Constance Agregaard Defamation Lawsuit

IN UNITED STATES DISTRICT COURT FOR THE DISTRICT OF
ARIZONA
PHOENIX ARIZONA DIVISION
AHMED SALAU,
P. O. BOX 6008,
PRINCETON, WV 24740.
Case No.
)
Plaintiff, pro se
)
)
vs.
COMPLAINT
)
CONSTANCE AGREGAARD,
C/O MG Robert Ashley, Jr.,

448 Christy Avenue,
Building 22408,
Fort Huachuca, AZ 85613
JURY TRIAL DEMANDED
)
)
)
Defendant
Constance
Agregaard.
COMPLAINT
Plaintiff Ahmed Salau, pro se, for his complaint alleges as follows:
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.
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.
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 1st 2012, Plaintiff and the Defendant

Constance Agregaard start a consensual romantic relationship & move
in together.
5.
On or about September 15th 2012, Petitioner and Defendant Constance

Agregaard meet Plaintiffs family and Defendant Constance
Agregaards family.
6.
On or about September 30th 2012, 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 1st 2012, the Plaintiff and the Defendant

Constance Agregaard visit Plaintiffs attorney friend Olayinka Hamza
for the weekend.
8.
9.
On or about October 12th 2012, Plaintiff and the Defendant Constance

Agregaard decide to break up.
On or about October 14th 2012, 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 19th 2012, the Plaintiff is arrested by the Police

Department and is in jail for seven months.
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
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 Agregaards

Statements.
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.
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.
33.

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
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)
35.

36.
Defendant Constance Agregaards Statements concerned Plaintiff and

was false as a matter of fact.
37.

38.

39.
Defendant Constance Agregaards Statements were slanderous per se

because they injure
Plaintiffs personal reputation.
40.

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.
43.

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
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.
THIRD CLAIM FOR RELIEF

(Slander Per Se Accusations of Criminal Conduct)
44.

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.
50.

actions.
51.

52.

contrary to and inconsistent with the statements of our roommates
and coworkers.
53.

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


FOURTH CLAIM FOR RELIEF

(Slander By Implication)
54.

55.

indicates the existence of other facts which are defamatory.
56.

57.

58.
Defendant Constance Agregaard has no reasonable grounds for

believing the truth of her Statements.
59.

the Plaintiff with stalking 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.
60.

61.

and co-workers.
62.

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.

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)
63.

64.

was false.
65.

66.

67.


actions.
68.

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.
70.

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

reputation.

SIXTH CLAIM FOR RELIEF

(Libel Per Se Injury to Professional Reputation)
71.

72.

was false.
73.

74.

75.
Defendant Constance Agregaards Statements were libelous per se

because they injure Plaintiffs professional reputation.
76.

actions.
77.

78.

79.

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
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)
80.

81.

was false as a matter
of fact.
82.

83.

84.
Defendant Constance Agregaards Statements were libelous per se

because they injure Plaintiffs personal reputation.
85.

actions.
86.

that, he raped me, contrary to and inconsistent with the statements
of the bar manager and her subsequent actions.
88.

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
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)
89.

90.
Defendant Constance Agregaards statements concerned Plaintiff and

were false.
91.
Defendant Constance Agregaards statements were widely published

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.

actions.
96.

97.

that, he raped me , contrary to and inconsistent with the statements
98.

permanently damage


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.

100.

indicates the existence of other facts which are defamatory.
101.

102.

103.
Defendant Constance Agregaard has no reasonable grounds for

believing the truth of her Statements.
104.

actions.
105.

106.

that, he raped me, contrary to and inconsistent with the statements
107.

permanently damage


TENTH CLAIM FOR RELIEF
(Libel Reckless Disregard/Malice)
108.
109.

was false.
110.

111.

112.

actions.
113.

114.

115.

permanently damage



ELEVENTH CLAIM FOR RELIEF
(Intentional Infliction of Emotional Distress)
116.

