regarding Harper's character and professional conduct constitutes defamation per se under Ohio law.

1. O'Fay acted with actual malice or reckless disregard for the truth by publishing the defamatory statements without conducting adequate investigation or seeking Harper's response prior to publication.

CAUSATION AND DAMAGES

1. As a direct and proximate result of O'Fay's defamatory publication, Harper has suffered and continues to suffer damages to his reputation, emotional distress, and professional standing within the university and broader community.

DEMAND FOR RELIEF

1. WHEREFORE, Plaintiff Bradley Harper respectfully requests that this Court enter judgment in his favor and against Defendant Sheila O'Fay, awarding the following relief:

1. Compensatory damages in an amount to be determined at trial;

1. Punitive damages in an amount to be determined at trial;

1. Costs and attorneys' fees incurred in prosecuting this action; and

1. Such other and further relief as the Court deems just and proper.

JURY DEMAND

1. Plaintiff Bradley Harper hereby demands a trial by jury on all issues so triable.

Respectfully submitted,

Gerard Haddad 66921 Scott and Free, P.A.

1231 South Lallendorf Road Oregon, Ohio 43616

Attorneys for Plaintiff Bradley Harper

How should Don Trump, Sheila O'Fay's counsel, ANSWER this complaint on her behalf denying the allegations?