Case 1:09-cv-00752-HTW Document 20-2 Filed 06/07/10 Page 1 of 18

IN THE SUPERIOR COURT OF FULTON COUNTY STATE OF GEORGIA

JAMES J. MURTAGH, M.D. Plaintiff, v.

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)

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CIVIL ACTION FILE NUMBER:

) ) FULTON-DEKALB HOSPITAL ) AUTHORITY, EMORY UNIVERSITY, ) EMORY HEALTHCARE, INC., GRADY ) HEALTH SERVICES COMPANY, INC., )

JOHNDOES 1-10 Defendants,

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)

COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL COMES NOW the Plaintiff, JAMES J. MURTAGH, M.D., and for his Complaint for Damages against Defendants Fulton-Dekalb Hospital Authority, Emory University, Emory Healthcare, Inc., Grady Health Services Company, Inc. and John Does 1 through 10 alleges as follows: INTRODUCTION 1.) This case involves the malicious slander of the Plaintiff, James J. Murtagh, M.D., by

representatives of Defendants Fulton-Dekalb Hospital Authority, Emory University, Emory Healthcare, Inc., Grady Health Services Company, Inc. and John Does 1 through 10 who at all times acted on behalf of and with the authority of said Defendants. The Defendants' defamation of the Plaintiff occurred as part of a concerted and ongoing effort by the Defendants to destroy Dr. Murtagh's personal and professional reputation, to intentionally and wrongfully interfere with the Plaintiffs valuable business and professional relationships and to interfere with and to disrupt the Plaintiffs ability to practice medicine. The Defendants' wrongful actions were also intended to, and

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did, inflict severe emotional distress on the Plaintiff. As a result of the Defendants' wrongful acts alleged herein, the Plaintiff has sustained, is sustaining and will sustain in the future substantial and ongoing damages in excess of $1,000,000. The Plaintiff seeks damages for defamation, for intentional interference with advantageous business relationships, for intentional infliction of emotional distress and for malicious injury to his business. THE PARTIES
2.)

The Plaintiff, James J. Murtagh, M.D., is natural person residing at 511Calibre Woods,

Atlanta, DeKalb County, Georgia. 3-1 The Defendant, Fulton-Dekalb Hospital Authority ("Fulton-Dekalb"), is an Atlanta,

Georgia volunteer board that governs Grady Health System which in turn operates Grady Memorial Hospital. Fulton-Dekalb may be served with process by serving Robert L. Brown, Jr., Chairman of the Board of Trustees, at Fulton-Dekalb's principal place of business, 80 Jesse Hill Jr. Drive, Atlanta, Fulton County, Georgia 30303.
4.1

The Defendant, Grady Health Services Company, Inc. is a corporationorganized and

existing under the laws of the State of Georgia which operates Grady Memorial Hospital. Grady may be served with process by serving Timothy Jefferson, its registered agent, at Grady's principal place of business located at 80 Jesse Hill Jr. Drive, Atlanta, Fulton County, Georgia 30303. All acts of the representatives of Fulton-Dekalb and of Grady Health Services Company, Inc. were performed by and on behalf of both Fulton-Dekalb and Grady Health Services Company, Inc. Accordingly, Fulton-Dekalb and Grady Health Services Company, Inc. are collectively referred to herein as "Grady".
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a)

The Defendant, Emory University, is a domestic non-profit corporation organized and

existing under the laws of the State of Georgia, with its principal place of business at 1380 Oxford

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Road N.E., Atlanta, Dekalb County, Georgia, 30322. Emory Universitymay be served withprocess by serving Stephen D. Sencer, its registered agent, at 201 Dowman Drive, 101 Administration Building, Atlanta, Dekalb County, Georgia 30322. The Emory School of Medicine is apart ofEmory University.

6.)

The Defendant, Emory Heathcare, Inc. is a domestic non-profit corporation

organized and existing under the laws of the State of Georgia, with its principal place of business at 201 Dowman Dr. N.E., Atlanta, Dekalb County, Georgia, 30322. Emory Heathcare, Inc may be served with process by serving Jane E. Jordan, its registered agent, at 201 Dowman Dr. 101 Administrative Building, Atlanta, Dekalb County, Georgia 30322. Emory Heathcare, Inc operates the Emory University Hospital. All acts of the representatives of Emory Heathcare, Inc and Emory University were performed by and on behalf of both Emory Heathcare, Inc and Emory University. Accordingly, Emory Heathcare, Inc and Emory University are collectively referred to herein as "Emory".

