DISTRICT COURT IN Tru I]NITED STATES MIDDLE DISTRICTOF GEORGIA

MACON DTVISION

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Plaintffi (propriapersona) v. HOSPITALOF AUGUSTA,LLC DOCTORS HeywardWells,DoctorsHospitaladministrator; Cole,DoctorsHospitalChief of Security; James Dorn, DoctorsHospitalsocialworker; Thomas DoctorsHospitalpatientadvocate; TrishaFoster, RichardCartie,MD DoctorsHospitalmedical directorof pediafriccritical care; director; ChrisHaga,DoctorsHospitaladmissions manager; Hospital nurse Doctors Masters, Donna DoctorsHospitalnurse; TerrellYelverton, JulieLewis,DoctorsHospitalnurse; JimmyWren,RichmondCountyDeputySheriff; Judicial Lisa Rambo,GeorgiaSouthwestern Disfiict JuvenileJudge; Patick Eidson,MaconCountyDFCSattorney; Hurt, MaconCountyDFCSattorney; James KaranAlbritton, MaconCountyDFCSsupervisor; Barr,MaconCountyDFCSsocialworker; Susan Doe,RichmondCountysocialworker; Jane Doe,RichmondCountysocialworker; Janet offrce Associates Pediatric EdnaMesser, manager; Fussell, CASA supervisor Stacee ; Advocate; EstellaLusane,CourtAppointedSpecial ofedch defendant, eachspouse in their individual capaclty,

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JuryTrial Demanded

Defendants Complaint the pursuant to 42 U.S.C.$ 1983to redress This is a civil actioncommenced within the and guaranteed deprivationof rights certainof which areexpressed Law of the Land. Constitutionor supreme

Plaintiffs are natural persons seeking to hold Defendants accountable for depriving Plaintiffs of their inalienable rights under color law and Defendants' failure, neglect, or refusal to protect Plaintiffs from said deprivations although it was within their power to do so. The Plaintiffs' son was unreasonably seized, his Fourth and Fifth mendment rights violated due to a culmination of malicious actions set into motion by a pediatric physician working in concert and collaboration with state actors, several nurses, administrative hospital staff, the hospital's admissions director, the Doctors !ospital patient advocate, a hospital social worker, two "ichmond #ounty, $eorgia DF#% social workers, two &acon #ounty social workers, a 'uvenile 'udge, at least two &acon #ounty DF#% attorneys, the Doctors !ospital security, and a "ichmond #ounty %heriff's Deputy without reasonable cause or emergency circumstances (ustifying such deprivations. The above entitled court is hereby respectfully directed to take (udicial notice that each of the principal actors named as Defendants herein, at all material times and places mentioned herein, were cognizantly acting in concert under color of law to the manifest in(ury and deprivation of Plaintiffs' #onstitutionally secured rights. Jurisdiction and Venue ). The Plaintiffs, *redacted father+ and *redacted mother+, individually and as parents of F.#., ".#., and D.#., who reside in &acon #ounty $eorgia at a confidential address with a mailing address of P.,. -o. /)), 0deal, $eorgia /)12), bring this civil rights lawsuit pursuant to 23 4.%.#. 5 )67/ to redress the deprivation of their rights by the Defendants secured to them and e.pressed within the 4nited %tates #onstitution. 3. 'urisdiction of this #ourt is invoked under 23 4.%.#. 5 )67/ and the supreme 8aw of the 8and. 9enue properly lies in this #ourt given that all of the parties reside in this federal district.

Parties /. Plaintiffs *redacted father+, *redacted mother+, and their young sons F.#., ".#., and D.#. are mericans residing near the city of 0deal within the %tate of $eorgia. forementioned Plaintiffs are beneficiaries of the public trust known commonly as the #onstitution and the supreme 8aw of the 8and. 2. ll Defendants are :persons: within the meaning of 23 4.%.#. 5 )67/ and at

all relevant times were acting under color of law. ;. Defendant D,#T,"% !,%P0T 8 ,F 4$4%T , 88# *a legal fiction+ is located at /<;) =heeler "d., ugusta, $eorgia /1616. %ummons may be sent to the registered agent in $eorgia as follows> D,#T,"% !,%P0T 8 ,F 4$4%T , 88#, c?o :The #orporation Process #ompany:, 3)71 %atellite -lvd., %uite 211, Duluth, $eorgia /116@. <. Defendant !eyward =ells, at all times and places material hereto, was acting in the capacity of an employee within the Doctors !ospital. Defendant =ells may be served summons at > Doctors !ospital of ugusta, /<;) =heeler "d., ugusta, $eorgia /1616. !e is being sued in his individual capacity. @. Defendant 'ames #ole, at all times and places material hereto, was ostensibly acting in the capacity of %ecurity #hief within the Doctors !ospital. Defendant #ole may be served summons at > Doctors !ospital of ugusta, /<;) =heeler "d., ugusta, $eorgia /1616. !e is being sued in his individual capacity. 7. Defendant Thomas Dorn, at all times and places material hereto, was ostensibly acting in the capacity of a social worker within the Doctors !ospital. Defendant Dorn may be served summons at > Doctors !ospital of ugusta, /<;) =heeler "d., ugusta, $eorgia /1616. !e is being sued in his individual capacity. 6. Defendant Trisha Foster, at all times and places material hereto, was ostensibly acting in the capacity of a patient advocate within the Doctors !ospital.

Defendant Foster may be served summons at > Doctors !ospital of ugusta, /<;) =heeler "d., ugusta, $eorgia /1616. %he is being sued in her individual capacity. )1. Defendant Dr. "ichard #artie, at all times and places material hereto, was ostensibly acting in the capacity of medical director of pediatric care within the Doctors !ospital. Defendant #artie, may be served summons at > Doctors !ospital of ugusta, /<;) =heeler "d., ugusta, $eorgia /1616. !e is being sued in his individual capacity. )). Defendant #hris !aga, at all times and places material hereto, was ostensibly acting in the capacity of admissions director for Doctors !ospital. Defendant, #hris !aga, may be served summons at > Doctors !ospital of ugusta, /<;) =heeler "d., ugusta, $eorgia /1616. !e is being sued in his individual capacity. )3. Defendant Donna &asters, at all times and places material hereto, was ostensibly acting in the capacity of nurse manager within the Doctors !ospital. Defendant, Donna &asters, may be served summons at her primary place of employment> Doctors !ospital of ugusta, /<;) =heeler "d., ugusta, $eorgia /1616. %he is being sued in her individual capacity. )/. Defendant Terrell Aelverton, at all times and places material hereto, was ostensibly acting in the capacity of a nurse within the Doctors !ospital in ugusta, $eorgia. Defendant Aelverton may be served summons at his primary place of employment> Doctors !ospital of ugusta, /<;) =heeler "d., ugusta, $eorgia /1616. !e is being sued in his individual capacity. )2. Defendant 'ulie 8ewis, at all times and places material hereto, was ostensibly acting in the capacity of a nurse within the Doctors !ospital. Defendant 8ewis may be served summons at her primary place of employment> Doctors !ospital of ugusta, /<;) =heeler "d., ugusta, $eorgia /1616. %he is being sued in her individual capacity. );. Defendant 'immy =ren, at all times and places material hereto, was

ostensibly acting in the capacity of a "ichmond #ounty employee under color of state law and e.ercising the public trust powers belonging to an office styled as ',ffice of the %heriff '. Defendant =ren acted in the capacity of "ichmond #ounty, $eorgia %heriff's Deputy. Defendant =ren may be served summons at his primary place of employment> 211 =alton =ay, ugusta, $eorgia /161). !e is being sued in his individual capacity. )<. Defendant, licia #oogle "ambo, is an attorney and 'uvenile 'udge within the %outhwestern 'udicial #ircuit. Defendant "ambo, may be served summons at her primary place of business> %umter #ounty #ourthouse, P.,. -o. <1@, mericus, $

