Electronically Filet Eviea L. Woodford, Cla Bibb County Superior Cour Docket Date: 7/7/2047 3:07:51 PD Raven Alston IN THE SUPERIOR COURT OF BIBB COUNTY STATE OF GEORGIA KENNETH JOHNSON and JACQUELYN: JOHNSON, and JACQUELYN JORNSON, as Administrator for and on Behalf of he Listate of, Kendrick Lamar Johnson, Plaintifis BRANDEN BELL; BRIAN BELL: RICHARD “RICK” BELL, ia his individual and official capacity, RYANTIATI5 (CURIS PRINT, in his individusl and. officiel capacity as Sheriff of the LOWNDES COUNTY SHERIFF'S DEPARTMENT; WILLIAM “WES” TAYLOR io tals iidividual and official capacities as Superintendent, LOWNDES COUNTY SCHOOL DISTRICT; JAMES D, THORNTON, in his individual andl official capacities; VRANK SIMMONS, in his official and individual capacities, RAY MCGRAW, in fis official and individual ‘capacities; JACK WINNINGITAM, in his official and ‘individual capacities; WANDA EDWARDS, in her official and individual eapecities: STRYDE JONES, in bis official and individual capacities, AARON PRITCHETT, in his official and individual capacitios: LOGAN HENDERSON, ir his official and individual capacities; RANDY LIGHTSEY, in tis official and individual eapecities; MICHAEL ADAMS, is official and. individual eapacitios; JACK PRIDDY, in his official and individual enpncites; KERRY QUINN, in bis official and individual capacities; CIVIL ACTION ave wo, 2017-C¥-067039 JURY TRIAL DEMANDEDCHRIST! GRIFFIN, in her official and ) individual capacities BRYCE WHITENER, in his officiel and d individual capacities; CHRISTOPHER BURKS, in his official and } individual eapavities, ROY BLACK in his official and individual ) capacities; HOWARD FISHRR, it his official individeal } capacities DETECTIVE MARK MASKULE, in his ) official and individual capacities: ROY FART, in his official and individual 3 capacitios; JOHN MARION, in his official and individual ) capacities, WES HORNE, in his official and individual ) capacities; SCOTT FORTHE, in his official ) and individual capacities; JAY FLOYD, in his official ) and individual capacitics; STEVE CALLAHAN, ia his ) ‘ficial and individual eapacitiens AMY BRASWELL, CFV, ACTION in her official and individuel caoacities; SYEVE TURNER, in his official ) 2017-CV-067039 and individual capacities, PILE NO. DR. MARY ANNE GAPENEY-KRATT, ) inher official end individual capacities; JURY TRIAL DEMANDID RODNEY BRYAN, in his cfBcial und ) individual eapacities; STEVE OWENS dita OWENS TRANSPORT ) SERVICE; LARRY HANSON, in his official and individual capacities: ) CITY OF VALDOSTA, GEORGIA, ‘Munieipat Conporation: ) JOHN DOE 1, JON DOR 2, JOLIN DOE 3, JANE ROR 1, JANE ROR 2 und JANE ROB 3, ) ‘unknown persons, Defendants. COMPLAINT FOR DAMAGESARISING FROM A VIOLATIONS OF RACKETEER INFLUENCED AND CORRUPT ORGANIZATIONS ACT AND OTHER TORTIOUS CONDUCE ‘NOW COME Plaintiffs KENNETH JOHNSON ead JACQUELYN JORNSON and JACQUBLYM JOHNSON, in her capacity as temporary acutinististor of tac Estate of Kendrick Page 2 of 41JLama: Jobnson, who now file this cause of action agains! the above named defendants pursvant 10 the Georgia Rackeroer Influenced and Corrupt Orgmizations Act, O.C.G-A, §16-L441, ef seg. (or “RICO™) for and while often acting together and in concert, engaging in unlavrful aad unconscionable conduct of causing the death af Kendrick Lamar Johns. In addition to, and ofen in furtherance of their RICO conspiracy, some defendants cnuaged in other actionable ceadver, including, but not litaied to, false swearing, obstruction of justice, intentional misrepresentation, influencing witnesses, tampering with evidence, tampering with witnesses, malicfons proseentions, and other tortions connet, all of which was designed and conducted in the interests of “covering up” (a) the true canse of Kendrick Lamar Johnson's death, and (b) she identity of the persons iho are respotsible and wers involved in onusing his death, Alleourt costs assceisted with any previously fled ation roasserted herein have beom paid in fall Jollowing the subtuission of a good faith inquiry to the Clerk's office by the undersigned, accompanied by the receipt of written confirmation, PRELIMINARY STATEMENT Plaintiffs KENNETH JOHNSON and JACQUELYN JOHNSON are the parents of KENDRICK LAMAR JOEINSON, who died while attending school on er about Jamvary L0, 2013 a: Lowndes High School focared in Veldosta, Lowndes County, Georsi, bring this action against Defendants BRANDON BELL, BRIAN BELL, end RYAN HALL, cath of whom were assisted each other, as well as, by certain wxknows individuals, Hoceinafter referred t9 a3 JOHIN DOK 1, JOHN DOB, 2, JOHN DOE 3, JANE ROB 1, JANE ROE 2 aad JANE ROM 3, for various actions or conduel witich led to or directly caused the death of KENDRICK LAMAR JOLNSON, Inch of the aforesnamed defendants are liable to Plaintiffs for the wrongful death of KENDRICK LAMAR JOLNSON, as well es the cover-up and obstruction of Justice which followed, Therenfer, the aforegnid defendants, along with cach of tae defendants named in the above styled caption, deliberately sad unlawfully conspited to hide and coves up: (a) the perpetration of an assault and ofner ciscumsiances upun KENDRICK LAMAR JOJINSGN on or about Fanwary 10, 2013. (9) their involvement as assailants or parsons who assisted in causing stid assault ar the Ceath of KENDRICK LAMAR JOHNSON, ( ¢) the identities of persons who diteclly or indirectly contributed to or assisted int Page 3 of Acausing the assault and ultimately the death of KENDRICK LAMAR JOHNSON, ané (@) the involvement of each other as participants in 2 conspizecy to unlawfully interfere with an investigation by law enfarceraent agencies that purportedly was designed to discover the true cirermistances surrounding ‘he desth of KENDRICK LAMAR JOHNSON. To addition, not only did cach of the defendants identified in the above styted action, oaalictously, conspire and engage in a deliberate and catmpt sffort to cover up ths involvement of Defendants as assailanis aad co-conspirators, bul the aforesaid conspimy also deliberately, maliciously and untswfially interfered with the rights of Plaintiffs KENNETH JOHNSON and JACQUELYN JOHNSON to have access fo the courts of ths state and thereby fustnte their desire to seck teal redress. Accordingly, each ofthe defendants nemed herein are liable lo said piainfiffs for the damages they have