in the united states district court for the …...6. defendant bobby g. “robby” robinson...

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF GEORGIA

BRUNSWICK DIVISION

COURTNEY WARD, as next friend of ) J.E., a minor, ) )

Plaintiff, ) vs. )

) CIVIL CASE NO.______________ )

MCINTOSH COUNTY SCHOOL ) DISTRICT and BOBBY G. ROBINSON, ) )

Defendants. ) )

)

COMPLAINT

COMES NOW the Plaintiff, COURTNEY WARD, as next friend of J.E., a minor, and

files this Complaint against Defendants MCINTOSH COUNTY SCHOOL DISTRICT and

BOBBY G. ROBINSON, alleging that the Defendants acted in violation of federal and state law,

as well as rights established under the United States Constitution, showing as follows:

INTRODUCTION

1. This civil rights and negligence action seeks compensatory and punitive damages from the

Defendants as a result of injuries sustained by the Plaintiff in an act of hazing committed by

other student athletes. This act of hazing as to the Plaintiff was foreseeable and avoidable. The

Defendants had actual knowledge of hazing activity in general and the threatened hazing of the

Plaintiff, but rather than act in a timely manner to address student hazing, Defendants instead

acted to excuse, condone, and even perpetuate the practice of hazing, enabling for the injurious

hazing of the Plaintiff. In so acting, the Defendants also deprived the Plaintiff of his right to

bodily integrity under federal law and the United States Constitution.

2:18-cv-13

Case 2:18-cv-00013-LGW-RSB Document 1 Filed 02/12/18 of 19

staylor

FileStamp

JURISDICTION and VENUE

2. This civil rights action is brought pursuant to, inter alia, the Fourteenth Amendment to the

United States Constitution, 42 U.S.C. §§ 1983. This Court has jurisdiction over federal claims

pursuant to the constitutional provisions enumerated and 28 U.S.C. § 1331 and § 1343 (3) and

(4), as they are brought to redress deprivations of rights privileges and immunities secured by the

United States Constitution and by law. This Court has supplemental jurisdiction over the state

claims pursuant to 28 U.S.C. § 1367.

3. Venue is proper in the Southern District of Georgia under 28 U.S.C. § 1391(b), in that

Defendants are located in this state and district and division, and a substantial part of the acts

and/or omissions giving rise to Plaintiff’s claim occurred in this district.

PARTIES

4. Plaintiff Courtney Ward (hereinafter “Ward”) is a resident of McIntosh County, Georgia. She

is the mother and legal guardian of J.E., a minor, on whose behalf she is bringing this suit.

5. Defendant McIntosh County School District (hereinafter “MCSD”) is a corporate entity

capable of suing and being sued pursuant to the laws of the State of Georgia, located within the

geographical boundaries of McIntosh County, Georgia.

6. Defendant Bobby G. “Robby” Robinson (hereinafter “Robinson”) is a former football coach at

McIntosh County Academy. Robinson is being sued in his individual capacity.


FACTUAL BACKGROUND Robinson’s Employment with MCSD

7. Robinson had previously been employed by MCSD for a period of time several years prior to

2015 and prior to the incident which is the subject of this action, but was allowed to resign amid

allegations of misconduct.

8. Robinson was a public employee re-hired by MCSD as the head football coach and athletic

director at McIntosh County Academy (hereinafter “MCA”) in February 2015.

9. In the intervening period between his initial employment by MCSD and his rehiring in

February 2015, Robinson was employed by other school districts in Georgia and, while thus

employed, was the subject of complaints and disciplinary action concerning misconduct toward

students and other coaches.

10. MCSD was aware of Robinson’s history of misconduct at MCA and other schools within the

state of Georgia when it chose to re-hire him in February 2015.

MCSD History of Enabling Student Exposure to Abuse, Safety Violations, and Hazing

11. In recent years, MCSD has been the subject of investigations into misconduct by teachers

and school administrators which conduct directly endangers students’ safety and welfare while in

the MCSD created and regulated environment. Most notably, during the 2013-2014 academic

school year, a teacher at MCA sexually abused at least one student while school administrators

and members of the Board knowingly concealed and/or failed to report the abuse to the proper

authorities. Several of these school officials, including the MCA principal and MCSD

superintendent at the time, were subsequently charged criminally for their roles in this incident.


12. On October 6, 2015, Superintendent of McIntosh County Schools, Dr. John Barge (“Barge”),

contacted McIntosh County Chief of Campus Police Daniel Lodise (“Lodise”) regarding an

incident reported to him by MSCD Board member Joe Maulden, in which Robinson had

allegedly punched a student in the chest during a football game approximately two weeks prior.