/)@16. Defendant "ambo, at all times and places material hereto, was ostensibly acting in the capacity of a %umter #ounty employee under color of state law and e.ercising the public trust powers belonging to an office styled as ''uvenile #ourt 'udge.' %he is being sued in her individual capacity. )@. Defendant, Patrick Bidson, is an attorney for DF#%. Defendant, Patrick Bidson, may be served summons at his primary place of business> )1) =alnut %treet, %uite , P.,. -o. ;@1, 8eesburg, $ /)@</. !e is being sued in his individual capacity. )7. Defendant, 'ames =. !urt , is an attorney for DF#%. Defendant, 'ames =. !urt, may be served summons at his primary place of business> ))) =. )/th ve., #ordele, $ /)1);. !e is being sued in his individual capacity. )6. Defendant Caran lbritton, at all times and places material hereto, was ostensibly acting in the capacity of a supervisor under color of state law within the office styled as 'DF#%' , 'The DBP "T&BDT', or 'Department of Family and #hildren %ervices'. Defendant lbritton may be served summons at her primary place of employment> &acon #ounty DF#%, P.,. -o. 2;@, 2)/ #lifton -radley "oad, ,glethorpe, $eorgia /)1<7. %he is being sued in her individual capacity. 31. Defendant %usan -arr, at all times and places material hereto, was ostensibly acting in the capacity of a social worker under color of state law within the office styled

as 'DF#%' , 'The DBP "T&BDT', or 'Department of Family and #hildren %ervices'. Defendant -arr may be served summons at her primary place of employment> &acon #ounty DF#%, P.,. -o. 2;@, 2)/ #lifton -radley "oad, ,glethorpe, $eorgia /)1<7. %he is being sued in her individual capacity. 3). Defendant %tacee Fussell, at all times and places material hereto, was ostensibly acting in the capacity of an office manager for # % *#ourt ppointed %pecial dvocates+ . Defendant Fussell may be served summons at her primary place of employment> %,=B$ # % , P.,. -o. @/3, mericus, $ /)@16. %he is being sued in her individual capacity. 33. Defendant Bstella 8usane , at all times and places material hereto, was ostensibly acting in the capacity of an ,fficer of the #ourt under color of state law and e.ercising the public trust powers belonging to a # % *#ourt ppointed %pecial dvocate+. Defendant 8usane may be served summons at her primary place of employment> %,=B$ # % , P.,. -o. @/3, mericus, $ /)@16. %he is being sued in her individual capacity. 3/. Defendant Bdna &esser, at all times and places material hereto, was ostensibly acting in the capacity of an office manager for Pediatric ssociates. 4pon information and belief &s. &esser fa.ed private medical documents to state actors Bstella 8usane and %tacee Fussell without 8awful authority to do so. Defendant &esser may be served summons at her primary place of employment> Pediatric ssociates, ))< %outh !ouston "oad, =arner "obins, $ /)177. %he is being sued in her individual capacity.

32. The true names, legal identity, and address's for summons for all of the named Defendants' spouses and the two "ichmond #ounty DF#% social worker Defendants, 'ane and 'anet Doe, are unknown at this time, but will be added by mendment when ascertained, each in his or her individual capacity.

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Judicial Notice Statement 3;. The above entitled court is respectfully directed to take (udicial notice that each of the principal actors named as defendants herein, whether bound by the solemn ,ath or affirmation mandated at rticle 90 of the supreme 8aw of the 8and in fact or not, did willfully e.ercise powers belonging to an office of public trust and, by such conduct, manifestly accepted the duties, obligations, and liabilities attendant to a trustee of such *public trust+ powers. 3<. The above entitled court is hereby further respectfully directed to take (udicial notice that it has been undeniably established as a fundamental ma.im of 8aw that the supreme 8aw of the 8and is wholly within the purview of the foundational precepts set forth in the merican Declaration of 0ndependence which makes unmistakably clear that, by operation of 8aw, the primary and superseding duty *obligation+ imposed upon anyone giving e.ercise to public trust powers is to :....secure *make safe+...the rights of 8ife, 8iberty, and the pursuit of !appiness Ewith which all *wo+men are endowed by their #reatorF G which encompass a whole plethora of other more specific rights relevant thereto. 3@. Plaintiffs assert herein that Defendants, acting in concert and in such respective official capacities, not only failed to perform said primary and superseding obligation to Plaintiffs but manifestly acted contrary to said protective reHuirement with willful intent. %aid primary obligation also carries the inherent ancillary duty to prevent such deprivations from occurring or reaching culmination. Plaintiffs further assert herein that Defendants were noticed, at all material times and places, that their conduct was unlawful and in(urious to the secured rights of Plaintiffs and that any defense raised on the basis of :ignorance of the law: or :innocent intent: is undeniably without factual foundation. 37. The above entitled court is hereby further respectfully directed to take

(udicial notice that the spouses of the principal actors named as Defendants herein, whether acting in active or passive capacity, are properly (oined as party defendants hereto pursuant to the long established precepts of coverture, marriage, accessory contract, and division of spoils as well as abundant stare decisis upon the sub(ect*s+ of accessory, tontine wagering, and misprision G all of which are relevant to the intrinsic nature of the instant action now before the eyes of the court. Facts 36. ,n December 2th, 31)3 at appro.imately 2P& Plaintiffs' two year old son , F.#., accidentally burned the tips and tops of both of his feet. /1. F.#.'s parents immediately washed their son's wounds, applied honey *a medically appropriate action+, loosely wrapped his feet, and delivered him to the #oliseum hospital in &acon, $eorgia. /). #oliseum medical staff again washed and wrapped F.#.'s feet recommending F.#. be seen by medical staff at the Doctors !ospital in ugusta, $eorgia. /3. F.#. and his father arrived at the Doctors !ospital in ugusta at around )1>/1P& and were told that F.#. would go into surgery in the morning around 7 & on December ;th, 31)3. //. The surgery would entail wound cleaning, debriding, application of skin grafts, and wrapping. /2. F.#.'s mother and grandfather arrived to the Doctors !ospital later that night. /;. t around 7>/1 & on December <th, 31)3 the surgeon's assistant, -rian