suffered due to & civil conspiracy eetried out by them and which sought to interfere with theie due process and oqual protection rights under the Constitution for the State of Georgia and the Constitulien of the United Stales of Ametica, Accordingly, Plaintiffs KENNETH JOHNSON and JACQUELYN JOHNSON seek equitable relief inthe form of declaratory judgment and injunctive relief ggninst afl state actors, including but not limited to Defendants CHRIS PRINE, STRYDE JONBS, RICHARD “RICK” AULL, WILLIAM “WES” TAYLOR, SCOTT FORTIS, MARYANNE GAFFNEY-KRAFT, RODNEY BRYAN, STEVE OWENS, os well as all other defndants named herein, and who are sued in their individval oapacity, as swell as, official enpacity as members of the Geongia Buresu of investigation (°G.B.L,"}, Lowndes County Shorit?’s Department, City of Veldosta and tts Police Department, and Lowndes County School Distiet, In the course of interfering with the rights of Plaintiffs KENNETH JONSON ancl JACQUELYN JOHNSON fo hava access to the courts and thus frustrate thedr desire te seck legal redress, cach of the dedvadants have caused said plaiutifis to suffer arcat physical and etactional paia and, as 2 consequence, are lisble for intentional infliction of emotional distress, as well as, other state law ‘violations, JURISDICTION AND VENUF, 1. Plaintiffs KENNETE JOHNSON, JACQUELYN JOHNSON and JACQUELYN JOTINSON in her capacity as specified in the above styled exption, bring this action prasuent to the Georgia Rackelect Page 4 of 41Influenced and Corrupt Organizations Act, O.C.G.A. §16-l4-1, ef seq. Accordingly, this Court has jurisdiction over the subject mater of this Comalaint, 2. Vem is properly invoked inofar as one cr mere of the defeadants are residents of Bibb ‘County, Georgia, As such, the foregoing cixcumstances provide a statutory basis for asserting that venue lies in this Court, RIES, 3, Plaintiffs KENNETH JOHNSON and JACQUELYN JOHNSON appear herein as individuals who are entitled (o bring this action for fae wrongful death because they are the patents of Kendriok Lamar Johnson, wio was a minor atthe time of his death and who left no surviving In addition, Plaintiffs KENNETH JOHNSON and JACQUELYN JOHNSON, appear herein as ‘he personal representatives of their minor son, KENDRICK LAMAR JOHNSON, with Plait JACQUELYN JOTINSON, serving as temporary Administrator for and on behalf of the Estate of KENDRICK LAMAR JOFINSON, As 2 resul, Plaintifis also bring this ection against the Defendants in ‘heir cepresentative capacity and sue the Defendants LOWNDES COUNTY SCHOOL. DISTRICT, WES TAYLOR, and JAY FLOYD pursuant to 0.C.G.A. §51-4-S to reaver flineral expenses, as well a5, compensation for the pain and suffering experienced by KENDRICK LAMAR JOHNSON fiom his Injuries, all of which was auxampanied by bis dsath on or about Jenuury 10, 2013, 4, Atall mes material to this Complaint, Defendant RICK BELL is at Agent ofthe Nederal Bureau of Investigation (“FBI”) and who is being sved ia his individual capacity. Detandant RICK BEL. may be served with servive of process at fis residence ia Lowndes County, Georgia oF at the office of the PBL, lovated at 6061 Gata Pewy N, Jacksonvills, Florida 32256. 5, Atall times matcrial to this Complaint, Defendant BRANDON BELL was the oldest son of Defendant RICK BELL, an Agent with the FBI and who is being sued in bis individuol eapacity and us a child of Detindant RICK BULT.. Refendant BRANDON BELL may be served with service of process at his residence on the campus of Valdosta State University, located in Vaidosta, Lowndes Counly, Georgia, Page 5 of 46. Atall times material to this Complaint, Defendant BRIAN BELL was the youngest son of ‘Detbadant RICHARD “RICK" BELL, wn Agent with the Federal Bureau of Investigation (T-BL.") and ‘who is being sued in his individual capacity and as a child of Defendant RICK BELL, Defendant BRIAN BELL may bo served with serviee of process af the residence of his parents, Defendant RICK BELL nnd ‘Karon Ball, which is Tocetod in the city of Points Verde Beach, St, Johns County, Plotida, 7. ACalltimas material to this Complaint, Delondant RYAN HALL ray be served with secviee of ‘process at 827 lone Church Road, Pavo, Georgia. 8, Atal times material to this Complaint, Defeadant WILLIAM WESLEY “WES” TAYLOR, ‘was the Supezintondent of the LOWNDES COUNIY SCHOOL DISTRICT, At all times materiel to this ‘Complaint, Defendant LOWNDES COUNTY SCHOOL DISIRICY is a goverumental crtity charged ‘with the responsibility of providing education lo residents, incloding Kendriex Lamar Johnson. Servies of ‘process may also be accomplished by serving Defendants WILLLAM WESLEY “WES” TAYLOR, who 4s being sued in his individual and officiel eqpaeity, and the LOWNDES COUNTY SCHOOT. DISTRICT, at 1592 Norman Drive, Valdoste, Georgie 9. Atall times materia to this Comptaint, Defendant CHRIS PRINE wes the Sheriff of Lowndes ‘County, Georgia and who is being sucd in his individval and official cagacities. Defeadant CARS PRINE mey be served with servize of process at 120 Prison Farm Road, Valdosta, Georgia, 10. Atall times material bo this Complaint, Defindant CITY OF VALDOSTA is a arnicipal comporation located in Lowndes County, Georgia. This Defendant may be servad with service of process by serving it upon its vity manager, Lary H, Hanson, at 216 E, Contral Avorus, Valdosta, Georgia, 11, Atall times material to this Complaint, Defendant LARRY H. HANSON was the eity ‘macagcr forthe city of Valdosta, Georgia, This Defeucant is being sncd in his individual and official capacity, He muy be served! service of process by serving it upon him al 216 B. Central Avenuc, Valdosta, Georgia 12, Atall simos material to this Complaint, Defendant FRANK STMMONS wats bie Chief of Police of the Valdosta Police Department and who is being sued in his individual, as well as, in his official Page 6 of 41capacily. Defendant PRANK SIMMONS may be served with service of process at $00 North Toombs Stret, Valdosta, Georgia 13. AC all Giaes muri to this Complaint, Datendant STRYDE JONES was a Lieulonaat ofthe T.owmdes County Sheriff Office end who is being sued in his individual, ax well a, in his official capacity. Defendant STRYDE JONES may be served with service of process at 120 Prisov-Fanm Road, Valdosta, Georgia. 