13. Lodise conducted an investigation as to whether a basis existed to bring criminal charges

against Robinson which substantiated the incident, however charges were not brought at that

time, in large part, because the victim’s mother requested that no criminal charges be brought

against Robinson related to the incident.

14. On August 17, 2016, McIntosh County Academy Principal Barry Lollis (“Lollis”) addressed

student athletes being subjected to weather-related heat and lighting violations by Robinson, the

same being a threat to student safety, as a result Lodise initiated an investigation into the matter.

15. After conducting g an investigation in which Lodise substantiated the foregoing allegations

as credible, he filed a Department of Family and Children Services notification in accordance

with state law and contacted the Georgia Bureau of Investigation for assistance.

16. On or about August 17, 2016, Lollis complained to Lodise regarding student disclosed

incidents of student “hazing” occurring on the MCA football team and potentially other MCA

teams after which Lodise began an investigation into the instances of “hazing.”

17. On or about August 17, 2016, Lollis addressed the foregoing issues of student safety

violations and student “hazing” with his superior, Barge.


J.E. becomes the Victim of “Hazing”

18. On Friday, August 26, 2016, while participating in a MCA football game, J.E. was threatened

with a “hit” by another student-player, “A.R.,” for not cheering loudly enough. A.R. stated the

“hit” would be carried out during the next MCA football practice.

19. Such “hits” consisted of one player, usually a senior player, intentionally ramming or

tackling the targeted player, usually a freshman player, with great speed and force when the

targeted player was not expecting the “hit” thus blindsiding the victim.

20. Such “hits” had already occurred after initiation of the 2016 season during summer practice

and prior to the threat directed to J.E. on August 26, 2016.

21. After the game on August 26, 2016, Ward, advised Robinson of the direct threat to J.E. in an

effort to avoid physical harm occurring to J.E. Robinson expressly assured them that he would

handle the situation.

22. On or about the morning of Monday August 29, 2016, Lollis sent an e-mail to all MCA

football coaches, including Robinson, addressing the issue of hazing of players on the football

team, and further described one such disclosed incident in which a student had been physically

forced into a trash can by teammates. Lollis directly instructed Robinson to address the matter

with the football team and further, in his capacity as the athletic director, to address the issue

with all other coaches to ensure hazing was addressed with all MCA teams.

23. On or about the afternoon of Monday August 29, 2016, Lollis spoke to Robinson instructing

him for the second (2nd) time to address the hazing issue.


24. On August 29, 2016, at afternoon football practice, Robinson willfully failed to address the

issue or incidents of “hazing” with the players as instructed and further willfully failed to address

the direct threat of “hazing” to J.E.

25. On or about the afternoon of Monday August 29, 2016, Lollis spoke with Barge to schedule a

joint meeting with Robinson to address the issue and incidents of “hazing.”

26. On or about August 29, 2016, MCSD Board members James McKinzie (hereinafter

“McKinzie”) and Bonnie Caldwell (hereinafter “Caldwell”) made separate phone calls to Lodise

to discuss the ongoing respective criminal and administrative investigations of Robinson by

Lodise and Lollis. During the course of both calls, both McKinzie and Caldwell sought to

persuade Lodise that Robinson’s conduct was not criminal, advised the matter did not warrant

further investigation, and that Lodise should instead investigate Lollis for harassing Robinson.

27. Lodise advised McKinzie and Caldwell if they had knowledge of any incidents of harassment

or potentially unlawful conduct by Lollis to provide the same and an investigation would be

initiated immediately. Neither McKinzie nor Caldwell was able to provide any such information

and as such Lodise did not initiate an investigation involving Lollis.

28. Subsequently, Caldwell contacted Lodise by text message and instructed him to hand over

the investigation to the McIntosh County Sheriff’s Department. Lodise objected to this

instruction due to the nature of the investigation involving activities of school personnel on

school grounds and further conferred with the Sheriff of McIntosh County who agreed the

investigation should remain under the jurisdiction of the campus police.

29. On or about the morning of Tuesday August 30, 2016, Lollis and Barge met with Robinson

specifically to address the issue and incidents of “hazing” on the MCA football team. Said


meeting addressed recent known incidents of “hazing”, including incidents of blindside “hits” on

students at practice by other students as punishment for various supposed infractions. Lollis

directed Robinson to immediately speak to the football team about “hazing” at the next practice,

which was scheduled for that afternoon.