7,)

The Defendants, John Does 1 through 10, are individuals or entities who committed,

or are otherwise liable for, the acts alleged herein.

JURISDICTION AND VENUE

8 .)

This is an action for damages and is within the jurisdiction of this Court. Venue is

proper in Fulton County, Georgia because the principal place of business and residence of Defendants Fulton-Dekalb Hospital Authority and Grady Health Services Company, Inc. ("Grady") is located in Fulton County and the Defendants Grady and Emory are joint tort-feasors.

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THE FACTS
9.) The Plaintiff is a licensed medical doctor who is Board Certified in Pulmonary

Medicine and Internal Medicine, and has been Board Eligible in Sleep Medicine. Dr. Murtagh graduated from the University of Michigan Medical School with honors in 1982 and successfully completed residencies in Internal Medicine at Parkland Hospital in Dallas, Texas in 1985, followed by the successful completion of a fellowship in Pulmonary Medicine at the University of Michigan at

Ann Arbor, Michigan and the National Institute of Health in Bethesda, Maryland in 1987. From
1985 to until 1991, Dr. Murtagh was employed by the National Institute of Health where he conducted scientific and medical research in the area of Pulmonary Molecular Medicine. Dr. Murtagh has published learned treatises in the areas of his specialty. 10.) In 1991,Dr. Murtagh was recruited by the Emory University School of Medicine,

became employed there as an assistant professor of medicine, and was promoted to associate professor with tenure in 1995. The Emory University School of Medicine operates physician residency programs at various hospitals in the Atlanta, Georgia area, including the Veterans Administration Hospital and Grady Memorial Hospital. As part of his duties as a professor at the
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Emory University School of Medicine, Dr. Murtagh trained residents in the specialties of internal medicine and pulmonary medicine and treated patients at the Veterans Administration Hospital and at Grady Memorial Hospital. 11.) The Plaintiff has also pursued additional medical education and training, and

acquired experience as a practitioner in sleep medicine, which is an area of internal medicine that is closely related to Dr. Murtagh's specialty of pulmonary medicine. In December 2003, Dr. Murtagh was Board Eligible in Sleep Medicine. 12.) The wrongful acts of the Defendants alleged herein were intentionally committed

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to damage Dr. Murtagh's personal and professional reputation in the medical and health care business communities within and outside of the Atlanta area. The Defendants' wrongful acts were further committed in order to interfere with Dr. Murtagh's ability to practice medicine in his chosen fields by, including but not limited to, falselyrepresentingto otherphysicians,hospital medical staffs and health care businesses that Dr. Murtagh is mentally incapable of effectivelypracticing medicine, that Dr. Murtagh was properly subjected to an adverse final peer review andlor medical review committee action while on the medical staff of one or more hospitals at which the Emory University Medical School operates residency programs and that Dr. Murtagh was terminated for just cause from the Emory University Medical School. In addition, the Defendants wrongfully interfered with Dr. Murtagh's advantageous business relationships by falsely communicating to prospective employers and health care businesses, with which Dr. Murtagh had established valuable business relationships, that the Defendants possessed adverse information about Dr. Murtagh's performance as a physician that dissuaded such prospective employers and health care businesses from pursuing or continuing with an employment or other business relationship with Dr. Murtagh. 13.) The acts of the Defendants alleged herein were committed in concert as part of

their shared and joint intention to ruin Dr. Murtagh's personal-aridprofessional reputation and to destroy the advantageous business relationships that he has developed. 14.) The Defendants knew that their repeated wrongful acts alleged herein would

cause, and the Defendants intended for them to cause, Dr. Murtagh great emotional distress and harm. 15.) Upon information and belief, the acts of the Defendants alleged herein were

committed for the wrongful purposes of damaging Dr. Murtagh's credibility as a witness in civil and criminal proceedings and investigations relating to other acts committed by the Defendants,
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retaliating for earlier instances when Dr. Murtagh reported to the proper authorities, what he believed was, unlawful conduct on the part of the Defendants and removing Dr. Murtagh as a competitor.
16.)

