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PLAINTIFF-COUNTER DEFENDANT
case that asserts claims for tortious interference with the marriage contract and reckless
infliction of emotional distress.
2.
The Mississippi Supreme Court has found that a claim for tortious
interference with a marriage contract does not exist. Carter v. Reddix, 115 So. 3d 851,
855 (Miss. 2012). As such, it should be dismissed.
3.
The Mississippi Supreme Court has found that a claim for reckless
infliction of emotional distress does not exist; however, based on the pleadings the
Court could consider the claim to be one for intentional infliction of emotional distress
and/or negligent infliction of emotional distress. Brent v. Mathis, 2014 Miss. LEXIS 557
*16-17 (Miss. November 6, 2014).
4.
the benefit of the doubt it is possible she could be pursuing claims for both negligent
claim, it should be dismissed as she fails to identify any facts that require Defendant
Barnett to owe her any duty of care.
6.
claim, it should be dismissed as she fails to identify any facts that support a finding that
(1) Defendant Barnett took any action directly toward Defendant Martin, and (2)
Defendant Barnetts actions are extreme and/or outrageous as Defendant Martin admits
that Precious Martin allegedly agreed to have an adulterous affair with Defendant
Barnett. Brent v. Mathis, 2014 Miss. LEXIS 557 *21 (Miss. November 6, 2014).
7.
s/ NICK NORRIS
NICK NORRIS (MB No. 101574)
LOUIS H. WATSON, JR. (MB No. 9053)
ATTORNEYS FOR DEFENDANT BARNETT
OF COUNSEL:
WATSON & NORRIS, PLLC
1880 Lakeland Drive
Suite G
Jackson, MS 39216
-2-
CERTIFICATE OF SERVICE
I, Nick Norris, attorney for Defendants/Counter-Plaintiffs, do hereby certify that I
have this day served a true and correct copy of the above and foregoing document via
ECF filing or United States Mail, postage prepaid, on all counsel of record.
s/ Nick Norris
NICK NORRIS
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