14, Atal ies material te this Complint, Defendant STEVE OWENS was the owner of Steve ‘Owens Transport Service and who is being sued. Defondant STEVE OWENS may be served with service of proooss at 4659 Wheeler Rou, Quitman, Goorgia 15, Atal times material to this Cosplaim, Defendant JAMES D. THORNTON was a Criminalit of the Valdosta-Lowndes Regions Crime Laboratory and wh is being sued ia his individual, es well a in his official capacity. Defendant JAMES D, THORNTON nay be served with service of process ut 1708 Nonth Asiey Steet, Valdosta, Georgi 16, Atall Ges material to this Complaint, Defendant WTS HORNE was a Crime Soene Specialist of the Geimgia Burcaa of investigation and who is hoing sued in his individu, as well as, in his oficial capacity, Defeadnaz WES HORNE may be secved with service of process atthe keadquavters ofthe GBI, locate! at 3121 Pauthersvlle Road, Decatur, Georgi. 17. Atall times material to this Comuplaat, Defendant JACK WINNINGHAM oins a Staff Sergsantinvestigator ofthe Lowndes County Sher Offog and who is being sued in his individual, as well as, in his official capacity. Defendant JACK. WINNINGHAM may be setved with servioe of process at 120 Prison-Farm Rosé, Valdosta, Goorgia 18, Atal! Limes material to this Complaint, Defendant DR. MARYANNE GABENEY-KRAPE ‘ens the Medical Txaminer af the Georgin Rorean of investigation and who ix being sued in her individual, 5 well as, in bis official capacity, Defendant MARY ANNE GAFENEY-KRAF'T ay be served with service of'process at her residence in Macon, Bila County, Georgia, as well as, the headquarters ef the ‘GBI, located at 3121 Panthersville Read, Decatur, Georgia. Page 7 of 4119, Atall times material to this Complaint, Defeadaat STEVE TURNER was the Special Ageat in Charge of the Region 9 Office of the Geongin Bureau of lavestigation and wh fs being sued in his individu, as well as, in Bis officiel capacity. Defendant STEVE TURNER may he verved with service of proses at the heaéquarters of the GBI, located at 3121 Panthersville Rand, Decatur, Georgia. 20. Avall times material to this Complaint, Defendant SCOTT FORTH? was media specie ist with the LOWNDFS COUNTY SCHOOL DISTRICT and who is being sued in his individu, as well es, in is official eapncity. Defendant SCOTT FORTHE may be served with sarvioa of process at the administrative offices for the Defendant LOWNDES COUNTY SCHOOL DISTRICT, located in Valdosta, Lowndes Coumty, Georgia ‘2A, Atall times material to this Complaint, Defendant LINDSAY MERCHANT yas an Agent of ‘he Georgia Bureau of Investigation and who is being sued in his individual, as well as, in his official capacity, Defendint LINDSAY MIRCHANT may be served with service of process at the heaulquanters of the GBI, located af 3121 Panshersville Roud, Decalur, Georgia, 22, At all times material o this Complsint, Defendant JAY FLOYD was the prineipal of Lowndes igh School and wo is being sued in his individual, as wel as, in his officiat capacity, Defendant JAY FLOYD znay be served with service of process at his residence in Valdosta, Lowndes Coumty, Georgia, 28 well as, 23, Atall times material lo this Complainl, Defendant AMY BRASWELL was an Agent of the Georgia Bureau af lavest’gation and who is being sued in his individual, as well as, i her official capacity. Defendant AMY BRASWELL nay be served with service of process at thie headquarters of the GBI, located at 3121 Panthersvitle Road, Decatur, Georgia. 24, Atell times material to this Complaint, Defondoat AARON PRITCHIBTT was a Sergeant of fhe Lowndes County Sherif? Offies and who is being sued in his individual, as well as, in his official capacily. Defendant AARON PRITCHETT may be se-vesl with service of process at 120 Prison-Faran Read, Valdoste, Georgia. 25. ACall times matesial to this Complaint, Defbudant SHANNON SALTERS was a Criminalist of the Valdesta-Lowndes Regional Crime Laboratory and whe is being sued in his individual, as well as, in Page 8 of 4this officiel capacity, Defendeat SHANNON SALTERS ay be served with service of proves at 1708 North Ashley Street, Valdosta, Georgia. 26. Atall times mater‘al to this Complaint, Defendam RAY MCGRAW wus a Crime Scene Specials. with the’ Valdosia-Lowndes Regional Crime Laboratory and who is being sued in his individual, aa well a5, in his official eapacity. Dofendant RAY MCGRAW may be served with service of process at 1708 North Ashley Strect, Valdosta, Georgia, 27. Atall times matorial to this Complaint, Defendant WANDA EDWARDS was ¢ Captain of the Lowndes County Sheriff Office nd who is being sued in his individual, as well as, #n her afficin! eapacity. Defendant WANDA EDWARDS may be served with serviec of process at 120 Prison-Farm Road, Veldesta, Georgia. 28, Atall times material to this Complsint, Defendant LOGAN TITINDERSON was a Major ofthe Lowndes County Sheriff Office and who is being sued in his individcal, as well ws, in his offigial capacity. Defendant LOGAN HENDERSON may be served with service of process at 120 Prison-Farm Rowd, ‘Valdosta, Georgia. : 29, Al oll (ites matetial lo this Complaint, Defendant RANDY LIGHYSHY was a Deputy of the Lowntes County Sheriff Office and who is being sned in his individual, as well as, in his official eaprcity. Detendant RANDY LIGHTSIY may be served with service of process af 120 Prison-Farm Read, ‘Valdosta, Georgie. 30, AL all fies material io this Complaint, Deendunt MICHABL ADAMS was a Deputy of the ‘Lowndes County Sheriff Office and wh ‘being sned in his individual, 2s well as, in his official capacity. Defendant MICHAEI. ADAMS may be served with service of process at 120 Prison-I'am Road, Valdosta, Georgia. 