Bradley Harper is turning out to be an active client. He is impatient to see the answer of the defendant, O'Fay, to your defamation complaint. He asked me to draft a sample answer to his complaint so he can be prepared for the actual response. My supervising attorney , Gerard Haddad, directs me to draft a sample answer as can be expected from O'Fay's counsel, Don Trumpo, and based on the facts of the case and applicable legal standards.

Complaint submitted by me on behalf of Bradley Harper

FACTUAL ALLEGATIONS

1. Harper is a university football coach at Clay University located in Lucas County, Ohio.

1. 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.

Don Trumpo needs to answer this complaint on behalf of Sheila Harper. How would I draft a rough response for Bradley Harper to see?