IN THE CIRCUIT COURT FOR CHEATHAM COUNTY 23® JUDICIAL DISTRICT, ASHLAND CITY, TENNESSEE FILED CHIP RONEY, ) SEP LY 2m Plaintiff, ) JULIE HIBBS v ) ‘CIRCUIT COURT CLERK ) JENNIFER HAMBLIN, ) Defendant. )Docket Nox _GYSF COMPLAINT FOR DAMAGE! (LIEF Comes now Plaintiff, Chip Roney, and sues the Defendant for slander, defamation, false light, intentional infliction of emotion distress, intentional interference with a contract, and for injunctive relief as follows: 1. The Plaintiff, Chip Roney, is a resident of Montgomery County, Tennessee, and works in Cheatham County, Tennessee. 2. Based upon information and belief, the Defendant, Jennifer Hamblin, is a citizen and resident of Cheatham County, Tennessee. 3. Defendant specifically is a member of the Cheatham County Board of Education for the 3" District. 4, Plaintiff specifically is the principal of Ashland City Elementary School and the principal of Riverside Academy, both in Cheatham County, Tennessee. He has been employed by the Cheatham County School District for a number of years and has been well regarded in his position. 5. Defendant has undertaken to publish to numerous persons false information regarding Mr. Roney, which has the potential to affect Mr. Roney’s employment. Page 1 of 7| i ‘The Defendant has expressed her intent to have Mr. Roney removed as the Principal. Defendant has made negative and harmful statements to Mr. Roney’s employers, superiors, coworkers, and others which display Mr. Roney in a negative manner and which have no basis in fact. 6. Defendant has specifically made these statements to both the interim Director of Schools, Stacy Brinkley, and to the current Director of Schools, Cathy Beck, as well as to numerous other individuals within the Cheatham County School System. 7. Defendant's statements have included stating that Mr. Roney was no longer employed by the Montgomery County School System because he had sexual relationship(s) with student(s). This is not true. The Defendant has also stated Mr. Roney engaged in a sexual relationship with a student, which resulted in a child being born, and that Mr. Roney ‘was present in the emergency room when the child was born, This is not true. These statements were made by the Defendant to numerous individuals, including the Directors of Schools. 8. Defendant’s statements have also included stating that Mr. Roney had a “green room” in the library of one of his schools, in which he and teachers would exchange sexual favors. This is not true. This statement was made by the Defendant to numerous individuals, including the Directors of Schools. 9. As a result of the green room allegation made by the Defendant, interim Director of School Stacy Brinkley conducted an investigation into the allegation, which included discussion with a previous librarian. The allegation was found to be untrue. Page 2 of 7oa ari 10. Defendant's statements have also included stating that Mr. Roney is here, but that is a different story and only for the time being. Defendant made this statement, threatening the longevity of Mr. Roncy’s employment with the Cheatham County School System, in front of multiple individuals. This statement was interjected into a conversation ‘Mr. Roney was having with another individual. This statement had no basis in fact. 11, The Defendantapproached other individuals within the Cheatham County School System and requested they not allow Mr. Roney to speak to her again; however, Mr. Roney had not, in fact, spoken to the Defendant. 12. Another incident with the Defendant involved a report of yelling outside of a School Board meeting. When the School Resource Officers went outside and questioned whether everything was alright, the Defendant stated that everything was okay as Jong as he kept Mr. Roney inside. At the time, Mr. Roney was in the Board Room and not in the vicinity of the Defendant or the disturbance. 13. Multiple false and negative statements about Mr. Roney have been made by the Defendant, to numerous individuals, both within and not within the Cheatham County School System, 14, Mr. Roney respectfully seeks an injunction barring the Defendant from making further false and negative statement and from further interference with his contract for employment. Mr, Roney also respectfully seeks damages against the Defendant. COUNT 1: SLANDER AND DEFAMATION 15. Plaintiff sues the Defendant for slander and defamation, as the Defendant Page 3 of 7