IN THE SUPERIOR COURT OF LOWNDES COUNTY STATE OF GEORGIA 25 SM-9 By) KENNETH JOHNSON and JACQUELYN) : JOHNSON, ) Paints, ) CIVIL ACTION FILE ‘CABLE NEWS NETWORK, INC, NO: 2013-CV-1230 ) Intervenor ws ) CHRIS PRINE, as Sheriff of Lowndes County, ) Georgi, as wel a, in his individual capacity, and LOWNDES COUNTY SCHOOL ) DISTRICT, ) Defendants AMENDED COMPLAINT OF KENNETH JOHNSON AND JACQUELYN JOHNSO! NOW COMES KENNETH JOHNSON and JACQUELYN JOHNSON, Plant in the shove siyled anion, and who hereby sets forth this amended complaint te add the following causes of action against the Defendant CHRIS PRINE, in his official capacity as Sheriff of Lowndes Counts, Georgia, as wel sin his individual capacity, and demand for relief arising in connection therewith, Although this Complaint sets forth certain causes of action against the individuals and entities whose names or identities ae recited herein below, this Complain isnot to be construed as negation of Plaintiffs" claims against any other partis whose names or identities are not specifically set forth herein,JURISDICTION 1. The following causes of action asserted hereinafter ae in supplementation and notin substitution ofthe action which was originally brought by plants herein for violations ofthe open records ac, O.C.G.A.§50-18-70 et eg. 2. This Court has jurisdiction to adjudicate the claims asserted inthis amerded complaint ‘Venues proper inthis Cour. EACTS COMMON TO ALL CLAIMS 3. On Jamiary 10,2013, KENDRICK LAMAR JOHNSON (hereinafter sometimes referred toa “pleinti' decedent” or “pai son” orl" cild), an ican Arevcanstdent, was tending Lowndes High School n Valdosta, Lowndes County, Georgia. 4. Atsome poin during the affemoon of Jansary 10,2013, plaints decent led attend the balance of his scheduled classes, 5. Upon information and bei plant's decedent entered an area upon the Lowndes igh School campus whore, aftr either being induced by a fellow student oo to sd location or because of pif’ decedent's elatonship ta fellow student. plant" deeelent, encountered by Brandon Bell and Brian Bell, both of whom were fellow male students a said highschool and th ehilden of local PBI agent, Rick Bell 6. Upon information and belief, when plainsf's decedent rive at the aforementioned location, he was violently asauted by person, including but not ited to Brando Bell and Brian Bell, an, inthe course thereof, suffered a ftl blow which ldo his death 7. Following the Jeath of plant" decedent, if ot during the course of sail assault, ‘defendants placed the body of plaintiffs’ decedent inside ofa rolled-up gym mat and secludedsame inthe far southwest corner of the gymnasium that is commonly refered to as the “old ym” 8.On the moming of January 11, 2013, Plaintiff JACQUELYN JOHNSON came to said iff's decedent who had failed to return high school oinguieasto the whereabouts of ple home fom suid high school the evening before. 9. Upon information and bli, Lori Taylor ander younger sister Laina Taylor, who ‘were students at sid highschool and who are the daughters of Lowndes County Schoo! Distt school suerntendent Wes Taylor, alerted schoo! officals as othe loation ofthe body of Plains" decedent while it was sil in the suid olled-up gym ma 16, While wating in the administrative ofices of sid schoo, Plaintiff JACQUELYN JOHNSON was advised thatthe dead body of her son had been located in the ol gym 11 Inthe several hours which followed various members of he Iw enforcement agencies appeared a said high school forthe alleged purpose of investigating the death of| plains decedent 12 Representatives of the various aw enforcement agencies who artived atthe aforesaid high schoo shorly following the discovery ofthe body of plains” decedent included the Lowndes County Sheriff's Department, the City of Valdosta Police Department, the Valdos Lowndes, Regional Crime Laboratory (“VLRCL”) and the Georgia Bureau of Investigation “GB. 13 In addition to the aforesaid law-enforcement agencies, one ofthe first responders to arrive at the aforesaid high schoo! included two (2) emergency medical technicians (“EMT™) ‘who examined the body plaintiffs’ decedent while it was still in the aforesaid old gym.14, Of the various observations which were made by said EMTS, they noted that there ‘was bruise tothe right side of the jaw of plaintiffs" decedent. In preparing their eportregarding ils" decedent, said EMTs characterized the loction of their observations of the body ofp said body asa “crime scene.” 15, Notwithstanding the aforesaid observations of sid EMT, who upon infomation and belie were the fit and only medical expr to examine the body of plaints" decedem while it was sill inthe aforesaid ld gym, cach ofthe defendant law enforcement officers fale 0 follow appropriate procedure o ensure against the contamination ofthe area surrounding where the body of plaintii" decedent was allegedly discovered or located. 