ELECTRONICALLY FILED - 2018 Jul 13 9:29 AM - LEXINGTON - COMMON PLEAS - CASE#2018CP3202393

STATE OF SOUTH CAROLINA IN THE COURT OF COMMON PLEAS

IN THE ELEVENTH CIRCUIT
COUNTY OF LEXINGTON CASE NO. 2018-CP-32-_______

Gregory L. Wright,

Plaintiff,
SUMMONS
v.

Lexington School District Four and Justin Nutter,

Craig Baker, Linda Lavender, Charles Sebok,
Laura Sebok and Gib Lackey in their individual
capacities,

Defendants.

TO THE DEFENDANT ABOVE NAMED:

YOU ARE HEREBY SUMMONED and required to answer the Complaint herein, a copy

of which is served upon you, and to serve a copy of your answer to this Complaint upon the

subscriber at the address shown below within thirty (30) days after service hereof, exclusive of the

date of such service, and if you fail to answer the Complaint, judgment by default will be rendered

against you for the relief demanded in the Complaint.

CROMER BABB PORTER & HICKS, LLC

BY: s/J. Lewis Cromer

J. Lewis Cromer (# 1470)
J. Paul Porter (#100723)
1418 Laurel Street, Suite A
Post Office Box 11675 (29211)
Columbia, South Carolina 29201
Phone 803-799-9530
Fax 803-799-9533

Attorneys for Plaintiff

July 13, 2018
Columbia, South Carolina
 ELECTRONICALLY FILED - 2018 Jul 13 9:29 AM - LEXINGTON - COMMON PLEAS - CASE#2018CP3202393
STATE OF SOUTH CAROLINA IN THE COURT OF COMMON PLEAS
IN THE ELEVENTH CIRCUIT
COUNTY OF LEXINGTON CASE NO. 2018-CP-32-_______

Gregory L. Wright,

Plaintiff,
COMPLAINT
v. (Jury Trial Demanded)

Lexington School District Four and Justin

Nutter, Craig Baker, Linda Lavender, Larry
Sebok, Laura Sebok and Gib Lackey in their
individual capacities,

Defendants.

EMPLOYMENT & DEFAMATION CASE

Plaintiff complaining of the Defendants respectfully alleges as follows.

PARTIES AND JURISDICTION

1. Plaintiff Gregory Wright is a citizen of Lexington County, South Carolina.

2. Defendant Lexington School District Four is a public school district in Lexington

County, South Carolina

3. Defendant Justin Nutter is a citizen and resident of Lexington County and was at

all times mentioned herein the Associate Superintendent of the District.

4. Defendant Craig Baker is a citizen and resident of Lexington County and is

currently appointed Principal at Swansea Middle School.

5. Defendant Linda Lavender is a citizen and resident of Lexington County and was

at all times mentioned herein the Superintendent of the District.

6. Defendant Larry Sebok is a citizen and resident of Lexington County.

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7. Defendant Laura Sebok is a citizen and resident of Lexington County and was at

all times mentioned herein the school nurse of the District.

8. Defendant Gib Lackey is a citizen and resident of Lexington County and was at

all times mentioned herein the Assistant Principal of Swansea High School

FACTUAL OCCURRENCES

9. Plaintiff realleges the foregoing where consistent.

10. Plaintiff is a resident of Lexington, South Carolina and a former athlete on the

football team of the University of South Carolina.

11. After his graduation, the Plaintiff worked as a graduate assistant, was Assistant

Athletic Director at Fairfield Central High School, and then Head Football Coach at Eau

Claire High School in Columbia, South Carolina.

12. Plaintiff became the Head Football Coach and Athletic Director at Swansea High

School three years ago where he undertook to coach a high school football team which

had little success in the years prior to his coming there.

13. In the two years that he coached the Swansea Tigers, he was able to make

substantial progress not only in the level of competition but also in teaching and

promulgating values outside of football to the young people that he coached and taught.

14. In addition to the responsibilities of the Head Football Coach, Swansea made

Plaintiff its Athletic Director with additional duties involving other High School sports,

although the Plaintiff was not afforded any secretarial or outside administrative help for

performance of his duties as was the case prior to his coming to Swansea and is the case

in practically every other situation when Athletic Director and Head Coach positions

are occupied by the same person.

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15. For the first year of the Plaintiff’s work as a coach and teacher, he received praise

and support for his work and no negative discipline or major criticism was ever

expressed concerning the same.

16. In the 2017-2018 football season, however, he began to receive criticism from

parents of one or more of his players that he did not give them sufficient playing time

or felt that their child or children had more talent or skills than the Coach had attributed

to them.

17. Further unjust and falsely inspired criticisms began to emerge, although these

criticisms in no way interfered with the Plaintiff carrying out his duties appropriately.