%hirley, entered F.#.'s hospital room to personally inspect F.#.'s wounds. -rian %hirley acHuired parental consent to perform surgery on F.#.. /<. t around this same time Defendant #artie had also entered the hospital room

and asserted that F.#. had not been vaccinated for tetanus and, :would now be now.: /@. Plaintiffs refused to provide informed consent for the tetanus vaccination of

their son to Defendant #artie. /7. Defendant #artie did not personally observe or e.amine F.#.'s in(ured feet. /6. Defendant #artie failed to verify F.#.'s medical condition instead relying on :reports: even though F.#. was within three feet of Defendant #artie. 21. Defendant #artie never demanded any other procedure be performed other than tetanus vaccination. 2). tetanus vaccine is not and can not be, under any circumstance, an

emergency medical intervention. 23. Defendant #artie was frustrated by Plaintiffs steadfast insistence on e.ercising their inalienable right to refuse the demanded tetanus vaccine for their son. 2/. Due to defendant #artie's abusive and bullying demeanor, Plaintiffs made it known to medical staff that Defendant #artie was :fired: insofar as being their son's pediatrician. 22. Defendant #artie became affronted when Plaintiffs :fired: him. 2;. Defendant #artie's wounded pride and frustration with Plaintiffs led him to initiate a series of deceptions and brutal punishments directed at F.#. and his parents *Plaintiffs+. 2<. Defendant #artie, directly assisted by Defendant Donna &asters, ordered that the scheduled wound cleaning and surgery be delayed until Plaintiffs consented to a tetanus vaccine for F.#.. %aid additional surgical delay was appro.imately four hours in duration and had absolutely no medical basis whatsoever. 2@. Defendant #artie intended to punish and did punish Plaintiffs for invoking their inalienable right to refuse his demanded an demonstrably unnecessary medical intervention. 27. Due to Defendant #artie's malicious order to delay medically necessary

debriding and surgery, appro.imately )7 hours had passes since F.#.'s wounds had been cleaned and dressed. 26. ,f paramount importance, in suspected tetanus e.posure cases, is the reHuirement to immediately wash , debride, and wrap the wound to effect an aerobic environment in which tetanus *#lostridium tetani + can not survive or colonize to the point of endangering the patient. ;1. ction consistent with an honest concern about F.#. being e.posed to tetanus

would be the immediate wound cleaning and debriding followed by skin grafts which Defendant #artie delayed an additional 2 hours in order to punish Plaintiffs and without any medical (ustification for doing so. ;). Defendant #artie's ordered IdelayJ ended when F.#. began to cry in discomfort and his parents *Plaintiffs+ became visibly and consistently agitated that their son be seen to immediately. ;3. F.#.'s father asked nurse Cathy Bcks why his son's surgery was being delayed. Durse Bcks indicated that it was due to the :vaccine issue:. ;/. Defendant &asters reported that the delay in surgery was due to another surgery which was more e.igent. !owever, both hospital staff and medical notes indicate that the delay was ordered, with malicious intent, by Defendant #artie. ;2. Defendant #artie ordered F.#.'s surgery to be delayed in order to :encourage: Plaintiffs to consent to vaccinate. ;;. t around )1 & December ;th, 31)3 Plaintiff *redacted father+ met with

Defendant #hris !aga so that Defendant !aga could personally inspect Plaintiff''s *redacted father+ 0D. ;<. Plaintiff *redacted father+ disallowed the copying of his 0D citing that 0D theft is prevalent within medical institutions and that a copy of his 0D would enable or encourage the theft of his 0D.

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;@. Plaintiff *redacted father+ allowed Defendant !aga to physically e.amine his *redacted father+ 0D. ;7. Defendant !aga never indicated any concern to Plaintiffs that the 0D had been anything other than authentic. ;6. Plaintiffs were :selfGpay: which prompted Defendant !aga to insist that Plaintiff *redacted father+ apply for &edicaid and sign another admissions document in which no terms and conditions had been struck out. <1. Plaintiff *redacted father+ had previously signed a Doctors !ospital admissions document wherein he **redacted father++ struck out several disagreeable terms and conditions prior to signing. <). During this brief meeting with Defendant !aga, Plaintiff *redacted father+ refused to apply for &edicaid or to sign admissions documents with disagreeable terms and conditions. <3. t around noon on December ;th, 31)3 it is believed that Defendant #artie

collaborated with two "ichmond #ounty DF#% social workers, Defendants 'ane Doe and 'anet Doe, to intimidate, harass, and threaten Plaintiffs. Defendants 'ane Doe and 'anet Doe plainly asserted that Plaintiffs son could be taken into the care and keeping of the Public Trust if Plaintiffs did not provide consent for the tetanus vaccine. Plaintiffs maintained their position of nonGconsent for the tetanus vaccine despite the "ichmond #ounty DF#% agents' hostilities and threats directed toward Plaintiffs. </. Defendant #artie and the hospital staff Defendants, by involving DF#% employees to investigate without emergency medical (ustification, set into motion a course of action he?they knew or reasonably should have known would result in the violation of the Plaintiffs' #onstitutional rights. <2. Defendants #artie's and &aster's hospital notes indicate paranoid ideations to (ustify the inhumane treatment of Plaintiffs. Defendant #artie's notes fail to mention

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e.culpatory evidence *to negate such imaginings and ideations+ including the obvious fact that Plaintiff *redacted mother+ was breastfeeding F.#. and was accompanied by her father while at the Doctors !ospital. Dr. #artie's reports were demonstrably created in bad faith. <;. Plaintiffs asked Defendant Donna &asters to contact the Doctors !ospital #B,, *Doug =elch+. Defendant &asters indicated that the #B, would be in touch with them :today or tomorrow:. <<. Doctors !ospital #B, Doug =elch was never heard from or seen by Plaintiffs. <@. Then, based on information and belief, Defendant #artie, working in concert with Defendants #hris !aga, 'ames #ole, Donna &asters, and !eyward =ells employed "ichmond #ounty %heriff Deputy =ren to intimidate and interrogate Plaintiffs under the prete.t that an 0D card had been IreportedJ as appearing to have been tampered with or altered. <7. The only person to have seen Plaintiff *redacted father+ 0D prior to Defendant =ren was the Doctors !ospital admissions director Defendant #hris !aga. <6. Defendant #artie's summoning of a Deputy %heriff and the Defendants 'ane and 'anet Doe, further evidences :bad faith: reporting by Defendant #artie in order to impose his will, via state actors, on the Plaintiffs. @1. These several intimidation tactics failed to result in Plaintiffs' consent to vaccinate. @). Bvidence indicates that Defendant #artie then proceeded to consult and plan with &acon #ounty DF#% supervisor, Defendant Caran lbritton, to take custody of not (ust one but all three *according to Defendant #artie's hospital notes+ of Plaintiffs' sons. @3. ,n or around 7P& on December ;th, 31)3 Defendant 'ulie 8ewis entered Plaintiffs' hospital room accompanied by armed guards including Defendant 'immy =ren to announce that F.#. would now be vaccinated. Plaintiffs again refused to consent to the

