Declaration in Lackey v. Metropolitan Life Ins. Co., 174 S.W.2d 575 (Tenn.
Ct. App. 1943)
"Now, in order to beat down, destroy and put out of business the plaintiff and to keep the public from being informed that these old lapsed policies do have a value, the Metropolitan Life Insurance Company, through its representatives, J. I. Lasky, H. G. Bland, acting within the scope of their authority, have, on many and different occasions, falsely and maliciously charged the plaintiff of larceny, stating that he was a thief, a robber, a crook, that he was operating a racket; further that he was crazy and that if they let him collect their money for them they would not get anything from him, that he would take it all and they would get nothing, and further, that he was in the chain gang, that they had padlocked his door, and closed up his business and that they were going to put him in the penitentiary; and, in particular on or about the 15th day of April, 1939, the defendant, by its agent, H. G. Bland, falsely and maliciously stated to one Della Dickerson and her husband, James Dickerson, that the plaintiff was a crook, that he was robbing the public, and that he would take all the money and give them nothing, and that he was running a racket, that he was a crazy dog, that he was in the chain gang, that they were going to put him out of business and put him in the penitentiary where he belonged; and on many prior and subsequent occasions the defendant had falsely and maliciously repeated these same statements through its agents, to many other people with whom the plaintiff has had business dealings, all these statements were made with the intention to, and calculated to do, and has resulted in, irreparable damage to the plaintiff's business and reputation, and has caused and resulted in mental anguish, strained and unfriendly relations with many of the persons with whom he has dealings. The conduct and actions and false and malicious statements of the said defendant, through its agents, concerning and about the plaintiff, has alienated the people with whom he has had business relations and the public in general." Id. at 577-578.