31. Atal times material to this Complaint, Defendant JOHN MARION was 1 Deputy of the Lowndes County Shesitf Oftice and who is being sued in his individvel, as well as, i bis offical eapacity. Page 9 of 41‘Defendant JOHN MARTON may be served with service of process at 120 Prison-Farm Road, Valdosis, Georgi, 32. AC all times material to this Complaint, Defendant JACK PRIDDY wats a Deputy’ of the ‘Lowndes County Sheriff Office and who is being sued in his individual, ax welll as, in his official capacity. Defendant JACK PRIDDY inay be served with service of process at 120 Privon-Farin Road, Valdosta, Georgia 33, At all fimes material te this Complaint, Defendant KERRY QUINN was @. Deputy of the ‘Lowndes County Sherif? Office and /ho is being sucd in his individual, as well as, in his official capacity, Defendant KERRY QUINN inay be served with servies of process af 120 Prison-Farm Road, Valdosta, Georgia, 34, Atall times material to this Complaint, Defendant CHRISTI GRIFFIN was a Deputy of the Lowndes Counly Shetil¥ Office and who is being sued in her individusl, ay welll as, in his eflicial capacity, ‘Defendant CURISTI GRIFFIN may be served with service of process at 120 Prison-Parm Rowd, Valdosta, Georgia 35, At alt times meterial to this Complaint, Defendant BRYCE WHITENER was a Deputy of the Lowndes County Sheriéf Office and whi dividual, as well as, in his officiat capacity. being sued in his Defendant BRYCE WHETENER may be scrved with service of process at 120 Prison-Farm Road, ‘Valinsta, Georgia 36, Atall times material to this Complaint, Defendant CHRISTOPHER BURKE, was a Deputy of the Lowades County Sheriff Office and who is being sued in his individual, as well as, in his official capacity, Defoadat CHRISTOPHER BURKE may be served with service of process a! 120 Prison-Pani Road, Vaklosia, Geergia, 237, At all times material to this Complaint, Defendant TROY BLACK was a Detective of the Lowndes County Sheriff Office and who is being suad in his individu as well us, in his official capacity. Page 10 af 41Defendant YROY BLACK may be served with servive of process at (20 Prison-Rarn Road, Valdosta, Georgia, 38. Atall 05 material to this Complaint, Defondast HOWARD FISHER was a Detootive of the ‘Lowndes County Sherit¥ Office ang who is being sued in his individual, as well as, in his official capacity Defendant HOWARD FISHER may be served with service of process at 120 Prison-Harm Road, Valdosta, Georgia, 39, Atall times material to this Complaint, Defeadant MARK MASRULE vias a Detective ofthe Lovndos County Sherif Office and who is being sued in fis individual, as well as, in his official capacity. Defendant MARK MASSULK inay be served with service of process at 120 Prison-Fama Road, Valdosta, Georgia. 40, Atal times matecial to this Complaint, Defendant ROY HART wes a Detective ofthe Lowndes Coumy Sheritf Oftice and who is heing sued in his individual, as well as, i his offical capacity, Defendant ROY UART may be served with service of process at 120 Prisen-Fesm Rowd, Valdosta, Georgi 41. ALalt tines material o this Complaint, Defendant RODNEY BRYAN was a death investigator with the Georgia Bureau of Investigation and who is being sited in his individat, as swell as, in his official copacity. Defendant RODNEY BRYAN may be served with servioe of process at his residence in Macon , Rikb County, Georgia, ax well as, the headquarters of the GBL., located at 3121 Panthersvilie Road, Decatur, Georgia, FACTS COMMON TO ALL CLAIMS Page Hof AL42, On Jactuary 10, 2013, KENDRICK LAMAR JOHNSON (hereinafier sometimes referted le ? decedent” or “plaintiffs? son or “plaintiffs? child, an Aftican-American student, was attending Lopmdes High School in Valdosta, Lowndes County, Georgia. 43, Atsome point dusing the eftemeoa of January 10, 2013, plaintifi’s decedent failed to attend the balanes of his scheduled classes, 44, Upon information and belief, plaintif's decedent entered am arca upon the Lowndes High School eampus where, afior being induced by a fellow famale snident, Defandant JANE, DONA, fo go to said location, he was encountered hy cefendant BRANDON BPLT. and deiindant BRIAN BELL, both of whom were fellow male stuclents at sai high school, 45, Upon informarion and belief, when pleintitf's decedent atrived ot the aforementioned ovation, he was violently assauied by persons, including butt limited to defendants BRANDON BELL, BRIAN BELL, and RYAN HALL, in the courte thereof, suffered a fatal injury which led to his death, 46, Upon information and belies, following the aforesaid assauit upon plaints’ decedent, defendants BRANDON BELL, BRIAN BELL, RYAN HALL, JANE DOEI and cottain individuals who are curently unknown fo plaintiffs, but who is identified as JOHN DOE 1, not only failed to render aid to plaintifs’ decedent or notify school enthorities af his condition, but instaad, sought fo hide the body of pleintiff's decedent, 47. Upon information and belief, following the aforesaid assault upon plaintiffs’ decedent, defendints BRANDON RBI, BRIAN BELT, RYAN LIAL, JANE DOEI and JOHN DOB1 netifiod defendant Lowndes County School Superintendent WILLIAM “WES” TAYLOR, detendant RICK BELL, a Federal Bureau of Investigation (“FBI”) Special Agont and father of defendants BRANDON ‘BELL and BRIAN BELL, and defendant CHRIS PRINE, the Shertff of Lowndes County, Georgia, of the circumstances surrounding the assault of plaintifiy’ decedent, as well as, the location of bis body. Page [2 of 4148, Upon information and belicf, Defeadaut RICK BELL, Defendant WILLIAM “WES” “TAYLOR and Sheriff Chiis Prine diseussed amongat themselves the eiccumstaneca surrounding the assault of plaimif’ decedent and entered into an agreement and plan fo Megally cover up the (ras cause of death to plainiifls” decedent, as well as, iP not more importantly, the involvement of defendants BRANDON BELL, BRIAN BELL, RYAN HALL, SANE DOBI and JOHN DUE in causing the fatal injuries suffered by plaintiffs” decedent, 49. Upon information and belie®, the afvressicl agreement by Defendant RICK RELL, Defendactt WILLIAM “WES” TAYLOR and Sheriff Chris Princ to hide and cover up the involvement of defendumts BRANDON BBL, BRIAN BELL, RYAN HALL, JANB DOBI and JOHN DOD, as well as, the true cause of plaintiffs’ decedent's death, amounted to an illegal conspitacy to obstruct justice to interfere with Plaintiffs KENNETH JOHNSON and JACQUELYN JOHNSON’s access to the courts, and lo deny ‘them their sights to de process and equal profection of the lavs as set forth by the Constitution of the State of Georgia. 450, Upon information and belief, Defendant RICK BELL, Defenciant WILLIAM “WES” TAYLOR and Shotiff Chris Prine cngaged in conduct which was designed to carry out said conspiracy. 51. Upon information and balief, the conduct engaged in by Defendant RICK BELL, Defendant WILLIAM “WHS” LAYLOR and Sheriff Cheis Prine cousisted of gaining access to the old gymmnasiors located at Lowndes High School and placing the body of plaintitf’” decedent upside down inside a rolled ‘up sgym mat and placing same in a comer of the afbresstid gymnasium with the idea that the body of plaintiffs’ decedent would be discovered following the begioning of classes on January 11, 2013. 