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tetanus vaccination. @/. Defendant 8ewis asserted to the Plaintiffs that the vaccination was court ordered and, as if a state actor, she served the soGcalled court order *B.hibit + to Plaintiffs. @2. Plaintiffs were in absolute shock that events were unfolding as they were. @;. Plaintiffs were sleep deprived in addition to being perpetually, harassed, terrorized, and their concerns ignored by hospital staff and state actors throughout the day. @<. Plaintiffs were completely aware that their rights were being violated at the time they were being violated and noticed *verbally+ Defendants 8ewis, =ren, and others that their *Plaintiffs'+ rights were being violated and their *Defendants+ actions were :wrong:. @@. The court order titled, :,"DB" F," %!B8TB" # "B: *B.hibit + stated , :The medical staff explained the significance of the shots and father refused the shots for the child therefore putting the child's life, possibly, in danger.: @7. The mere possibility of danger does not constitute an emergency or e.igent circumstance that would (ustify the seizure of F.#. or any other human being. @6. t no time did any of the medical staff verbally convey any information,

positive or negative, regarding the tetanus vaccine to the Plaintiffs. 71. Defendant #artie, at no time, provided any information, significant or otherwise about the tetanus to.oid * DT vaccine+. 7). The soGcalled :,"DB" F," %!B8TB" # "B: contained no language to indicate probable cause or that e.igent circumstance e.isted to (ustify the seizure of F.#. %aid order was authorized by Defendant 8isa #oogle "ambo and prepared by Defendant Patrick Bidson. 73. Defendants 8isa "ambo's and Bidson's :,"DB" F," %!B8TB" # "B: was not supported by ,ath or affirmation as is mandated by the Fourth mendment.

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7/. Defendant 8isa "ambo, asserting herself to be a 'udge, is e.pressly reHuired at rticle 90 *%upremacy clause+ of the #onstitution to support the Fourth mendment. 72. Defendant 8ewis indicated to Plaintiffs that they may leave the Doctors !ospital without their son or they could stay with F.#. as long as they did not attempt to flee the Doctors !ospital with F.#. 7;. Defendant 8ewis advised Plaintiffs to abandon their son F.#. to her and other hospital staff. 7<. Plaintiffs refused to abandon their in(ured and traumatized son. 7@. Defendants 8ewis and #artie, being a nurse and medical doctor, respectively, knew or should have reasonably known that refusal to vaccinate did not and could not have caused F.#. to be in imminent danger regarding the instant matter. 77. t no time did any of the named Defendants assert to Plaintiffs, by word or

action, that failure to consent to a tetanus vaccine or failure to receive a tetanus vaccine presented an imminent danger or e.igent circumstance regarding F.#.. 76. &edical staff Defendants could not impose their will upon Plaintiffs without armed state actors presenting the threat of armed and lethal force to Plaintiffs. 61. Defendant 8ewis demanded F.#. be taken to another room to be forced vaccinated. 4nder threat of lethal force and by threat of being separated, via force, from their son, Plaintiffs complied, under duress, and proceeded down the hall to what appeared to be a storage room. 6). Defendant Terrell Aelverton prepared to administer the vaccine while Defendant 8ewis and Defendant =ren looked on. 63. Defendant Aelverton became confused by the court order *B.hibit + and left the room for some 3; minutes at which time he returned and in(ected F.#. with two substances> T0$ and DT. These were administered biGlatterly amidst intense screaming and crying from F.#. while Plaintiffs attempted to console their son.

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ccording to the manufacturer of the T0$, :Pediatric Use: Safety and

effectiveness in the pediatric population have not been established. : 62. fter F.#. received the forced medical intervention, armed guards were

posted near the Plaintiffs' room and at the e.its for the rest of the night and the ne.t day creating a veritable prison for the Plaintiffs. 6;. Plaintiffs' later research indicated that the unwanted and forced medical intervention contained neuroto.ins and ototo.ins none of which were disclosed to Plaintiffs by Defendant #artie or any other of the medical staff.. 6<. F.#. was later diagnosed with a hearing loss and, to this day, is severely delayed in his ability to speak . 6@. ,n December <th, 31)3 at around )P& Plaintiffs son was seized by Defendants location. 67. s Plaintiffs left the !ospital room Plaintiffs observed Defendant &asters lbritton and -arr, armed guards looking on, and taken to an unknown

and another nurse crying. 66. Bmotionally distraught Plaintiff %haron #ross asked visibly distraught and crying Defendant &asters, I re you happy nowKJ. Defendant &asters responded, IDo.J )11. Defendant 'ames #ole then escorted Plaintiffs and F.#.'s grandfather out of the Doctors !ospital at which time Plaintiffs traveled home without their son and without knowledge of their son's condition or location. s Defendant #ole escorted Plaintiffs

from the Doctors !ospital to the parking lot he indicated that he regretted that this had happened to Plaintiffs and that he felt it was Iwrong.J )1). Defendants' son had never long been without his mother or father and was now deprived of both, deprived of his mother's nourishment in the form of breast milk and emotional support. This deprivation of their rights to familial association during a traumatic time *post burn recovery+ when F.#. most reHuired his parents' and familial

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support. )13. ,n December @th 31)3 Plaintiffs visited their son at the &acon #ounty DF#% in ,glethorpe, $eorgia. )1/. t this time Defendant %usan -arr entered into negotiations to have

Plaintiffs' son returned. ,ne of the conditions of return was for Defendant -arr to be allowed to enter and search Plaintiffs' domicile prior to returning F.#. to his parents. )12. 4nder duress, Plaintiffs agreed to allow Defendant -arr to enter and walk through the Plaintiffs' domicile located in &acon #ounty, $eorgia. )1;. During this unreasonable search Defendant -arr reHuested to speak with Plaintiffs' sons ".#. and D.#. without Plaintiffs present. )1<. 4nder duress Plaintiffs allowed Defendant -arr to interrogate minors ".#. and D.#. )1@. n interrogation of a minor by a state actor without parents' freely given

consent, without probable cause, and without an e.igent circumstance is an unreasonable seizure under the Fourth mendment. )17. Defendant -arr unreasonably seized Plaintiffs' two older sons, ".#. and D.#., so as to interrogate them. )16. ,n December @th, 31)3 appro.imately 3@ hours after F.#. was unlawfully seized from Plaintiffs, F.#. was returned to his grandparents by an unidentified DF#% employee. ))1. =hile briefly in government custody F.#. was neglected by Defendants lbritton and -arr resulting in his wrist being in(ured causing him great discomfort and mental anguish. police report was made about this in(ury.