The Defendants have misused their positions as teaching hospitals by falsely

representing that Dr. Murtagh had been the subject of a final adverse peer review or medical review committee action as a member of the medical staff of one or more hospitals at which the Emory Medical School operates residency programs. Adverse peer review and medical review committee actions are properly taken by hospitals and their organized medical staff against physicians only in situations where factual evidence establishes that the physician is guilty of misconduct related to his or her exercise of medical staff privileges or is unqualified or incompetent to exercise his or her medical staff privileges. Such actions may result in a limitation, reduction, suspension or

termination of medical staff or clinical privileges and are properly concluded only after accusations are made in writing and signed by the appropriate hospital official and the physician in question is provided with notice of the allegations and alleged evidence and a fair opportunity to confront, respond to and rebut any witnesses and evidence against him or her. Such due process rights are provided for in the hospital's medical staff by-laws, or other hospital procedural rules, which also specify the manner in which the severity of-final adverse action, if any, will be determined. Thereafter, the hospital's rules or medical staffbylaws or rules and applicable laws specifywhen and if such action will be reported. Any statement to another hospital, medical staff, health care business, or government entity, by a representative of the Defendant hospitals, that a physician on their medical staffs has been subjected to adverse peer review is likely to have a devastating effect on the subject physician's professional reputation and is likely to destroy any advantageous business or employment relationship, or potential relationship, that the physician may have with another hospital, medical staff or health care business. The representatives of the Defendants were, at all times

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material to this case, fully aware that any statement that Dr. Murtagh had been subjected to adverse peer review or medical review committee action would cause the injuries to Dr. Murtagh alleged herein.

17.)

Representatives of Grady and Emory became aware of Dr. Murtagh's

advantageous business and prospective employment relationships through various means, including direct inquiries by representatives of prospective employers. Those relationships include, but are not necessarily limited to, the following: a. In or about January 2003, representatives of Emory and Grady became aware that Dr. Murtagh had developed an advantageous business relationship and prospective employment relationship with James St. Clair at J&C Nationwide Placement, a business entity that specialized in physician recruitment that was attempting to recruit Dr. Murtagh for a position. b. In or about December 2003, representatives of Emory and Grady became aware that Dr. Murtagh had developed an advantageous business relationship and prospective employment relationship with Somnograph, Inc, an entity that provided sleep medicine services, and its representative. Duke Naipohn. Representatives of Emory and Grady were also aware that, because Emory desired to become involved in the expansion of its sleep medicine services in the Atlanta area, Dr. Murtagh's relationship with Somnograph, Inc. and Mr. Naiphon would result in a competitive threat to Emory. Emory and Grady representatives, with knowledge of Dr. Murtagh's advantageous
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business and prospective employment relationships alleged above, abused their positions as representatives of prestigious teaching hospitals in order to make false representations about Dr. Murtagh that in each case damaged and interfered with the relationship. By way of example: a. Somnograph, hie. is, one of the largest sleep medicine providers

in the United States. Dr. Murtagh was in the process of finalizing

a valuable business arrangement through discussions with Somnograph's chief executive officer. Duke Naipohn in December 2003. b. One or more managerial representative of Emory became aware that Somnograph was about to consummate an employment relationship with Dr. Murtagh and falsely stated to Mr. Naipohn that Emory University had completed an adverse peer review proceeding with respect to Dr. Murtagh, and had concluded that Dr. Murtagh suffers from a mental illness which would preclude him from competently and effectively, engaging in the practice of medicine.
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c. As a result of the Emory's false and disparaging representations about Dr. Murtagh, Somnograph elected not to go forward with its relationship with Dr. Murtagh. 19.) With respect to the other advantageous business and prospective employment

relationships alleged herein, the Emory and Grady representatives made similar false statements about Dr. Murtagh or failed to provide truthful information knowing that such failure would damage the relationship.

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20.)

The Defendants' conduct alleged herein constituted willful misconduct, malice,

fraud, wantonness, oppression, or that entire want of care which would raise the presumption of conscious indifference to consequences. Any peer review or medical review committee action by Emory or Grady representatives was conducted with malice or fraud.

COUNT ONE SLANDER AND DEFAMATION PER SE

21.)