52. Upon information and belief, and in firiherance of said conspiracy, Sheriff Chris Prine solicited and engaged the involvement of subordinates and members af the Lowaues County Shesiff's meal to iL. The purpose ‘Department for purposes of comtrolling the old gym and areas which were pro Page 13 of 44behind controlling these areas was fo ensure the appearance that plaintiffs? decedent had died as a result ofan unfortunate accident 53. Those subordinates and members of the Lowndes County ShetifP's Department who were notified of the plan and conspiracy to disguise the trus cause of Kendrick Johnson's death, as well as, the involvernent of those responsible dor causing, sare, ineJuded, bt is not Himited to Defendants JAMES ‘THORNTON, SHANNON SALTERS, RAY MCGRAW, JACK WINNINGHAM, WANDA EDWARDS, STRYDE JONES, AARON PRITCIINTT, LOGAN [ENDERSON, RANDY LIGHTSEY, MICHAEL ADAMS, JACK PRIDDY, KERRY QUINN, CHRISTI GRIFFIN, BRYCB WIITENER, CHRISTOPHER BURKE, TROY BLACK, HOWARD FISHER, MARK MASKULE, ROY HART, and JOHN MARION. 54, Upon information and belief, said conspiracy also involved the purported discovery of the ody of plaints" decedent by Lori Taylor amd Lisma‘Taylin, both of sham arv the daughters of Defendant WILLIAM “WES” TAYLOR and students at Lowndes High Sehool, 538, On tho noraing of January 11, 2013, Plnintil? JACQUELYN JOHNSON came to said high schoo! to inquire as to the whereabouts of plaints? decedent inasmiuch as he bad failed to rotum hotne fiom said high sehool the evening befor, 56. Upon information end belied: Lori Taylor and Laina Taylor, who were in the old gyi aud ‘near the eforosaid gyin mst containing Kendrick Jounson’s body, slered school officials as to the preseuoe of the body in the said zolled-up gym mat while it was still in the sid zolled-up gan meat, 57. Shortly thereafter, sad while waiting in the administrative offices of said high school, Plaintif? JACQUELYN JOHNSON was advised that the dead body of her son had been located in the old gytn. 58. In the several hours which followed various members of other law enforcement agencies appeared at said high school lor the alleged purpase of investigating the death of plaintif?s decedent, Page 14 of 4159. Of tha various law onforcement ayeneies which arrived at the aforesaid figh sooo! shortly following the discovery of the body of plaintiffs’ deveden|, there were representatives of cach of the law enforcement agencies from withia Lowndes Couaty, Georgia, including, but not limited to, the Lowndes County Sheviff’s Department, the City of Valdosta Police Department, the Valdosta Towndes, Regionat Crime Tshoretory (*VTRCIZ) and the Georgia Bureau of Investigation (°GBM), (60, In addition to the aforesaid law-enforcement agensies, one of the first responders to arrive at the aforesaid high schoot included two (2) emergency medical technicians EMT") who examined the body plaintiffs" decedent while it was still in the aforesaid old gym. 61, Of the vations obscrvations which wore made by said EMTs, they noted that there was @ bruise fo the right sida of the jaw of plaints" decedent. In preparing (heir report regarding their observations of the body of plaintiffe’ decedent, said I'MTs characterized the location of said body 2s a “rime scsme” 62, Notwithstanding the albtesaid observations of said KM1s, who pon information aud belie ‘were the frst and only medical experts to examine the body of plaintiffs’ decedent while it wax fill in the aforesaid old gym, defendant fav enforcement officers JAMES THORNTON, SHANNON SALTERS, RAY MCGRAW, JACK WINNINGHAM, WANDA EDWARDS, STRYDE JONES, AARON PRITCHETT. LOGAN HENDERSON, RANDY LIGHTSEY, MICHAEL ADAMS, JACK PRIDDY, KERRY QUINN, CHRISTI GRIFFIN, BRYCE WHITENER, CHRISTOPHER BURKE, TROY. BLACK, HOWARD FISITER, MARK MASKULE, ROY ART, ard JOHN MARION (hereinafter sometimes referred to as “Defordant Lowndes County Dupativs") furthered the eforosaid conspiracy by {ailing to follow appropriate investigative procedures to ensure against the contamination of the aren surroundiag whete the body of plaimtifl’ decedent was allegedly discovered or located. Page 15 of 4163. Upon information and belief, members of the Georgia Bureau of Investigation, ineluding but. ‘not Limited to Defendants STEVE TURNER, RODNEY BRYAN, AMY BRASWELL, MIKT. CALLAHAN, LINDSAY MARCHANI, aud WES HORNE (hereiualicr sometimes referted to as “Defendant GEL Agents") became aware of the afurosaid conspitaey and also joined the aforesaid conspiracy by failing to follow appropriate investigative procedures to cnsute ageinst the ecaramination ofthe area surrounding where the body of plaintiffs” decedent was allegedly discovered or located. 64, Upon information and belief, City of Valdosta Police Chief Defendant FRANK SIMMONS also became aware of the aibresaid eanspiracy and joined the aforesaid conspiracy by fuling to follow appropriate investigative procedures to ensure against the contamination othe area sarrounding where ‘the body of plaintifts” decedent was ellcgedly discavered or lovated. 65, After Plaintiff 1ACQUELYN JOHNSON was aotified thet the body that had been Teented in the gymnasium was believed to be her son, she along with offer farnily members who artived at the alineseid high school, requested but were refused permission by afore-named Defendamt GBI Agents, the afore-named Defendant J. owndes County Deputies, Defendant Frank Simmons, and Sheriff Chris Pring to identify the body of her son; ail that isa pact of and in furtherance of the aforesaid conspiracy. 66, Notwithstanding the discovery of ¢ dead body and the presence of defendant law-enforcement, officials, said defeudants knowingly and with malicious intent failed to uotify the Lowndes County Coroner for approxiziately six (8) hours folowing the alleged discovery of the body of plaintifis” decedent. 