))). 4pon hearing about Plaintiffs' son being unreasonably seized, another

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medical doctor *a practicing surgeon+ submitted a formal complaint against Defendant #artie citing #artie's :abuse of power: to the the $eorgia &edical -oard. Furthermore, said complaint indicated, INecessary surgery as delayed for a tetanus vaccine ! hich is not an acutely necessary medical treatment." ))3. %eeking to reacHuire their son, Plaintiffs , on December )1th, 31)3, attended a hearing in which Defendant 8isa "ambo and Defendant 'ames !urt decided to allow plaintiffs' son to go back home to his family under the condition that Plaintiffs contract for )3 months of :services: from DF#% or the soGcalled :DBP "T&BDT.J ))/. Defendant 'ames !urt :prepared a :@3 !,4" !B "0D$ ,"DB"?P",TB#T09B ,"DB": at B.hibit -. Defendants 8isa "ambo authorized and made operative, under color of law, this soGcalled :Protective ,rder: with her signature. ))2. ,n page two of the :@3 !,4" !B "0D$ ,"DB"?P",TB#T09B ,"DB": are printed the following five actual threats to unreasonably seize F.#. > + The parents are to successfully complete parenting classes and immunization education. ny deviation will result in the child being taken into emergency custody, and the nonGcomplying parent will be sub(ect to civil contempt. -+ #omply with all home schooling regulations reHuired by the &acon #ounty -oard of education. ny deviation will result in the child being taken into emergency custody, and the nonGcomplying parent will be sub(ect to civil contempt. #+ Bnsure child receives all medical attention recommended by any medical provider. ny deviation will result in the child being taken into emergency custody, and the nonGcomplying parent will be sub(ect to civil contempt. D+ %ign any releases for information reHuested by the Department. ny deviation will result in the child being taken into emergency custody, and the nonG

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complying parent will be sub(ect to civil contempt. B+ #ooperate with DF#% and any related agencies. ny deviation will result in the child being taken into emergency custody, and the nonGcomplying parent will be sub(ect to civil contempt. ));. Threats Through B, if carried out, would be unreasonable seizures in

violation of the law as e.pressed at the Fourth and Fifth mendments. ))<. 4nder duress, coercion, and Defendants "ambo's and !urt's threats to unreasonably seize their son, Plaintiffs agreed to do as they were directed by Defendants 8isa "ambo and 'ames !urt. ))@. The :@3 !,4" !B "0D$ ,"DB"?P",TB#T09B ,"DB": evidences that the law as it is e.pressed at the Fourth and Fifth mendments are of no import to Defendants 8isa "ambo and 'ames !urt. ))7. $iven that their son was neglected and in(ured while briefly in the care and keeping of the Public Trust, Plaintiffs had the reasonable e.pectation that F.#. could again be harmed or even killed if again taken by these negligent state actors. ))6. Plaintiffs were coerced into signing the soGcalled IFamily PlanJ document thus contracting, under duress , with DF#%. %aid document was not willingly agreed to or willingly signed by Plaintiffs. %aid document is, essentially, an unconscionable contract. )31. B.hibit # is a partial transcript of the coerced meeting Plaintiffs had with DF#% and # % Defendant Bstella 8usane regarding the soGcalled Ifamily planJ. This Jfamily meeting: with DF#% was not voluntary. Plaintiffs clearly stated to Defendants, 8usane and lbritton, that their rights were and continue to be violated and that they *Plaintiffs+ were threatened that their nonGcooperation would result in their son being seized, whereafter he could, again, be harmed or possibly killed. Plaintiffs showed video and pictures of F.#'s in(ured wrist to Defendants lbritton and 8usane.

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)3).

t no time did Plaintiffs ever sign a document or agree to any demands

made by any of the named state actors of their own free will. )33. Defendants 8isa "ambo, Bdna &esser, Bstella 8usane, and %tacee Fussell, by way of the document, : ppointment of #ourt ppointed %pecial dvocate: or I# % J *B.hibit D+ deprived plaintiffs of their Fourth mendment rights to be secure in their private medical documents. Plaintiffs' Fifth mendment rights were also violated insofar as any possible incriminating elements those unreasonably seized documents may have provided to the Defendants. )3/. %aid I# % J document was specifically used by Defendants as if it were a subpoena or warrant. )32. Defendant &esser has refused to e.plain to Plaintiffs e.actly why she allowed private medical records to be conveyed to state actors "ambo, 8usane, and Fussell. )3;. The :# % : document , the :,"DB" F," P",TB#T09B # "B: document, and the :@3 !,4" P",TB#T09B ,"DB": documents evidence e.treme disregard for restrictions on state actors as provided by the Fourth mendment. )3<. forementioned documents authorized by Defendant 8isa "ambo evidences

absolute disobedience to the #onstitution directly resulting in its beneficiaries, the Plaintiffs, being deprived of their rights. )3@. Plaintiffs have written letters to several of the state actor Defendants noticing them of specific mendments which they *Defendants+ are violating in addition to rticle 90 of our #onstitution. %aid state actors responded to Plaintiffs' claims of duress and rights violations with more rights violations and perpetually threatening to unreasonably seize Plaintiffs' son for nonGcompliance with the soGcalled court order. )37. ,n several occasions Plaintiffs contacted *in writing+ multiple employees of

)6

Doctors !ospital to inHuire as to how and to whom complaints are made to the hospital regarding abusive treatment. )36. Bmployees contacted include Defendants Foster and &asters. contacted was Doctors !ospital chief of security and Defendant 'ames #ole. lso ll three of

the aforementioned Defendants refused to answer Plaintiffs' Huestions as to how to make a formal complaint to the hospital. )/1. lso contacted *in writing+ was Bllen !intz who is employed by !#

*!# allegedly owns Doctors !ospital+ as an ethics compliance officer. Plaintiffs asked &s. !inz how to file a formal complaint regarding the abuses suffered within Doctors !ospital. &s. !inz refused to answer Plaintiff's Huestions. )/). B.hibit B is titled, :=hat !ospitals re Doing To Ceep Their facilities %afe: and was written a few months prior to the unreasonable seizure of F.#.. )/3. ccording to this article Defendant #ole asserts that he makes training a top

priority while 'ohnny &eiles asserts that his hospital has a policy or procedure in place for any :security: event. )//. -oth &ieles and #ole indicated, :how they work closely with the "ichmond #ounty %heriffs ,ffice.: )/2 . The Doctors !ospital of ugusta has in place a formal or informal policy or custom of working with state actors resulting in the deprivation of Plaintiffs' rights. )/;. Plaintiffs made it abundantly clear, both verbally and in writing, to the Doctors !ospital and its staff that no private medical information was to shared with anyone including &edicaid. )/<. Defendants D,#T,"% !,%P0T 8 and the named medical staff Defendants were fully aware that F.#. would receive &edicaid benefits if F.#. was seized by state actors and that Plaintiffs' private medical information would be made available to &edicaid.