16. After Plaintiff JACQUELYN JOHNSON was notified that the body that had been located in the gymnasium was believe tobe her son, she along with other family members who amived atthe aforessd highschool, requested but were resed pemnssion by person cing under the authority and supervision of defendant to identity the body. 17, Notwithstanding the discovery ofa dead body and the presence of defendar: aw: ‘enforcement officals sai defendans knowingly and with malicious intent fied tonality the Lowes County Corner for approximately st (6) hours following the alleged discovery a the body of paint’ decedent 18, The aforesaid flue ofthe defendant Sheriff CHRIS PRINT to immediately nti ‘he Lowndes County Corener was in deliberate violation of the laws ofthe tate of Georgie, more specifically identified 85 O.C.G.A § 45-16-24, which states, in relevant pat that “it hal be the duty of any law enforcement fice or eter person having knowledge of such death o notify immediatly the comer or county medical examiner ofthe county in which the aor ‘events resulting inthe death occurred othe body is found,”19, Notwithstanding the discovery of dead body, the aforesaid observations of EMTS, aswel as, the lbcation of blood ofan identified source that was observed upon the surfaces of walls tht were proximal tothe location ofthe body of plaints decedent, Defendant CHRIS PRINE, expressed tothe news media on January 11,2013 that there was no evidence of “oul pay” and thatthe case of death was accidental based upon a heory that lini’ decedent ded as a est of him attempting to retieve a tenis shoe by entering ino the center opening ofthe aforesaid rolled-up gym mat and thereafter becoming stuck and without the ability to te hms 20, Ono about January 12,2013, Plaintiff KENNETH JOHNSON requested pemisson to view te body of plaints" decedent, but was also refused permission by de‘endans. 21, Following the aforementioned denial of permission by defendants tallow plants JACQUELYN JOHNSON and KENNETH JOHNSON to view and identity te body of their deceased son, plaintiffs contacted the news media and conducted a press conference to vive their concerns regarding the kindof treatment tht they were receiving from sid defendant ‘embers of the law enforcement community, more particularly the Lowndes County Sherif's Department andthe Vatiosta-Lowndes, Regional Crime Laboratory. 22. Upon information and belief, defendant Sheriff CHRIS PRINE and members of the Lowndes County Sherifs Department, the City of Valdosta Police Department, and the ‘Valdost-Lowndes, Regional Crime Laboratory reconsidered ther positon regering the Pim’ request o view the body of thei som and, as a consequence, granted them permission to come tothe Valdosta Lowndes, Regional Crime Laboratory for purposes of viewing the bod. 23, On January 13, 2013, pails JACQUELYN JOHNSON and KENNETH JOHNSON went to the Valdosta-Lowndes, Regional Crime Laboratory where they were met bydefendant Sheriff CHRIS PRINE and other members ofthe Sheriff's Department for purposes of viewing the body of plaints" decedent. On tha occasion, plaintiff KENNETH JOHNSON entered the room where the body of pains" decedent was beng stored and noted tha the room temperature appeared to be much warmer than what he had antieipated inasmuch ashe thought that sid room and the vault that the decedent's body was in was designed to preserve the remains through process similar to refigertion 24, At that time, defendant Sheriff CHRIS PRINE explained to plaints hat pint’ decedent had enteral the center hole ofthe aforementioned ey mat “eet frst” andthe while et te botom ofthe hale, plaints decedent bent over to retrieve his tenis shoe and became stuck in such «way that could not ee or emove himself from te hot. 25. Upon hewing the foregoing explanation, plaintiff KENNETH JOHNSON stated to Shesff CHRIS PRINE that his explanation was not posible, whereupon STRYDE JONES stated to plaintiff KENNETH JOHNSON that he (KENNETH JOHNSON) did not understand that “wen you die, your musles relax and then you fll forward.” 26, Approximately two (2) or more days late, an ex-employee ofthe Lowndes County Sherif’ Deparmert contacted paintitf KENNETH JOHNSON and stated to hr that he (KENNETH JOHNSON) misunderstood whet defendant Sheriff CHRIS PRINE and STRYDE JONES had attempted to explain to plaints and that ther explanation was mest o explain tht plainf's decedent had entered the center hole ofthe gym mat head first instead of feet first 27. Due to the aforessid findings of no foul play” anda theory offered by defendant Sheriff CHRIS PRINE, Pl [s KENNETH JOHNSON and JACQUELYN JOHNSON were ); KENNETH JOHNSON and JACQUELYN) JOHNSON, ) ) ) Plainitt, CABLE NEWS NETWORK, INC., Intervenor vs. ) CHRIS PRINE, as Sheriff of Lowndes County, ) Georgia, as wel as, in his individual capacity capacity, and LOWNDES COUNTY SCHOOL ) DISTRICT, ) Defendants CIVIL ACTION FILE NO: 2013-CV-1230 CERTIFICATE OF SERVICE | hereby certify that I have served AMENDED COMPLAINT BY KENNETH JOHNSON AND JACQUELYN JOHNSON, by email and US mail on the following counsel of recor: Bric Schroeder, Esq. Bryan Cave, LLP One Atlantic Center-14* Floor 1201 W. Peachtree Street, NW ‘Atlanta, GA 30309-3488 1. Warren Turner, Je, Esq Post Office Box 157 Valdosta, GA 31603, ‘This 9” day of January 2015, Prepared by: Chevene B. King, Jr Post Office Drawer 3468 Albany, GA 31706 (229)136-0524 James L Elliot, Eso. Elliott, Blackburn & Gooding, PC 3016 N. Patterson Street Valdosta, Ga 31602 Attorney for Plaintiffs State Bar No.: 420105