30. On Tuesday, August 30, 2016, at afternoon football practice, Robinson again willfully failed

to address “hazing” with the football players, as he was instructed now on three (3) separate

occasions by his superiors, and again willfully failed to address the direct threat of “hazing” to

J.E. as advised by J.E.’s mother and grandmother on August 26, 2016.

31. During said practice on August 30, 2016, J.E. was blindsided (“hit”) by another player at the

express instruction of AR. This “hit” was not performed during the course of a play, drill, or

exercise, and further came from a direction outside J.E.’s line of sight; as such J.E. was not

physically prepared, or even able to prepare, for the brute force impact.

32. J.E. was not provided any medical treatment after the “hit” and was required to complete

practice before he was able to call a family member for help. Ward and her mother both

responded to the school to check on J.E. and address the matter with Robinson.

33. Ward spoke with Robinson to inquire why he had failed to address the threatened “hazing” as

he had previously assured her of the same. Robinson advised that J.E. needed to “toughen up”

and dismissed her complaints without further discussion.

34. The “hit” on J.E. resulted in several severe injuries, including a concussive brain injury and

multiple bruised ribs. J.E. was required to miss several weeks of school in order to recover from

these injuries. At the present, J.E. still suffers from headaches, and Ward has noted behavioral


and emotional changes to J.E. since the incident, including anger management issues, that were

not present before the incident.

35. Ward contacted Caldwell to complain about the incident, Robinson’s prior knowledge, his

assurance to address the issue to protect J.E., and his attitude after the incident occurred.

Caldwell instructed Ward to contact Lodise.

36. Ward contacted Lodise to complaint about the incident and specifically Robinson as

instructed and Lodise immediately initiated an investigation, the third (3rd) separate investigation

into allegations involving Robinson after the commencement of the 2016 MCA football season.

37. During the course of the investigation into all alleged incidents of hazing, complaints against

Robinson, and the J.E. incident Lodise learned that several other students had also been

subjected to “hits” as part of “hazing” by older students.

38. GBI, who had previously initiated an independent investigation into the allegations involving

Robinson and student safety violations expanded the purview of its investigation to include the

allegations of “hazing” which required cooperation from Lodise and MCA administration.

Lodise advised Barge, to the extent possible without inappropriately hindering said investigation.

Aftermath of “Hazing”/Child Abuse Complaints Against Robinson

39. Prior to the next regularly scheduled MCSD board meeting MCA administration suspended

Robinson for a period of less than one week which resulted in Robinson being absent for one (1)

football game.

40. On September 12, 2016, at the first regularly scheduled session of the MCSD board to occur

after the “hazing” incident involving J.E., and after Robinson’s short suspension, Ward and her


mother, Gidget LaRoach, both publically addressed the entire board. Ward advised the board

members as to the chain of events leading to her son’s injury, her discussion with Robinson

warning him of the threat, her discussion with Robinson after the incident, and her desire that a

thorough investigation take place.

41. At the conclusion of public comment section of the meeting the board members recessed to

have an executive session. Upon returning from executive session the first item of new business

was a motion by board member McKinzie to transfer Lollis from acting principal of MCA to

acting principal of the county’s alternative high school currently only responsible for two (2)

students. Said transfer was approved over the express repeated objections of Barge, and despite

knowledge of Lollis’s role as a witness in an ongoing GIB criminal investigation involving

Robinson. The motion passed to transfer Lollis.

42. At no time during said MCSD board meeting on September 12, 2016, did the board address

any allegations or concerns involving Robinson or necessary action the MCSD should take to

ensure student safety while engaged in team sports at MCA.

43. On or about September 15, 2016, MCSD attorney expressly advised MCSD board regarding

the decision to transfer Lollis and advised it was likely best to reverse their decision to transfer

Lollis and grant him an 1160 hearing in the event Lollis requested the same.

44. On or about September 19, 2016, at the next regularly scheduled MCSD board meeting Lollis

publicly addressed the board in its entirety. He reminded the board of his legal and ethical duty

to ensure the safety and well-being of students under his care and addressed allegations his

actions were undermining the MCA football program. He expressly requested he be awarded an


1160 hearing to have the matter and his actions thoroughly reviewed. The MCSD board did not

grant his request but rather affirmed its prior decision to transfer him made September 12, 2016.

45. J.E. was the victim of relentless teasing, harassment, and bullying by other students as a

result of the public attention the “hazing” incident had received. This emotional distress

continued through the remainder of the 2016/2017 academic year.