18. Criticism arose regarding the way that he handled a child who had an indicated

possible concussion in a game. The issue had been raised that he did not properly

safeguard the child and give him the proper protocols under the circumstances

19. Such criticism was baseless, all appropriate precautions were taken, and the

player was held out of practice and games for a period of time to ensure that he would

not be reinjured. It never appeared that he in fact had suffered a concussion.

20. After the end of the football season in 2017, and going into the first couple of

months of 2018, Plaintiff’s problems became acute.

21. Plaintiff began to receive complaints from Defendant Nutter, Defendant Baker,

and others regarding his duties as Athletic Director and Head Football Coach.

22. These complaints claimed excessive expenditures for football uniforms,

complaints and accusations regarding proper paperwork on student athletes, and

continuing criticisms related to the duties of Athletic Director. Plaintiff requested

secretarial help or outside help from the administration but did not receive the same.

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23. In February of 2018, he was notified that he would lose his Athletic Directorship

and only coach and teach for the 2018-2019 year. While this would result in a loss of

income, Plaintiff did not file a formal grievance but rather sought to cooperate with the

District’s administration to resolve the issues before the new contracts came out at the

end of the year.

24. Sadly, the Plaintiff continued to be under undue and continuing harassment and

poor treatment by Defendant Baker and Defendant Nutter, the Associate Superintendent

of the school district.

25. Plaintiff was also receiving considerable criticism and harassment directly and

indirectly through Defendant Lackey and Defendant Laura Sebok whose son also played

on the football team.

26. All of such criticism, harassment, and treatment appeared to be for the purpose

of eliminating the Plaintiff as Head Football Coach.

27. On June 26, 2018, Plaintiff, through his attorney wrote a letter to the District’s

attorney complaining about his losing the Athletic Director’s supplement which he had

just learned had officially occurred a week or two before.

28. On Monday June 25, 2018, the day before the letter, the Plaintiff held a practice

in the Swansea High School football stadium since the practice field was cluttered with

construction at that time. The weather was very warm and all appropriate safeguards

were made assure that the players were rested and hydrated.

29. During the practice, one of the players, the son of Defendant Lackey complained

to the coach that he was feeling dizzy. The coach immediately removed him from the

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practice, gave him ice, and saw that he fully recovered. He was never permitted to return

to the practice even though he asked to do so.

30. Sometime late the next day, Plaintiff was summoned to a meeting with

Defendant Nutter and was terminated by Defendant Nutter and Defendant Lavender,

acting Superintendent of the District, from his job as Head Football Coach on the

grounds that he was grossly negligent in the way that he failed to safeguard his players

along with a litany of false charges and accusations about previous pretextual warnings

and write-ups that he had received from Defendant Nutter and others.

31. As a result of this termination, brought about by false and pretextual charges

made by Defendant Laura Sebok, Defendant Nutter, Craig Baker, and Larry Sebok,

another disgruntled parent and others, the Plaintiff has now been reduced to teaching

duties in the middle school by the District and his opportunity to coach not only for this

year but in future years has been greatly damaged along with other damages that are set

forth later herein.

FIRST CAUSE OF ACTION

AGAINST THE DISTRICT
(DEFAMATION)

32. Plaintiff realleges the foregoing where consistent.

33. The Defendant District, through its agents and employees, made comments and

took actions to directly state and insinuate that the Plaintiff was unfit for his job, that he

violated the criminal laws of the State of South Carolina and the policies of the School

Board, and that he deserved to be removed from his position therewith.

34. These comments, statements, verbal and in writing including written and oral

communications and actions by the Defendant District in terminating Plaintiff on

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pretextual grounds and commentary to the media were made to unprivileged third-

parties, and throughout Lexington County were made more broadly by publicly

accessible media. Such publications were false, defamatory per se, and made with

malice. Plaintiff can name some of the recipients of the defamatory publications and

will do so in response to appropriate discovery requests. The Defendant is liable for the

defamatory conduct and statements described herein and above.

35. Such statements were knowingly false and were made with reckless disregard

for the truth. Such statements were malicious and have harmed Plaintiff’s reputation and

lessened him esteem in his profession.

36. Plaintiff, as a direct and proximate result of the defamation alleged herein, is

entitled to damages directly and proximately caused by the Defendant District.

37. Such damages include special harm including a decreased earning capacity, loss

of good will, reputational loss, and pain and suffering. Plaintiff is also entitled to

reasonable attorney’s fees and costs pursuant to state law and prejudgment interest.

SECOND CAUSE OF ACTION

AGAINST THE INDIVIDUAL DEFENDANTS
(DEFAMATION)

38. Plaintiff realleges the foregoing where consistent.

39. The individual Defendants Nutter, Baker, Lavender, and Laura Sebok, as well as

others, acting within the course and scope of their employment have falsely accused the

Plaintiff of incompetence, negligence, violations of laws and policies on numerous

occasions to numerous persons which are outside of the District.