67, The aforesaid fhilure of the defendant law-enforcement officials to immediately natily the ‘Lowndes County Corener was in deliberate violation of the laws af the state of Georgia, more specifically identified as 0.C.G.A § 45-16-24, which states, in relevent part, that “it shall be the duly of any Law enfoseement officer or other person having knowledge of such death to notify immediately the comer or county medica? examiner of the county in which the aots or events resulting in the death occurred or the Page 16 of 41Dbody is found.” The alore-named Defendant CBI Agents, the afore-named Defendant Lovmdes County Deputios, Deftadant FRANK SIMMONS, and defendant CHIRIS PRINE deliberately failed to notify the County Coroner for Lowndes County in furtherance of the afiresaid conspiracy. 68, Norwithstanding the discovery of'a dead body, the aforesaid observations of said EMTs, as well 2, tho loeation of blood of sn unidentified source that was observed upon the surfaces of walls thet ‘wete proximal to the location of the body of plaintiffs’ decedent, defendant CHRIS PRINE, expressed to the news media on Jamuary 11, 2013 that zhere was no ovidenes of “foul play” and that the cause of death ‘was accidental based upon 2 theory thal plaintiff's decedent died as « result of him attempting to retrieve a ‘tennis shoe by entering into the center opening of the aforesaid rolled-up gym mat and thereafter becoming stuck ad without the ability 19 ee himself, The afove-named Defendant GBT Agents, the afore-named Defendaat Lowades County Deputies, and Defendant FRANK SIMMONS, were aware of ‘the announcements made ky defendant CHRIS PRINE and the falsity of samo, and in fartherance of the conspiracy, deliberately failed to correct the reposts mace by defendant CHRIS PRINE or to notify the appropriate governmental entries or other law caforcement personnel of the folsity of the atbresaid reports made by defendant CHRIS PRINE,, a5 well as, the conspirazy itself, 69. On or about Jenuary 12, 2013, Plaimiff KENNETH JOHNSON requested permission 1 view the body of plaintiffs’ decedent, but in furtherance of the aforossidl conspiracy, was also refused permission by afore-named Defendant GBI Agents, the affre-named Defendant Lowndes Coumy ‘Deputies, Defendant Frank Simmons, aad deftndaut CHRIS PRINE. 70. Following the aforementioned denial of permission by defendants to allow plaintiffs TACQUELYN JOHNSON and KENNETH JOHNSON to view and identify the body of their deceased son, plaintiffs contacted the news medie and eondueted « pross conference to voice their eoncerms regarding the kind of treatment that they were recciving ftom said doftadant stembers of the law enforverent community, more particularly defendant CHRIS PRINE , Delendant $ LRYDE JONES with Page 17 of 41the Lowndes County Sherill"s Deparment, and Defendant JAMT:S THORNTON of the Veldosta- ‘Lowndes, Regional Crime Laboratory. 71. Upon information and beliaf, defendant CITRIS PRINE, Defend STRYDE JONES th afote-named Defendant GBI Agents, the alore-naed Defendant Lowndes County Deputies, aad Defendant FRANK SIMMONS, reconsidered Gieit position reginding Une Plaintif(s” request ta view the body of their son and, as a consequence, granted them petsnission to come to the Valdosta-Lowndes, Regional Crime Laboratory for purposes of viewing the body. 72, On January 13, 2013, plaints IACQUTLYN JOHNSON and KENNETH JOHNSON went fo the Valdosta-Lowndes, Regional Crime Laboratory where they were met by Sheriff Chris Prine, Defindant STRYDE JONES und Defendant JAMTS TITORNTON for purposes ol'viewing the bady of pisinfiffi” docodent. On that occasion, plaintiff KENNETH JOHNSON cmtcred the room whete the body ‘of plaints decedent was heing stored and. where he noted that the room {emperature appeared to be ‘much warmer than what be had anticipated inasmuch as he thought that said roor and the vault that the docedent’s body was being stored in was dosigued to presoeve the remains through a process similar akin to vehigeration, Upon information aad balief, each afbrensutioned defendant, inehuding but not limited to ‘Sheriff Chris Prine, Defenéant STRYDE JONES aad Defendant JAMES THORNTON, wes aware of the cffortto advance the decomposition of Kendrick Johason's remains as a part ofthe aferosntd conspiracy. and ye! failed to take any action to prevent the destruction or eliination of the evidonee that would otherwise be preserved through appropriate handing of said semains, 73. Ab that tine, Sheriff Chri ing explained (i Plaintiffs JACQUELYN JOHNSON and KENNETH JOHNSON that plaintitt’s decedout hnd otered the center bole of the aforementioned gyn ‘mat “(vet first” and thal while al the bottom of the hele, plaintifis” devedent bent over to cettieve bis tanmis shoe and became stuck in such a way that he could not five or remove himself from the hole Page If of 4174, Upon hearing the foregoing explanation, Plaintiff KENNETH JOHNSON steted to Sherif (Chris Prine that bis explanation was not possible, whereupon Defendant STRYDE JONES stated te Pisin KENNETH JOHNSON that he (CENNETHL JORNSON) dé nét uoderstand tec “hen yon die, ‘your muscles relax and then you fal! forward,” The aforesaid explenation offered by Shecif Chris Prine and Delimdant STRYDE JONES was commemicated te plaintiffs in trtherance of the aforesaid conspiracy. 75, Approximately vo (2) ot more days later, au ex-cimployee of the Lowndes County SherifPs Departnent contested plaintiff KENNETH JORINSON and stated to him that he (KENNETH JOHNSON) misunderstood what Sheriff Chris Prine and defendant STRYDE JONES liad attempted to explain to plaintiffs ane that their explanation was meant to explain that plaintifs decedent had entered the center hole of the gyn mat head first instead of feet first, 76, Due te the atbresaid findings of “no foul play” and a theory offered hy Sherill Chris Prine, Plaintiffs KENNETH JOHNSON and JACQUELYN JOTINSON were desirous of having 2 father investigation into the cause and citeumstances of their son’s death. 77. Concueront therewith, Plainliffs eomsofed Herringion's Funeral Home ead Antonio Harrington for purposes of properly handiing the remains of plainlil’s decedent, 25 well as, making the arrangements for the fimeral services and internment of his remains. 