46. Robinson’s actions in contributing to, and knowingly allowing for, if not outright

encouraging, student “hazing,” including the incident involving the J.E., are an actionable

criminal offense which resulted in his indictment by a grand jury in March 2017.

47. At no time prior to being indicted did MCSD board terminate Robinson’s employment or

seek his resignation. Rather, a few days following Robinson’s indictment, Robinson elected to

voluntarily resign from MCSD.

48. The MCSD board only took action to administratively discipline Robinson or address

allegations of “hazing” and student safety after the 2016 football season had concluded thus

allowing Robinson to remain in his position as the athletics director and head football coach at

MCA until the spring of 2017.

49. In June of 2017, after months of equivocating on the matter of Lollis’s employment, which

ultimately included a transfer to another school, termination, and reinstatement as Principal of

MCA, the Board decided not to renew his employment contract with MCSD for the 2017-18

school year amid allegations of improper interference by board members with ongoing criminal

investigations and state regulatory reviews conducted by Advanced Ed on behalf of the

Department of Education.


50. At said June 2017 MCSD board meeting after voting to not renew his employment, Lollis

asked the board to elaborate on this course of action, he was told that the Board’s decision was

“due to a change in direction.”

51. In the months leading to June 2017 the MCSD board discussed the possible termination of

the MCSD police department.

52. In June of 2017 at the same board meeting in which the MCSD board elected not to renew

Lollis’s employment the board, under public pressure to maintain the campus police department

as an independent department, voted unanimously to renew Lodise’s employment contract for

the 2017-18 fiscal year with an effective of July 1, 2017.

53. On or about June 30, 2017, a date subsequent to the regular Board meeting described above,

the Board held an executive session during which Lodise was approached by the current Board’s

attorney and current School Superintendent who informed Lodise the Board wanted him to

tender his resignation or the Board would entertain a vote to terminate his employment in

upcoming weeks. Lodise did not have any direct communication with Board members regarding

the information.

54. On July 1, 2017, Lodise signed and received his copy of the employment contract, which

outlined the offer of renewal unanimously offered by the Board in June, thereby accepting the

renewal of his employment as Chief of Campus Police.

55. On or about July 30, 2017, Lodise received and accepted his monthly salary pursuant to the

employment contract.


56. On August 7, 2017, before the close of business, Lodise tendered a letter of resignation to the

Board seeking a postponed date certain to cease employment to allow Lodise time to secure

alternative employment.

57. On or about August 7, 2017, during a regular Board meeting McKinzie made a motion was

made to terminate Lodise’s employment effective on August 11, 2017, which the Board voted to

pass 4-1 thereby effectively refusing to accept his resignation.

58. In terminating Lodise’s employment, the Board made no finding, nor did it allege, that

Lodise had violated the terms or conditions of his employment contract.

59. The Board’s publicly stated rationale for terminating Lodise’s employment was that MCSD

was going in a “different direction.”

60. In August 2016, Lollis and Lodise separately filed suits against MCSD, alleging that they had

been terminated or released from employment in violation of Georgia’s Whistleblower statute .

Both of these suits are still pending.

CLAIMS FOR RELIEF

COUNT I NEGLIGENCE PER SE

(Against Robinson)

61. Ward reasserts and re-alleges paragraphs 1 through 60, inclusive, as though fully set forth

herein.

62. Section 505-6-.01 of The Code of Ethics for Educators states as follows:

(a) Standard 1: Criminal Acts – An educator should abide by federal(a) Standard 1: Criminal Acts - An educator should abide by federal, state,


and local laws and statutes. Unethical conduct includes but is not limited to the commission or conviction of a felony or of any crime involving moral turpitude. As used herein, conviction includes a finding or verdict of guilty, or a plea of nolo contendere, regardless of whether an appeal of the conviction has been sought; a situation where first offender treatment without adjudication of guilt pursuant to the charge was granted; and a situation where an adjudication of guilt or sentence was otherwise withheld or not entered on the charge or the charge was otherwise disposed of in a similar manner in any jurisdiction.

(b) Standard 2: Abuse of Students - An educator should always maintain a professional relationship with all students, both in and outside the classroom. Unethical conduct includes but is not limited to: 1. committing any act of child abuse, including physical and verbal abuse; 2. committing any act of cruelty to children or any act of child endangerment; 3. committing or soliciting any unlawful sexual act;

63. McIntosh County Schools Board Policy GBU states as follows:

Standard 1: Criminal Acts - An educator should abide by federal, state, and local laws and statutes. Unethical conduct includes the commission or conviction of a felony or misdemeanor offense, including DUI/BUI, but excluding minor traffic violations such as speeding, following too closely, improper lane change, etc. As used herein, “conviction” includes a finding or verdict of guilt, a plea of guilty, or a plea of nolo contendere.

