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Jefferson v. Stripling

Statements made to the State Bar were covered under the Anti-SLAPP statute because such statements were official proceedings authorized under law; however, an evidentiary hearing was required when the plaintiff raised an Anti-SLAPP defense.

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Sherri Jefferson, an attorney representing herself, appeals from the trial court’s dismissal of her complaint for failure to state a claim upon which relief could be granted against three siblings, Frances Stripling, Fanny Salley, and Leroy Engram, whom she accuses of, among other claims, tortious interference with her business or profession, libel and slander. Jefferson represented another sibling, Willie Saby Walkes in disputes arising over the distribution of property from the estates of the siblings’ relatives and her difficulties with Stripling, Salley, and Engram arose from this.

A complaint must contain “a short and plain statement of the claims showing that the pleader is entitled to relief,”1 and “this short and plain statement must include enough detail to afford the defendant fair notice of the nature of the claim and a fair opportunity to frame a responsive pleading.”2 If the complaint gives fair notice, “it should be dismissed for failure to state a claim only if . . . its allegations disclose with certainty that no set of facts consistent with the allegations could be proved that would entitle the plaintiff to the relief she seeks.”3

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