The allegations of Paragraphs 1 through 20 are re-alleged, re-asserted, and re-

averred as if fully set forth herein. 22.) The defamatory, slanderous, and false statements made by the Emory and Grady

representatives wrongfully disparaged Dr. Murtagh's character, professional competence, professional knowledge, and professional abilities. 23.) The Emory and Grady representatives knew that the representations were false

when made and that an actual adverse peer review had not been concluded. 24.) The false, disparaging, and defamatory statements made by the Emory and Grady
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representatives were specifically made about, and for the purpose of injuring, Dr. Murtagh's business and professional reputation. 25.) The false, defamatory, and disparaging statements made by the Emory and Grady

representatives have caused Dr. Murtagh to sustain damages in excess of $1,000,000, plus prejudgment interest accruing thereon.
26.)

The false, defamatory, and disparaging statements made by the Emory and Grady

representatives were made intentionally, and for the express purpose of wrongfully damaging Dr.

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Murtagh's business and professional reputation and, accordingly, Dr. Murtagh is entitled to an award of punitive damages to deter and punish Emory and Grady for their intentional defamation of Dr. Murtagh .

27.)

Defendant's slander of Dr. Murtagh in his trade or business is per se and damages for

such slander are presumed as per O.C.G.A. 5 5 1-5-4(a)(3) and Georgia common law. 28.) Plaintiff Murtagh is entitled to recover damages for Defendant's per se slander in an

amount to be determined by the enlightened conscience of a fair and impartialjury. WHEREFORE, Plaintiff Murtagh prays: (1) (2) that he be granted trial by jury as to this Count One; that judgment be entered in favor of Plaintiff Murtagh, and against Defendants Fulton-

Dekalb Hospital Authority, Emory University, Emory Healthcare, Inc., and Grady Health Services Company, Inc, jointly and severally, as to Count One of Plaintiffs Complaint;

(3)

that Plaintiff Murtagh recover from Defendants Fulton-Dekalb Hospital Authority,

Emory University, Emory Healthcare, Inc., and Grady Health Services Company, Inc, jointly and severally, his damages, including direct, consequential, general, special, interest and necessary expenses, for Defendant'sperse slander in an amount to be determined by the enlightened conscience of a fair and impartialjury, but in no event less than $1,000,000.00;
(4)

that Plaintiff Murtagh recover from Defendants Fulton-Dekalb Hospital Authority,

Emory University, Emory Healthcare, Inc., and Grady Health Services Company, Inc, jointly and severally, punitive damages in an amount to be determined by the enlightened conscience of a fair and impartial jury.
(5)

that the Court grant such other and further relief as is just and proper.

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COUNT TWO DEFAMATION

29.)

The allegations of Paragraphs 1 through 20 are re-alleged, re-asserted, and re-averred

as if fully set forth herein. 30.) The defamatory, slanderous, and false statements made by the Emory and Grady

representatives wrongfully disparaged and slandered Dr. Murtagh's character, professional competence, professional knowledge, and professional abilities. 31.) The Emory and Grady representatives knew that the representations were false when

made and that an actual adverse peer review had not been concluded. 32.) The false, disparaging, slanderous and defamatory statements made by the Emory and

Grady representatives were specifically made about, and for the purpose of injuring, Dr. Murtagh's business and professional reputation. 33.) The false, defamatory, slanderous and disparaging statements made by the Emory and

Grady representatives have caused Dr. Murtagh to sustain damages in excess of $1,000,000, plus prejudgment interest accruing thereon.
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34.)

The false, defamatory, slanderous and disparaging statements made by the Emory

and Grady representatives were made intentionally, and for the express purpose of wrongfully damaging Dr. Murtagh's business and professional reputation and, accordingly, Dr. Murtagh is entitled to an award of punitive damages to deter and punish Emory and Grady for their intentional defamation of Dr. Murtagh . 35.) Plaintiff Murtagh is entitled to recover damages for Defendant's slander in an amount

to be determined by the enlightened conscience of a fair and impartial jury.