117. Defendant Constance Agregaards Statements and conduct were
extreme and outrageous. So outrageous as to shock any marginally
literate persons sensibilities.
118.
Defendant Constance Agregaards Statements and conduct have

caused Plaintiff to suffer severe emotional stress.
119.

actions.
120.

121.

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

reasonably punish Defendant Constance Agregaard for their conduct, prejudgment 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 24740
Phone) 5403151147 Fax) 5403016034 ahmed@ahmedsalau.com
Dated : Princeton, West Virginia November 27th, 2014.

Constance Agregaard Defamation Lawsuit

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Constance Agregaard Defamation Lawsuit

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IN UNITED STATES DISTRICT COURT FOR THE DISTRICT OF

C/O MG Robert Ashley, Jr.,

JURY TRIAL DEMANDED

NATURE OF THE CAUSE

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

JURISDICTION AND VENUE

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

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

2. Defendant Constance Agregaard, Constance Agregaard is a natural

On or about August 2012, Plaintiff and the Defendant Constance

On or about September 1st 2012, Plaintiff and the Defendant

On or about September 15th 2012, Petitioner and Defendant Constance

On or about September 30th 2012, Plaintiff and Defendant Constance

On or about October 1st 2012, the Plaintiff and the Defendant

On or about October 12th 2012, Plaintiff and the Defendant Constance

On or about October 19th 2012, the Plaintiff is arrested by the Police

In May 2013, the Defendant Constance Agregaard recanted her

The Defendant Constance Agregaard continues to make these false

Plaintiff was informed by Mr. Lowe that the Defendant Constance

The Defendant Constance Agregaards statements have been widely

The Plaintiff is forever damaged by these statements.

The stigma caused by her statements has completely destroyed the

The Defendant Constance Agregaard ended up keeping the child and

Several members of STOP TRAFFIC and Women and Gender Studies

Several members of Plaintiffs church The Baptist Student Union have

Several co-workers and supervisors have heard Defendant Constance

Plaintiffs Advisors have heard Defendant Constance Agregaards

Members of PSI CHI have heard Defendant Constance Agregaards

Members of Green Dot have heard Defendant Constance Agregaards

Members of On the Rock have heard Defendant Constance Agregaards

Plaintiff never raped Defendant Constance Agregaard.

CLAIMS FOR RELIEF

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

Defendant Constance Agregaards Statements and publications

Defendant Constance Agregaards Statements were widely published

Defendant Constance Agregaards Statements were made with

Defendant Constance Agregaards Statements were slanderous per se

Defendant Constance Agregaard falsely and as a matter of fact charged

Defendant Constance Agregaard falsely and as a matter of fact charged

Defendant Constance Agregaards statements forever falsely taint and

Gender Studies Department at the University of Missouri, STOP

WHEREFORE, Plaintiff prays this honorable Court to enter a judgment

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

Defendant Constance Agregaards Statements concerned Plaintiff and

Defendant Constance Agregaards Statements were widely published

Defendant Constance Agregaards Statements were made with

Defendant Constance Agregaards Statements were slanderous per se

Defendant Constance Agregaard falsely and as a matter of fact charged

Defendant Constance Agregaard false and as a matter of fact charged

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

Defendant Constance Agregaards statements forever falsely taint and

The Psychology Department of the University of Missouri, The Women

WHEREFORE, Plaintiff prays this honorable Court to enter a judgment

THIRD CLAIM FOR RELIEF

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

Defendant Constance Agregaards statements concerned Plaintiff and

Defendant Constance Agregaards statements were widely published

Defendant Constance Agregaards statements were made with

Defendant Constance Agregaards statements were slanderous per se

Defendant Constance Agregaards statements accused Plaintiff of

Defendant Constance Agregaard falsely and as a matter of fact charged

Defendant Constance Agregaard false and as a matter of fact charged

Defendant Constance Agregaard falsely and as a matter of fact charged

Defendant Constance Agregaards statements forever falsely taint and