alt:
"Mr. Pool was damaged by the Harris Campaign's bad faith misconduct as
previously described herein in addition to his expenditures for the prosecution of this cause of
action, which is necessary to clear Mr. Pool's name and restore his reputation.
54. The Harris Campaign's bad faith misconduct triggers this State's exception to the
American Rule for payment of attorney's fees, as described in Syl. Pt. 3, Sally-Mike Properties v.
Yokum, 179 W.Va. 48, 365 S.E.2d 246 (1986) et al.
The Harris Campaign's pre-litigation misconduct likewise triggers the exception
to the American Rule for payment of attorney's fees, as described in In re John T, 225 W.Va.
638, 695 S.E.2d 868 (2010) et al. as the misconduct, among other things, caused Mr. Pool to
incur legal expenses he would not otherwise have to pay."