78, On of about January 14, 2023, lke retains of Plainlis* minor chile wore transported by Defendant STEPHEN WESLEY OWENS of Deferdant OWEN’S TRANSPORT SERVICE fiom the ‘Valdosta-Lawndes, Regional Crime Laboratory to the GBI's Crime Lab lovated in Macon, Georgie for pumposes of undergoing an official antopsy, Upon completion of said amopsy, Defendant STPPIEN WESLBY OWENS transported the remains of pluintif’s decedant back t» Valdosta during the early afictnoon hours of Fanuary 14, 2013, delivered said remains of Plaintiff’ decedent to Harrington's Page 19 of 41Funeral Tome, all of which was pursuant fo an understandine. and oral agreement entered into hetween Plaintiffs and Defendants, 79. Antonio Harrington oxpressed to Plaintiffs KENNETH JOHNSON and JACQUELYN: JOHNSON his concems as to the aforesaid explanation for thie child’s death and recommended thar they should get a “sceond opinion” as ta the esuse of death notwithstanding the tho-unknown-findings of official autopsy, Plaintiffs concurred with Aatonio Harrington's recommeadation. 80, On of about January 16, 2013, au occasion on whieh Plaiutitts KENNETH JOHNSON and JACQUELYN JOHNSON visited The Harrington's Fanetal Home, said plaintiffs inquired of Antonio Maringion whether they coud eotllect the clothing that plainti’s decedent wars wearing at to time that is body was discovered Lowndes High School. Responsive fo said request, Antonie Tlarringlon advised Plaintitls that he was unaware thet their child had aty clothes when his remains were retarned from the sforssaid GBI Crime Lab. 81, fn addition to the aforesaid inquiry about their minor child’s clothing, Plaintitfs never authorized Antonie Harrington nor his stait to destroy or dispose of any of the plaintiffs’ decedent's body parts, including but wot litniled Lo his intemal organs, 82. In the course of atlempting to ascertain the whereabouts of plaintiffs’ decedent's clothing, Plaintiffs contasied the GBI Crime Lab in Macon, Georgiz based upon Antonio Hlztrington's representations to them that the subject clothing was not remmed wich whe remains of plaintiffs? decedent 83, Upon making eontact with employees at fhe aforesaid! GBT Crime Fab, Plains JACQUELYN JOHNSON and KENNETH JOHNSON wore advised thet all personal effeets, including but not linied to plaiutif's deeedeat’s clothing, was placed in a body bag and rettmed to Valénsta, Georgia with the aforesaid zemains, 84, In addition to making contact with the aforesaid GBI Crime Leb five purposes of locating the said clothing which was wom by theit son, plaintiffs JACQUBLYN JOHNSON and KENNETH Page 20 of 41JOHNSON inquired 48 to the length of time that ir would fake the Gist Crime Lab to complete the autopsy report, Upen information and belief, the aforesaid clothing disappeared while in the possession of Defeadant STEPHEN WESLEY OWENS and as such, said defendant disposed of said clothing as a part of the aforesaid conspiracy to hice or cover up the true ciroumstences surrmunding Kendrick Johnson's death. 85, Afier several months of repeatedly calling the G.B.(, Crime Tah to establish the slalus of the entopsy report, on or ahout Muy 2, 2013 the autopsy report which had heen authored and propared ‘Defendsat MARYANNE GAPFNEY-KRAFT wes released to the Defendant Lowndes County Sheriff's Department and ultimately, to Plaintiff: JACQUELYN JOUNSON and KENNEL JOHNSON. This autopsy report concluded thus the cause of death of Plaintif’s* dovedemt was positional espliyxia and the manner of death was concluded to be aevidental, 86, Upon information and belief, the eutopsy report which had been authored and prepared Defenstant MARYANNE GAFENEY-KRAFT and who was aided by Defendant RODNEY BRYAN, was false and misleading, and, as such, a pict of fhe aforeseid conspitacy to hide or cover up the (rus civeunstenees sumrounding Kendrick Johnson's éecth, 87. Inastnuch 25 Plaintiiis JACQUELYN JOHNSON and KENNETH JOHNSON were in recoipt of conflicting evidence amd reports, as well as, heing heleazuered by many unanswered questions, Plaintiffs made arrangements to have the remains of their son’s remains exlunied for gusposcs of ‘conducting a seconed and independent auiapsy. 88. Yet, in spite of the absence of any ordinance, regulation, or state Taw requiring Ua the neat of in obtain a court order before they would be allowed to reoiove the remains of theit loved ome, in this fnslamce, tho city manager the Deféndanis LARRY HANSON and the CITY OF VALDOSTA required ‘that the Plaialiflk JACQUELYN JOHNSON and KENNETH JOHNSON petition the Sugsriot Court of Lowndes County for 2 court order before allowing them to exbume the remains of the plaintiffs? Page 21 of 41decedent. Upon informatfon aod belie, the afesnd actions on the part of Defenéants LARRY HANSTN and the CITY OF VALDOSTA were a part of the aforesaid conspiracy to interfere with Plaintiffs access to the courts for purposes of secking fe truth of what occurred to ther son and, legal zedress for aay and all damages which they may have suffered. 89. Oa or about Jums 14, 2013, PlaimuifS’ minor child was disintered, and thereafter, the remains ‘of plaintif's decedent were transported fo Orlando, Florida on June 15, 2013 for purposes of uadergoing ‘xecand and independent autopsy by Dr, William R. Andetson, a licensed forensic patholagst in Orlanéo, Floride. 90, On or about Jue 15, 2013, as Dr. Anderson began to cxamtine the inside of said minor child's abdomen, he devised that all of the internal organs were missing and that snid decedent's bedy was sauffed with waded newspaper. 91. In addition, De. Andersoa observed that the bain of Plaistif®s’ decedent was also missing, Upoa information and belict, ke autopsy by Dr. Anderson was made mote complicated and tims deprived hhim of the ability to conduct the type of autopsy thal vas otherwise contemplated and snore faforinative in seatare, 92, Notwithstanding the foregoing circumstances, Dr. Anderson established that PlaintiflS* decedent had seifered an injury to the right side of his upper ncek, and that the cause of death was blunt force trauma, au injury that was consistent with oa thal hax! been “inflicted” upon plaintifis” decedent end “uoa-aceldental” in neture, 93. fnastnnch as the right side of plaiifls* decedent’s ugper neck had not bccn sectioned by Defendant MARYANNE. GAPENTTY-XRAPT, the forensic pathologist who porformned tha official aulopy for the GBI, Dr. Anderson reached oul io said delendimnt oF her office to establish whether or not she wanted to examine his findings, inclnding the tissue samples which were tulcen from plaintiff decedent daring his autopsy «vf Sune 15, 2013. Page 22 of 4194, Upon information and belief, Defendant MARY ANNE GALENEY-KRAFT nor anyone from hor agency aver accepted Dr. Anderson's aforesaid inviiution fo examine his tissue spectitiens and thus ‘establish whelhet or not said defendant had missed a critical pisvs of evidence in teaching het opinion as to whthor the cauae of death was altogether aceidental or possessed Reatures indicating oa assmelt or Bhant once tranma, ba fet, Dr. Andecson’s invitation was roundly zojected, 98. Upon informstion and belief, the refusal of Defendant MARYANNE GAFFNEY -KRAFT to ‘examine the aforesaid tissue specimens was a pact of aud in furtherance of the aforceaid eenspizncy of which Defendant MARVANNE GABENEY-KRAHY aad bocume a participant. Moreover, a a forensic pathologist with the Cleongia Bureau of Investigation, Defendant MARY ANNE GAPFNEY-KRAFT tad a duty to cxaunine the tissue specimens which Dr, Andsvsen collected cuting his autopsy os well as, his ndings and conelosions as a fallow forensic psthologisc. 