31

)/@. Defendant -arr or someone within DF#%, without Plaintiffs' consent and after F.#.'s unreasonable seizure, activated &edicaid for F.#. retroactive to December )st, 31)3. )/7. ,n 'anuary 3)st, 31)/ Defendant Dr. #artie shared Plaintiffs' private medical data with a third party by billing &edicaid L/;<. &edicaid paid Dr. #artie L)/3.<@. )/6. ,n February 3nd, 31)/ Defendant #artie's coGworker by the name of Bric B. Dewman shared Plaintiffs' private medical data with a third party by billing &edicaid for L@; and received L)@.@7. )21. Bric B. Dewman was also specifically restricted by Plaintiffs from sharing any information with &edicaid. )2). These egregious acts by Defendant #artie and his coGworker, Bric Dewman, of sharing private medical information with &edicaid, after being forbidden by Plaintiffs to do so, again indicates a pervasive and institutionalGwide indifference to the #onstitutionally secured rights of Plaintiffs. First Cause of Action Unreasonable Seizure and False Imprisonment in Violation of the Fourth Amendment to the U.S. Constitution ( ! U.S.C. "#$%& Claim' )23. Plaintiffs reGallege and incorporate by references all allegations set forth in the paragraphs above as if set out fully herein. )2/. Defendants "ichard #artie, !eyward =ells, 'ames #ole, Thomas Dorn, Trisha Foster, #hris !aga, Donna &asters, Terrell Aelverton, and 'ulie 8ewis worked collaboratively and in concert with state actors and Defendants 8isa "ambo, Patrick Bidson, Caran lbritton, %usan -arr, 'immy =ren, 'ane Doe, and 'anet Doe, under color of law, to deprive Plaintiff's of their right to be free from unreasonable seizures without probable cause, without a de (ure warrant, without e.igent circumstances, without

3)

parental consent , and by threat of force of arms. Defendants "ichard #artie, !eyward =ells, 'ames #ole, Thomas Dorn, Trisha Foster, #hris !aga, Donna &asters, Terrell Aelverton, and 'ulie 8ewis worked collaboratively and in concert with state actor 'immy =ren, under color of law, to falsely imprison F.#. and his parents within the Doctors !ospital of ugusta, $eorgia. )22. forementioned Defendants violated clearly established #onstitutional

rights of which a reasonable person in their positions knew or should have known. Second Cause of Action Unreasonable Seizure and Search of Pri(ate )papers) in Violation of the Fourth Amendments to the U.S. Constitution ( ! U.S.C. "#$%& Claim' )2;. Plaintiffs reGallege and incorporate by references all allegations set forth in the paragraphs above as if set out fully herein. )2<. Defendants 8isa "ambo, Bstella 8usane, %tacee Fussell, and Bdna &esser acting in concert and in such respective official capacities, not only failed to perform primary and superseding obligation *to protect Plaintiffs' and F.#.'s rights+ to Plaintiffs but manifestly acted contrary to said protective reHuirement and with willful intent to deprive Plaintiffs of their rights. %aid Defendants willingly and knowingly made operative a :# % : document *B.hibit D+ resulting in Plaintiffs being deprived of their Fourth and Fifth mendment rights. )2@. Defendant Bdna &esser was a willful participant engaged in (oint action with state actors in effecting the deprivation of Plaintiffs' rights. Defendants violated clearly established #onstitutional rights of which a reasonable person in their positions knew or should have known.

33

*hird Cause of Action +epri(ation of +ue Process in Violation of the Fifth Amendment to the U.S. Constitution ( ! U.S.C. "#$%& Claim' )27. Plaintiffs reGallege and incorporate by references all allegations set forth in the paragraphs above as if set out fully herein. )26. Defendants "ichard #artie, !eyward =ells, 'ames #ole, Thomas Dorn, Trisha Foster, #hris !aga, Donna &asters, Terrell Aelverton, 'ulie 8ewis, Bdna &esser, 8isa "ambo, Patrick Bidson, 'ames !urt, Caran lbritton, %usan -arr, 'immy =ren, 'ane Doe, 'anet Doe, %tacee Fussell, Bstella 8usane, and the Doctors !ospital, under color of law, deprived Plaintiffs of their due process rights e.pressed and guaranteed at the Fifth mendment. Defendants violated clearly established #onstitutional rights of which a reasonable person in their positions knew or should have known. Fourth Cause of Action +epri(ation of +ue Process in Violation of the Fifth Amendment to the U.S. Constitution ( ! U.S.C. "#$%& Claim' );1. Plaintiffs reGallege and incorporate by references all allegations set forth in the paragraphs above as if set out fully herein. );). fter unreasonably seizing F.#., Defendants lbritton and -arr neglected to

remove the Doctors !ospital 0.D. bracelet from F.#.'s wrist. The bracelet, fitting too tightly, girded the complete circumference of F.#.'s wrist causing substantial pain, discomfort, and an.iety for him. Therefore, Defendants lbritton and -arr, while acting under color of law, deprived F.#. of his due process rights to personal security and bodily integrity.

3/

Fifth Cause of Action Unreasonable Search of Plaintiffs, home and unreasonable seizure of Plaintiffs, t-o eldest sons in Violation of the Fourth Amendments to the U.S. Constitution ( ! U.S.C. "#$%& Claim' );3. Plaintiffs reGallege and incorporate by references all allegations set forth in the paragraphs above as if set out fully herein. );/. Defendant -arr unreasonably searched Plaintiffs' domicile and seized Plaintiffs' eldest sons, ".#. and D.#., in violation of the Fourth mendment. );2. Defendant -arr entered the Plaintiffs home without a warrant, without Plaintiffs' voluntary consent, and without any evidence of e.igent circumstance to (ustify said :search:. );;. Defendant -arr, by way of coerced consent , entered Plaintiffs' home and interviewed Plaintiffs' sons without parents present and without freely given parental consent. );<. The interrogation of both Plaintiffs' sons by Defendant -arr was an unreasonable seizure of both sons. Defendant -arr's entering of plaintiffs' domicile was an unreasonable search. Si.th Cause of Action Unreasonable Seizure of Plaintiffs, son/ F.C./ in Violation of the Fourth and Fifth Amendments to the U.S. Constitution ( ! U.S.C. "#$%& Claim' );@. Defendant D,#T,"% !,%P0T 8 of 4$4%T , 88# is animated by natural persons demonstrating an informal policy or custom which resulted in depriving Plaintiffs of their Fourth and Fifth mendment rights to not be unreasonably seized. );7. Defendant D,#T,"% !,%P0T 8 of 4$4%T , 88# consulted and collaborated with state actors to unreasonably seize and falsely imprison F.#. and both of

