VIRGINIA: IN THE CIRCUIT COURT OF THE CITY OF ALEXANDRIA ERIC J. BONETTI, Plaintiff, CIVIL ACTION NUMBER:
vs. GRACE EPISCOPAL CHURCH Defendant
COMPLAINT Eric J. Bonetti, in support of his Complaint against defendant Grace Episcopal Church, states the following: NATURE OF THE ACTION 1.
This is an action for defamation and defamation per se.
2.
In an email dated November 22, 2017, Grace Episcopal Church, acting through its agent Kelly
Gable and employee Robert H. Malm, sent an email to staff of the Episcopal Diocese of Virginia stating that plaintiff had embezzled money from a previous employer. Exhibit 1. 3.
The claim in the email referenced above was knowingly false.
4.
Mr. Malm demonstrated actual malice when he lied to diocesan staff, stating that Plaintiff’s
departure from the previous employer occurred prior to Plaintiff’s arrival at Grace Episcopal Church. 5.
Mr. Malm, a member of the clergy, knew that the statement about the timing of Plaintiff’s
departure from his previous employer was false when he made it, for he had discussed the matter repeatedly with Plaintiff and others, including church officer Elizabeth Legere. 6.
An action for defamation would ordinarily be time-barred by Virginia’s one-year statute of
limitations, as set forth at Va. Code § 8.01-247.1. 7.
Pursuant to Va. Code 8.01-229(C) the statute of limitations is tolled when the an injunction
delays filing of a claim. 8.
An injunction, in the form of a protective order, was in place from a date on or about January 27,
2018 to January 27, 2020. This order prevented contact with Mr. Malm and was obtained by him via a series of false and misleading statements to the courts. Exhibit 2.
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