Standard 2: Abuse of Students-An educator should always maintain a professional relationship with all students, both in and outside the classroom. Unethical conduct includes but is not limited to: committing any act of child abuse, including physical and emotional abuse; committing any act of cruelty to children or any act of child endangerment….

64. The Georgia Professional Standards Commission defines moral turpitude as

follows:

“Turpitude in its ordinary sense involves the idea of inherent baseness or vileness, shameful wickedness, depravity with respect to a person’s duty to another or to society in general. In its legal sense it includes everything contrary to justice, honesty, modesty or good morals.”

65. Robinson’s abuse and endangerment of J.E., a student at MCA, violated Section 505-6-.01

of The Code of Ethics for Educators, the Standards promulgated by the Georgia Professional


Standards Commission, and Board Policy promulgated by McIntosh County Schools Board of

Education.

66. Robinson’s violation of Board Policy and the Ethical Code were each substantial factors in

causing harm to J.E.

67. J.E. was within the class of people the Board Policy and the Ethical Code provisions were

intended to protect. The abuse he suffered was the type that these provisions were intended to

protect against.

68. As a direct and proximate result of Robinson’s violations of Board Policy and the Ethical

Code, J.E. has suffered general and special dames, more specifically J.E. suffered physical

injury, required to undergo medical treatment, miss several weeks of school, and endure

emotional distress and bullying. Said damages are in an amount to be proven at trial.

COUNT II.

INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS (Against Robinson)


herein.

70. Robinson’s abuse and endangerment of J.E. coupled with his duplicitous response to the

threat of violence, and his blatant dismissal of J.E.’s actual injury and pain in telling Ward he

needed “to toughen up,” was intentional and outrageous conduct.

71. As a direct and proximate result of Robinson’s intentional conduct, J.E. has suffered general

and special damages, more specifically J.E. suffered physical injury, was required to undergo

medical treatment, miss several weeks of school, and endure emotional distress and bullying.

Said damages are in an amount to be proven at trial.


72. J.E. further requests punitive damages because Robinson acted with oppression, fraud and

malice, willfully and wantonly, and in conscious disregard of J.E.’s rights and safety.

COUNT III. (VIOLATION OF 42 U.S.C. § 1983 – DENIAL OF LIBERTY INTEREST IN

BODILY INTEGRITY UNDER THE DUE PROCESS CLAUSE OF THE 14TH AMENDMENT TO THE U.S. CONSTITUTION)

(Against Defendant MCSD) 73. Ward reasserts and re-alleges paragraphs 1 through 60, inclusive, as though fully set forth

here.

74. Minors, and thus students, have a recognized liberty interest in their bodily integrity

protected pursuant to the Due Process Clause of the 14th Amendment to the U.S. Constitution.

It is well established that in the educational setting the respective school district is standing in

loco parentis and as such the school district is required to take reasonable steps to ensure the

physical safety of the students under its care and/or supervision. While the Defendant is not

required to ensure complete safety from the myriad of unforeseeable possible actions of fellow

students it is required to provide students with an environment free of faculty/teacher created

danger, the same representing a fundamental aspect of any school system standing in loco

parentis. The school system cannot take steps which endanger the physical wellbeing of a child

which if taken by a parent would be deemed criminal conduct.

75. MCSD, acting under color of law, by policy, custom, or practice, unlawfully and

intentionally endangered J.E. in violation of the 14th Amendment to the U.S. Constitution, when

it engaged in the widespread practice over the course of months, if not years, to conceal

allegations of teacher created physical harm to students, attempt to derail or force the termination

of investigations into teacher created physical harm to students, and to repeatedly elect to not

limit the supervisory and/or authority of the subject teacher as to students under his/her


supervision and/or care. Evidence of said policy, custom or practice is first seen during the

investigation and eventual arrests of a former MCSD superintendent, MCA principal, and MCA

teacher after said teacher engaged in an unlawful sexual relationship with at least one student.

MCSD continued the same policy, custom or practice to engage the widespread practice to

conceal and permit the continued environment of faculty/teacher created physical harm to

students when it carried out the same conduct in the instant case.