32

his parents without probable cause, without e.igent circumstance, and without parental consent. );6. Defendant D,#T,"% !,%P0T 8 of 4$4%T , 88# is a state created statutory fiction, animated by, among others, state licensed attorneys, and receives public monies by way of &edicaid and &edicare. !owever, said Defendant is not a state actor insofar as being authorized to e.ercise public trust powers. )<1. D,#T,"% !,%P0T 8 of 4$4%T , 88# *more accurately, the natural persons animating said 88#+ must reHuest or enable state actors to intervene on Defendant's behalf to impose Defendant's will through state actors, under the color of law presumption, to deprive Plaintiffs of their rights. )<). Defendant D,#T,"% !,%P0T 8 of 4$4%T , 88# utilizes an informal custom, in direct conflict with its own corporate policy, setting into motion or enabling to be set into motion events knowingly intended to deprive Plaintiffs of their inalienable rights via its bad faith and improper utilization of the "ichmond #ounty ,ffice of the %heriff , "ichmond #ounty DF#%, and &acon #ounty DF#%. +ama0es Defendants acting in concert and without warrant, probable cause, e.igent circumstances, or parental consent> a. breached the domestic tranHuility of Plaintiffs' family, friends, community and the security thereof M resulting in hurtful and e.cessive distress, aggravation and anguish. b. caused Plaintiffs to suffer from e.cessive and unwarranted diminution of both their reputations and en(oyment of their lives. c. caused physical in(ury to F.#.'s arm while in the care and keeping of the Public Trust. d. caused Plaintiffs to suffer debilitating trepidation insofar as interacting with

3;

pediatricians, nurses, hospitals, and private medical practices. Trepidation based upon the reasonable e.pectation that said interactions may result in Plaintiffs' sons being, again, unreasonable seized, neglected, harmed, or killed while in the care and keeping of the Public Trust. Pra1er for 2elief =herefore, the Plaintiffs respectfully reHuest that this #ourt to> ). Declare that the actions of Defendants violated the Plaintiffs' rights certain of which are e.pressed and guaranteed withing the 4.%. #onstitutionN 3. Find that the Defendants intentionally and unlawfully violated the Plaintiffs' inalienable rights certain of which are e.pressed and guaranteed within and by the #onstitutionN /. For general and special damages according to proof at the time of trialN 2. For costs of suit and interest incurred hereinN ;. For punitive damages for Defendants' conduct in willful and wanton disregard for the rights of the PlaintiffsN <. @. ny further in(unctive or declaratory relief this court deems (ust and properN ward monetary damages payable to Plaintiffs in #onstitutional lawful money

gold and ? or silver coin as e.pressed in rticle 0 %ection )1 of the #onstitutionN 7. That Plaintiffs' demands for all issues to be decided by the 'ury demandedN 6. 0f Defendants move to dismiss this suit then Plaintiffs demand this case to be heard by the 'ury demanded and only dismissed if the 'ury considers this case to be lacking in merit.

3<

Dated this @th day of 'anuary, 31)2,

"espectfully submitted,

*redacted father+ , &*redacted mother+, PsyD. P.,. -o. /)) 0deal, $eorgia /)12) Phone> *redacted+ Bmail> section)67/suitOgmail.com Plaintiffs *propria persona+

3@

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Exhibit A

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OF COURT INTTIBJUVENII,E STATEOF

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F[pil ONYOF, "^ 14lar*-

IN TIIETNTERBSTOF: CASE# 09+IU-VI9 MALE DOB: il29l2010 FEIFCRO$S SEX:

Child Underthe Age of l8

Oir}nR 72HOUR ntrASF{G ORDEn/TROTECTII'E

Thc sbove m*Hr is bofolt the Courtfor a 72 Hour andforegoing neeartnentof Human upontr (Conplaint[Pctition)filod by thc Georgia nsnedchild to be tbs lvlacm Counry DFAC$allqlng tlc above ondtbrrouglr in / for Courtwerc: IfrEscnt ( ) 0O (X) (X) il child: Motun SHARONHARVBY LsgslFsthr: DANCROSS
( ) Attomcy: ( ) Attomey:

DFC$:KARm.lALBRITTON& SUSANBARR CASA:

W. Jamer

Bascdqon tbc cnidme pruembd [or consentof the prentis)], the tblt tltcrc ir probable carsc to bcliovo thc abovo nrm6d child is depdved

O.C.O.A. 15.11-2(tXA): Soction Thc childwasbsrnin wudodqh tb her rnaidmnarnc. Theprnots uo mnrricdurd togdttr. Thc child urasbruncd, doctorar the Augrutr Bum Clinic odviredthal tlu chitd needed a ffianu wooldhavcn 25%chance of deathif hercceivsdtstmrg fto,mhis wounds.
r+louldaot eoffcnt

Nciths tlis childnor his riblirgr havee\rcr rtccivcd imruurizatlons. Thc uhil&tn sre hornc-dcboolod but not in complianoe $th the Macon Boad of Educdionrquircmonts.

Exhibit B
in the porot's crr$odywilhout idenrentim to have the Continuation wE lrot hhls bestinH'est imrnrmization custody Order in liar of seeking fhc ffepartnentsougtrta Protectivc hearhU, IT IS THE ORDEROF THE COURTthat custodyis TI-IBREFORE to ensurethe to thE purtnb wirh opervirion by ttrc Dedarhnefit restorcd aremet: requirumerns Thepatmtseieto: r . educati SuccqsfullycomplaePailntingclascs andimrnunizntion by thc Ioquircd conply with 8ll honnsechooting regulsdon$ CountyBosrdof Educdion r &rnue ssid child reccivecalt mcdicsl ctentistl rscommcnded provide,r rncdicsl by theDoportment roquostod . slgn anynclcreoo for futronnalion r Coopcrau wi& DFCSnndanyrcktodagwies

cusody, will resuh in thcchild boingtalrminto cmcrgency Any deviation to civil conternptparent will bcsubject non-complyitrg msdc ttopamcnt of Familysndchildrenscrvics TheMaconCounty of tfte ohild snl repiry &c &mily PrlG to tbc placement cffons to prescrvc
or climin*c thc nFal fDr tbc rennovalof tbc child from the lo p,rcryent cBne, makeit posslblcfor tbp child to rthm re&ly home.

this f IT Is SO ORDERED 10.201?.

2013,nuncPmhrnc dayofJnnuary

beT'Kn*h"
LiasC.Rmbo IudgeofJwmileCowt Georgn MaconCotmty,

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Exhibit B

UYI prceareif onOrr W. Htnt Jamcs cts#380100 19-l order10hourhcaring cros t2-2E0\?2 2012\Flint Fltwpwin\DFCSrnracon