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WHEREFORE, Plaintiff Murtagh prays:

(1) that he be granted trial by jury as to this Count Two;

(2) that judgment be entered in favor of Plaintiff Murtagh, and against Defendants Fulton-Dekalb Hospital Authority, Emory University, Emory Healthcare, Inc., and Grady Health Services Company, Inc, jointly and severally, as to Count Two of Plaintiffs Complaint; (3) that Plaintiff Murtagh recover from Defendants Fulton-DekalbHospital Authority, Emory University, Emory Healthcare, Inc., and Grady Health Services Company, Inc, jointly and severally, his damages, including direct, consequential, general, special, interest and necessary expenses, for Defendant's slander in an amount to be determined by the enlightened conscience of a fair and impartial jury, but in no event less than $1,000,000.00; (4) that Plaintiff Murtagh recover from Defendants Fulton-DekalbHospital Authority, Emory University, Emory Healthcare, Inc., and Grady Health Services Company, Inc, jointly and severally, punitive damages in an amount to be determined by the enlightened conscience of a fair and impartialjury. (5) that the Court grant such other and further relief as is just and proper.

COUNT III TORTIOUS INTERFERENCE WITH ADVANTAGEOUS BUSINESS AND PROFESSIONAL RELATIONSHIPS 36.) The allegations of Paragraph 1 through 20 are re-alleged, re-asserted, and re-averred

as if fully set forth herein. 37.) This is an action for damages for tortious interference with Dr. Murtagh's

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advantageous business and professional relationships. 38.) Dr. Murtagh possessed valuable business and professional relationships as alleged

herein, including with Somnograph, Inc. of Wichita, Kansas and Duke Naipohn, its chief executive officer of which Emory and Grady representatives were well aware.

39.)

The false statements made by the senior Emory and Grady representatives alleged

herein, were made for the express purpose of and did, in fact, wrongfully and tortiously interfere with Dr. Murtagh's advantageous and valuable business and professional relationships with Sornnograph, Naipohn and others. 40.) As a result of the wrongful interference by the Emory and Grady representatives, Dr.

Murtagh has sustained damages in excess of $1,000,000. 41.) Plaintiff Murtagh is entitled to recover damages for Defendant's tortuous interference

in an amount to be determined by the enlightened conscience of a fair and impartial jury.

WHEREFORE, Plaintiff Murtagh prays: (1) that he be granted trial by jury as to this Count Three;
(2) that judgment be entered in favor of Plaintiff Murtagh, and against Defendants Fulton-Dekalb Hospital Authority, Emory University, Emory Healthcare, Inc., and Grady Health Services Company, Inc, jointly and severally, as to Count Three of Plaintiffs Complaint;
(3) that Plaintiff Murtagh recover from Defendants Fulton-Dekalb Hospital

Authority, Emory University, Emory Healthcare, Inc., and Grady Health Services Company, Inc, jointly and severally, his damages, including direct, consequential, general, special, interest and necessary expenses, for Defendant's tortious interference with advantageous business and professional 13

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relationships in an amount to be determined by the enlightened conscience of a fair and impartial jury, but in no event less than $1,000,000.00; (4) that Plaintiff Murtagh recover from Defendants Fulton-Dekalb Hospital Authority, Emory University, Emory Healthcare, Inc., and Grady Health Services Company, Inc, jointly and severally, punitive damages in an amount to be determined by the enlightened conscience of a fair and impartial jury. (5) that the Court grant such other and further relief as is just and proper.

COUNT FOUR INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS 42.) The allegations of Paragraph 1 through 20 are re-alleged, re-asserted, and re-averred

as is fully set forth herein. 43 .) 44 .) This is an action for damages for intentional infliction of emotional distress. The Defendants acted intentionally and recklessly in reporting to third parties that Dr.

Murtagh had been the subject of a final adverse peer review, had been terminated from his teaching position, and was mentally imbalanced.
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45 .) 46.) 47 .)

The Defendants' conduct was extreme and outrageous. The Defendants' conduct caused Dr. Murtagh severe emotional distress. The Defendants' actions were intentional and calculated to inflict harm on Dr.

Murtagh, including emotional distress.

48.)