76. At all times relevant hereto Robinson was employed by MCSD which had supervisory

authority over Robinson and as such were able to take action at any point in time.

77. MCSD had actual knowledge of Robinson’s propensity to abuse students, place students in

circumstances which violated student safety regulations and as well as Robinson’s condoning

and/or encouragement of hazing, prior to J.E.’s injury and as such Defendant’s actions were

taken with deliberate indifference to the obvious consequences it would have as to J.E.’s rights

under the Due Process Clause to a liberty interest in his bodily integrity.

78. Moreover, MCSD, as policymaker, proximately caused J.E.’s injuries and damages by

failing to institute adequate protective policies and/or following harmful firmly-rooted customs

in the following ways:

a. Failing to train and supervise its teachers adequately concerning their interaction with

students;

b. Failing to train school officials regarding the proper manner in which to investigate

complaints concerning student-on-student hazing;

c. Failing to train and supervise its teachers and officials regarding the proper manner for

reporting suspected child abuse;


d. Failing to adequately supervise Robinson, especially after learning of the numerous

allegations of child abuse and child endangerment;

e. Failing to adequately discipline Robinson for abuse/misconduct toward student

athletes;

f. Failing to limit Robinson’s supervisory and authoritative role over the students under

his care and/or control;

g. Responding with deliberate indifference to substantial credible evidence of teacher

misconduct arising to the level of a crime;

h. Responding with deliberate indifference to substantial, credible evidence to teacher

misconduct arising to the level of a crime and failing to follow the procedures prescribed

by law to address such misconduct;

i. Failing to establish adequate procedures for reviewing teacher performance, in general,

and complaints involving allegations of misconduct related to the physical safety of

students by teachers in particular;

j. Acting to punish and thereby deter the MCA school administration from following

proper protocol to document and report suspected child abuse as well as any potential

violations of student safety regulations;

k. Attempting to divert a police investigation by the MCSD Campus Police into

Robinson’s conduct and the incidents of known physical harm to students.

79. The facts and circumstances of this particular case, and the facts and circumstances

involving Robinson abusing and endangering other student athletes and his wanton disregard for

J.E.’s physical wellbeing demonstrate the unreasonableness of Defendant’s actions. Defendants

failed to remedy known historical custom and/or practice which resulted in an environment of


faculty/teacher created physical harm to students; to institute, maintain and enforce the proper

procedures, customs, and/or measures to prevent the acts in question as a matter of policy, which

allowed and caused the alleged events to occur.

80. As a direct result, J.E. was subjected to serious physical injury, to which he did not consent

and for which he did not assume the risk, thus violating his constitutional right to bodily

integrity.

81. As a direct and proximate result of Defendants’ intentional actions, J.E. has suffered

damages in an amount to be proven at trial.

82. Pursuant to 42 U.S.C. §1988, Ward is entitled to costs of suit herein, including attorneys’

fees.

IV. PUNITIVE DAMAGES


herein.

84. The conduct of the Defendants set forth above and herein was willful, wanton, and

intentional and evidences a want of care which raises the presumption of conscious indifference

to the consequences.

85. As an actual and proximate result of the willful, wanton, and intentional conduct on the part

of Robinson and MCSD, J.E. suffered general damages for physical pain and suffering, mental

pain and suffering, needless agony, loss of his dignity, loss of his reputation, and cost/expenses

for having to bring this lawsuit. The measure of damages will be determined by a fair and

impartial jury.


DEMAND FOR JURY TRIAL

86. Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Ward respectfully demands a trial by jury for all issues in this case that are so triable.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff COURTNEY WARD prays for judgment against

Defendants, and each of them, as follows:

1. For money damages according to proof; 2. For pre and post-judgment interest on money damages allowed by law; 3. For costs of suit herein, including attorneys’ and expert fees; 4. For punitive damages according to proof; and 5. For such other and further relief as the court may deem proper. Respectfully submitted this 12th day of February, 2018.

MITCHELL & REDDOCK, LLC.

/s/ Scott G. Reddock_______

SCOTT G. REDDOCK Georgia Bar No. 476162

KATIE S. MITCHELL Georgia Bar No. 106088 Attorneys for Ward

111 West Court St. Hinesville, GA 31313 Phone (912) 332-7077 Facsimile (912) 332-7179 Email: [email protected]


Case 2:18-cv-00013-LGW-RSB Document 1-1 Filed 02/12/18 Page 1 of 1

in the united states district court for the …...6. defendant bobby g. “robby” robinson...

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