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40. The insinuations flowing from the above statements that Plaintiff was an unfit

coach and administrator and engaged in criminal or illegal conduct were false and made

without justification.

41. The same has lessened Plaintiff’s reputation in his profession and is defamatory

per se.

42. The above statements were made with malice and reckless disregard for the truth

and are defamatory per se.

43. Those statements have resulted in damages to the Plaintiff to include:

reputational loss, lost goodwill, diminished earning capacity, shock, humiliation, and

pain and suffering.

44. Further, the extensive and excessive publication of the reasons for Plaintiff’s

removal as Head Football Coach and Athletic Director which were also false and

defamatory constitute defamation by actions as well as words.

45. That as a direct and proximate result of the defamatory words and actions, the

Plaintiff has sustained loss of income and earning capacity, loss of reputation,

embarrassment and humiliation and pain and suffering all of which will continue in the

future.

THIRD CAUSE OF ACTION

AGAINST THE INDIVIDUAL DEFENDANTS
(CIVIL CONSPIRACY)

46. Plaintiff realleges the foregoing where consistent herewith.

47. The individual Defendants and others combined to harm Plaintiff constituting an

unlawful civil conspiracy.

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48. In furtherance of their conspiracy, Defendants Nutter, Baker, Lavender and

Laura Sebok took actions outside the course and scope of their employment with the

District to make Plaintiff appear complicit in wrongs that he did not commit. Defendant

Sebok and others outside the scope of any agency or employment by the Defendant

District, met and schemed with District officials and others to disparage and defame the

Plaintiff and cause him special damages.

49. The circumstances of their actions and shared objective of harming the Plaintiff

reveal an unlawful civil conspiracy.

50. The individual Defendants’ conduct has caused the Plaintiff special damages

including: he has lost the opportunity to be a Head Football Coach, he has been

ostracized in his field of athletics and education and has limited availability of

alternative opportunities in his specialized field, he has suffered loss of sleep and

companionship, and sever stress, anxiety, and related ailments.

FOURTH CAUSE OF ACTION

AGAINST DEFENDANTS JUSTIN NUTTER, CRAIG BAKER,
LARRY SEBOK, LAURA SEBOK, AND GIB LACKEY
(INTERFERENCE WITH CONTRACTUAL RELATIONS)

51. Plaintiff realleges the foregoing where consistent herewith.

52. The individual Defendants Justin Nutter, Craig Baker, Larry and Laura Sebok

and Gib Lackey were aware of Plaintiff’s employment relationship with his employer,

the District.

53. Such Defendants unjustifiably interfered with that contractual relationship when

they informed Plaintiff’s supervisor and others with the District that Plaintiff was not

performing his duties properly, was violating policies and regulations and was not fit

for his position as coach and athletic director, all leading up to the Plaintiff’s

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unjustifiable termination as Head Football Coach at Swansea High School and the

proximate damages attendant thereto.

54. Such Defendants unjustifiably interfered with that contractual relationship in

violation of state law.

55. Such Defendants have procured the breach of that contractual relationship

insomuch as Plaintiff has lost his head coaching position with the Defendant District.

56. Further, the Defendants’ actions were outside the course and scope of their

employment

57. As such, Plaintiff is entitled to recover all damages resulting from such

Defendants jointly and severally, for the interference alleged her to include: diminished

earning capacity, lost wages, lost benefits, embarrassment, shock, humiliation, pain and

suffering, reputational loss, and loss of good will.

58. To the extent such Defendants are proven to have engaged in malicious conduct

with respect to this claim, Plaintiff is entitled to an award of punitive damages as well.

WHEREFORE, Plaintiff prays for judgment against all Defendants, where sought, in an

amount to be determined reasonable by a jury not to exceed Three Hundred Thousand Dollars

($300,000.00) actual damages.

Plaintiff requests an award of punitive damages to be assessed by a jury in an amount

deemed appropriate against the individual Defendants where sought. Plaintiff also prays for the

costs, attorney’s fees and expenses of this action. Plaintiff asks that where claims are alleged jointly

against parties, that any award of damaged be awarded jointly and severally. Plaintiff seeks pre-

judgment interests on all damages. Plaintiff last seeks whatever other equitable relief justice

requires.

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CROMER BABB PORTER & HICKS, LLC

BY: s/J. Lewis Cromer

J. Lewis Cromer (# 1470)
J. Paul Porter (#100723)
1418 Laurel Street, Suite A
Post Office Box 11675 (29211)
Columbia, South Carolina 29201
Phone 803-799-9530
Fax 803-799-9533

Attorneys for Plaintiff

July 13, 2018

Columbia, South Carolina

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