As a result of the Defendants' conduct, Dr. Murtagh has sustained substantial

damages in excess of $1,000,000 that he is entitled to recover. 49.) Plaintiff Murtagh is entitled to recover damages for Defendant's intentional infliction

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of emotional distress in an amount to be determined by the enlightened conscience of a fair and impartial jury. WHEREFORE, Plaintiff Murtagh prays: (1) that he be granted trial by jury as to this Count Four;
(2) that judgment be entered in favor of Plaintiff Murtagh, and against Defendants

Fulton-Dekalb Hospital Authority, Emory University, Emory Healthcare, Inc., and Grady Health Services Company, Inc, jointly and severally, as to Count Four of Plaintiffs Complaint;

(3) that Plaintiff Murtagh recover from Defendants Fulton-Dekalb Hospital Authority,
Emory University, Emory Healthcare, Inc., and Grady Health Services Company, Inc, jointly and severally, his damages, including direct, consequential, general, special, interest and necessary expenses, for Defendant's intentional infliction of emotional distress in an amount to be determined by the enlightened conscience of a fair and impartialjury, but in no event less than $1,000,000.00;

(4) that Plaintiff Murtagh recover from Defendants Fulton-Dekalb Hospital Authority,
Emory University, Emory Healthcare, Inc., and Grady Health Services Company, Inc, jointly and severally, punitive damages in an amount to be determined by the enlightened conscience of a fair and impartialjury. (5) that the Court grant such other and further relief as is just and proper.

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COUNT FIVE CIVIL CONSPIRACY TO MALICIOUSLY INJURE BUSINESS AND PROFESSION OF ANOTHER AM)COMMIT OTHER TORTIOUS ACTS

50.)

The allegations of Paragraph 1 through 20 are re-alleged, re-asserted, and re-averred

as if fully set forth herein.. 5 1.) This is an action for damages for civil conspiracy to maliciously injure Dr. Murtagh

in his business and profession and to commit the other tortious acts alleged in this Complaint. 52.) The Defendants intentionally committed the acts alleged herein as part of a

combination between representatives of Emory and Grady to professionally discredit Dr Murtagh, to damage his personal and professional reputation and to destroy his business relationships that are essential to his ability to engage in his chosen business and to practice his chosen profession. 53.) The Defendants, acting in concert, have maliciously injured the business of Dr.

Murtagh and his ability to practice medicine. 54.) The Defendants committed the acts alleged herein with the express purpose of

depriving Dr. Murtagh of the benefits and certain contemplated benefits of employment as a
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. ,

medical doctor in the areas of internal medicine, pulmonary medicine and sleep medicine. 55.) As a result of their combined and concerted acts, the Defendants are each liable for

the acts of the other and are jointly and severally liable for the damages caused by their acts to Dr. Murtagh as alleged in this Count as well as in Counts I, I,1 1and IV. I 1 56.) As a result of the Defendants' conduct, Dr. Murtagh has sustained substantial

damages in excess of $1,000,000 that he is entitled to recover. 57.) Plaintiff Murtagh is entitled to recover damages for Defendant's malicious injury to

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his business and profession and conspiracy to commit the acts alleged herein in an amount to be determined by the enlightened conscience of a fair and impartial jury.

WHEREFORE, Plaintiff Murtagh prays:

(1) that he be granted trial by jury as to this Count Five;

(2) that judgment be entered in favor of Plaintiff Murtagh, and against Defendants FultonDekalb Hospital Authority, Emory University, Emory Healthcare, Inc., and Grady Health Services Company, Sic, jointly and severally, as to Count Five of Plaintiffs Complaint;
(3) that Plaintiff Murtagh recover from Defendants Fulton-Dekalb Hospital Authority, Emory

University, Emory Healthcare, Inc., and Grady Health Services Company, Inc, jointly and severally,his damages, including direct, consequential, general, special, interest and necessary expenses, for Defendant's malicious injury to the Plaintiffs business and profession and conspiracy to commit the tortious acts alleged herein in an amount to be determined by the enlightened conscience of a fair and impartial jury, but in no event less than $1,000,000.00;
(4)

that Plaintiff Murtagh recover from Defendants Fulton-Dekalb Hospital Authority,

Emory University, Emory Healthcare, Inc., and Grady Health Services Company, Inc, jointly and severally, punitive damages in an amount to be determined by the enlightened conscience of a fair and impartial jury. (5) that the Court grant such other and further relief as is just and proper.

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DEMAND FOR JURY TRIAL The Plaintiff demands trial by jury on all issues so triable.

RESPECTFULLY SUBMITTED this 3othth day of November, 2004.

&Jd$fL~p

JOSE H BREEN Ga. Bar No.: 079275

J~AN GUTERMUTH Ga. Bar No.: 315913

Attorneys at Law

The Breen Law Firm 3562 Old Milton Parkway Alpharetta, GA 30005 (770) 740-0008