The amended and more detailed complaint obtained by PEOPLE largely alleges Kelly, 31, “stimulated controversy for the purpose of making money” and promoting her upcoming book, There’s No F—ing Secret. The complaint lists three causes of action: public disclosure of private facts, negligent interference with prospective economic relations and intentional infliction of emotional distress.
Pugh, a hairdresser in Los Angeles, had a four-year affair with Ozzy, 67, which was revealed earlier this year.
Pugh’s attorney Edie Mermelstein tells PEOPLE in a statement: “Yes, we have free speech in this country but when speech is hate speech or it’s defamatory or incites bullying or discloses personal information that’s when it rises to a different level. Kelly published Michelle’s private information.”
According to the court documents, Pugh claims Kelly used her Twitter account to “paint a target” on Pugh’s back “as a publicity stunt for financial gain” by tweeting out Pugh’s direct phone number and accusing her of “elder abuse” when news of the affair was breaking in May.
Pugh also repeats her initial complaint that Kelly disregarded Twitter’s policies, as well as the cease and desist letter Pugh’s legal team sent her.
In regard to the “publicity stunt,” Pugh alleges Kelly obtained her private landline by using software to unblock unlisted numbers “for strategic publicity purposes and financial gain.” Notably, the complaint points out that Kelly’s book deal was announced less than a month after the Twitter drama, which Pugh believes was a “choreographed media play.”
Pugh claims Kelly “violated her right to privacy,” impacted her ability to obtain work and caused her “severe emotional distress.”
The complaint also takes aim at Ozzy, claiming he led Pugh to believe he was preparing to divorce Sharon and “continually wooed [her] with false promises and false representations as well as requiring complete discretion regarding their relationship.”
Pugh also alleges that Ozzy moving out of the family home in early May was “due to Sharon and Ozzy’s arguments involving financial issues and control, not Ozzy’s infidelity.”
“The relationship was mistakenly characterized as a short term fling and the catalyst to the Sharon/Ozzy divorce rumors,” reads the complaint.
In August, Pugh exclusively opened up to PEOPLE about the affair, saying she didn’t “regret anything.”
“You happen to meet someone and you have an amazing connection and it’s not desirable to act upon it. End of story,” she said. “Do I realize that certain people will not understand? Yes. I am not asking for anyone’s approval.”
“Love is never a mistake,” she said. “Even when it’s messy and even when it hurts.”
A rep for Kelly did not immediately respond to PEOPLE’s request for comment.
• With LIZ McNEIL