Re: Unlswful Macon County , GeorgiaDFCS "Family Meeting" on February ,lth, 20l i
l)articipanls: rcdactedfather rcdactedntother rcr,lacted grandfather Klran ,\lhriton t'r'rrthialv{artin ilcvcrlv I'larris i :iirrllal,ttsant: I)lrtial lranscription of this coerced meeting's audiorecording: i\ls. llarris: Can you briefly kind of tell the teamhow DFCS got involvedrvith you all? \{other: I teel like my rightswerc violated. I f-eel like my son'srightswere violated. I contilrr:r,. i' thal wa,v. \l'b drd havc Flint rcturnecl to us irnd now we are under the court ordc.r.We are here, \\, , cturess. lundcr We are doing this because wc har,'e the threatof our child heingtaketrfrom us ul irrr,, time. We are cooperating,complying with the court order. .lustwant to get our family back tog:"ttr, our norrnal simple life with no intervcntionfrom an_vhody. Fathcr: (.oulclI add to that? lleverlv: You can. ' 1p l v u r t l r lather: l;irstandfirremostlrvantlomakeabsolutelyclearthatwedointendtolullycom e r . i l t i c c .l i r u r " l ' j r e b u l l e t p o i n t s o f t h e c o u r t o r d Itsaysbelowthefivebulletpoints:An1'deviali,'r,.., t'r:sull in llte child beingtakeninto emergency custodyand the non-cromply-ing parentwill be quh'tc, ; r'r\ rl c()ntempt. So it is prettyplain, in mv opinion ,thatwe'vegottado all five thingsand wcrc p:uiri: ,iri 11 11pilg1 durcssbecause wc arc) beingcoerced to do it. \fu'hen I sayduress. Mother and I hav,:rr , , , ll'ltl (rrlttcerlt that our child rvill be takenaway from us if we do not atlendrneetings and sign d{rt.nr,,, lhirt arc put irr front of us. lVev,ill sign documents and attend meetings,whateverlhe court tlqt,i:',. l:CL+: hec,ture /bel l:u!_:ts_a!_<_d!!-ing_i!-UAdeLd!.!'ess efuld wilt he harmed f not .fu": t: ",e tttt.tttt-trltlLutltuJ:lclt I r.vanted to sharcsomething rvith lou. \lftilc Flint was in fostercust(,,1, I' rrrl tllrtttagt:d he r.vas infured. \\truld 1'oulike to sec: evidence of that? i )l ( S. ct alia: No response and no indicationof interest to learnaboutFlint beins hanned. Father: I would like to show.vouwlmt happened to his arm. l"athcr:'lhc rcason I am sltorving \rlu this is becausc ir givesus the reascrnable e.xpectation thill rt , is takcn fiont us he vvill be harmed vidco and picsof Flirrt's {5iror.l'crl arm ro all.) Father: lt concemsus that this hasnever beenbrouglrtup... Kilran: Well that is thc first timc I haveseenthat or heardof that. Notc: \!'r never heardmention of thrs incident again irom anyone.

Exhibit C

Exhibit D

IN THE JWENIIT, COUNTOF lUE ff)TITEWT^STERNJTDICIAL INTEN COUNTYOT MACON

IN}IE.IbIJEBF$TOF:
Cros$.F:L

(a$-E-D{J!&E& D9B:
09+t2J{79 aEngil0

APPOIITTME.NT OT COURr APFOINTAD SPECIAL ADVOCAM

The cnurt hercby rypoinrr EsrcllaLusane ald cAsA sffi ss the court specielAdvocaie(cAsA) for tueabovo named dnor drild(rm) in thb caurg to O.C-G.A. Sectiorr 1.5-l t -9.It i8 nrilcr orrdcrcd th:
l. tJpn prcsentathn of this Gder, any agcnoy, ho$pital, school, org divisicur, or department of fre strb, doctor, nurso, ointhcr hsolth carc t{flnr't &cility, psychologi$,psych'rstrist,policc deporfncn! or mental clinic gtnll peirrit tho cASA who preents thi$ ore b inspecrand co rcqnnd-s or reporb rclatlng to thc child aador thc cbild's prnsng, pmtectedtpalth informcion, withorr consmt be the child or the child's 2. The CASA assignedfor {rc child(rcn) shall mlintEin any isfi}rmdion from any sourceas cmfidcntiaf d wilt not disclose srrcniorormstiott oral or $ritbn rcportst0 &c coort and as directed by the court to otber this pnoccoding. 3. Thc cAsA shEll b notifiod of my hoaring; shffing investigations, <lcp appeals'or orher puuodings oowning the child, and snll-be notified any action taksn on behalfof tic chlld by my pdty. 4' The cASA shau appearar dl court or child wetFarehcaringsor prccs relcing to tre child ud rupresent the child's best intsrastut *io hearings sthflr'i$e eirderod by thc Court 5. 'fhis
v6d

tin sto

any child uiho hasrqched agelB, for any child foil qaom m order of har treengranted,or for any child rryboce parrunett legal custodyor gua is granted by this Coun to the ctild's parent, relsti\,s, G other adult the C-rxnt

unlcssothrevisc ordcrcd by thccoufl" thfuo/ndr shalrtcrminatc

order shell rc{nain in frril frrrcc and effect until futhcr order of the for

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t,iss C. Rambo,Judge

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DAY

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Fo'/d M17.2012616P$FST 0y Jmalhan Dsvis

Exhibit E

ll mly lakos a sedd for hagedy lo slrik ju3t lik8 lhe shootino that t@k ple on Tucdsy al Univcr3ity Hosprta! .iohnrry Melles th Directo. of SKufty at Univtrsity h@pital tells re thev ksp a tight watch m people comino in and oul ot th hospital 6nd whai's going m lnside. He $ys thcre 6re proedures In place in tlE event ot a searity enErgncy. lik6 Trc|day'! 3hmt|ng. ' I hs osngral public ahould raalia trlat ws del wilh emroscirs 6vcryday we trsin annually s any klnd ot ev6nt thal you cn think cl. vve have polides md pmcedures in plae. And any ev6nt that takes plsce we pDbably h8ve swthing in drca to hedlo thst." sid Mllos Molle$ says lhat 6ach s$Urily olllctr oo the uniwrslty's fipus ls amd 6nd trsined lo use the,r werpon. Fle says trining 16 ssious busilress lf offtcers don't 9q, e lri0h elough on the $hootiog tst, they cs lrie their Job Mellft aleo says evon und6r a tighl watci, thre is no way to se vorything at 6ll tire$ and 3lill. UnNffiW ls ssfe plac6 almsl physicslly inrpos8rble wilh arry facility at f|is size lo checl everybody al every door I don't knw any hGpital in this area or rn Gesgla thal have nEdi.;l deteclors 6t every Ehgla dod that you cm in I Ju3t want lo lel you. and assure our sttt . pattsts, 8nd th CSRA thal you 6re a3 ssto as you willd be at any olhef larlitv rn the CSRA.' ssd Moies Chf Jeres Cole at Doctors tlosp(al agrees lite thjr en happen an!ryhere. wtlether il tts al 'll's

"Jusl likc msl hospilsls lhol don'l havc that EUs s(ml'lino 6 hogpltator mll d. anwhere els. Cole sys ''Wo he rukss trarnrng8lop prionty.'srd Cole.

hat/ our ofiEers go through irarnlrq where lhey cen identify pos3ible hidden weap69 on s Individual ,And we 6end them on that lrarf,rng onc o year on@ every six trDnlhs. Just lo Inow {hal to be of the l@koul fo(. Th fiBnnensryE ild also wdh cooealed weapons " sard Cole, Both Hogprtals dld want lo stEsg lhot thrs vras an rsot6ted inodent sd that thsy {m @\md {or any event thal $iddd ffiUr Thay also siared h@ lhey wofk closoly wrth lh Rrc'l|]6d Crunty Shdfts otrrc