96, Kollowing the discovery of theis son's missing organs, plaintiffs sougkt to inquire of Antonio Hevrington whether he was aware of what had happened to the organs of plainlif’s decedent. Of the several zesponses which Antonio Haeringron offered, ue advised that the Coremer for Lowndes County, Georgia, had informed hira thet Defbndant RODNEY BRYAN, a dosti investigator with the GBI, tole hin via telephone that the viscera or intemal organs were disposed of during the GBI’s official autopsy duo to decomposition. 97. Priot fo the completion of the aforesaid official autopsy by the Defendants MARYANNE, GAPYNEY-KRAPT and the GBI, a1 Open Records Act CORA) request, pursuant to OCGA §50-18-70 cet seq., Was initially placed upon the Lowndes County Sheriffs Department on behalf of plaints JACQUELYN JOFINSON and KENNETH JOFINSON on Jamuaty 28. 2013, 98, Notwithstanding that Sheriff CHRIS PAINE had senounced that the Sheriff’s Department had ‘completed its investigation on or about May 4, 2013 and as a consequence thereof, was no longar exerapt from complying with the plaintifls’ ORA request, it was not until Ooteber 3D, 2013 and November 6, Page 23 of 412013 that Sheri? CHRIS PRINE ultimately released the Sheriff's Departments full investigative fle, including copies of surveillance images recorded at Lowades high school en January 10, 2013 and January 11, 2013. 99. The Sheriff's compliance with pluintills aforessid Open Records Avt roquest, however, was not voluntary, but the result oFa court order which was issued on October 30, 2013 and grossly defictemt in several respects, The refusal of Sheriff CHRTS PRINE to reiease the Sherilf*s Daparimes*s fill investigative fle, was in furtherance of te aforesaid conspiracy and thus designed to withhold ‘information from Plaintiffs and to interfore with their eecess to the eourts for purposes uf seeking legal redress, 100. OF the materials that were reproduced by suid Sheriff's Department lor plaintifist cxathination, plaints were advised that certsin documeats or matoriels wete being: withheld for various reasons, including but not Timited to the desire to proteet the privacy of minors witase identity was otherwise disclosed or suggested in the cosuments, 101. As result, said Shosiff’'s Department withheld photographs and moving images that plaiifis were otferwise entitled to reccive. 102. In addition to the reflusel to disclose entine documents ar allow fir their review, ssid. Sheriff's Department redacted many if'not most of the documents it produced by eliminating any information that disclosed or suggested the idontty of individuals it maintained or considered to bo 073, as though the alleged minans were eniitled (o privavy or confidentiality undor the Open Records Act, which they do not 103, The aforesaid refusal to comply with plaintiff” ORA request constituted a deliberate and malicious effort to withhold information ftom plaintifis wha were legitimately entitled to receive sume as aTaeans of determining the tree cause of their son's death, as well 2s, the i¢ontities and involvement of ‘the individuals who were connected with or responsible for his death, Page 24 of 41104, The aforesaid retinal by Sheriff Chris Prine ond each af the various other defendant liv enforcement officers, including but not limited to Defendant Lowndes County Deputies end Defendant GBI Agonts, conducted a kind of investigation that was in furtherance of the aforesaid conspiracy and, therefore, was designed to nol only deliberately and maliciously cover-up the less-thar-adequate effort by said Iaw cnfercetncnt agencics to investigate the death of plaintiffs’ decedent, but to also cover-up the identities of those individuals responsible for said decedent's death, 105, In addition, the aforesaid refusal by Shoriff Chris Princ to comply with plaintiffs’ ORA request was designed to delsberately and maliciously cover-np how the defendants Irom the various lew cafoveamont agencias deliherarely and maliciously mishandled the subject investigation in suet a way that anyone who might ever be charged with plaintifis’ decedent's death would never be vonvieied due (0 «patently sawed investigation. 106, Upon receipt of the Lowndes County Sheriff's Investigative Tile rewarding the death of ‘Kendrick Johnsae, documents therein reves! that tie only students whose patents, including but not limited to Defendant RICK BELL retained an ettomey in respoise to two or mote requests to be interviewed ond who ultimately refused to be interviewed at all were Defendants BRIAN BFLI- and BRANDON BELL, Upon information and belief, the Fallure on the part of Defendant Lowndes Coumty Deputies and Defendant GBI Agents to interview Defendants BRIAN BELL and BRANDON BELT. was in Suriherance of the atiresnid conspiracy and designed to shield Defindants BRIAN BELL and BRANDON BELL, as well as others, fom possible criminal prosecution, 107, During the latter part of November 2014, the Lowndes County Shoriffs office chose te interview for the first Lime members of the high school’s wrestling team in response to allegations that school documents showed thet the alibi of Defendants BRANDON BPI. anit BRIAN BEEL were questionable. Upon information and belief, this failure of to promptly interview Ue tiga school’s ‘verwslling team was in flrtharanoe of the said conspizicy. Page 25 of 41108, As aesult of Plaintiffs discoveriag that their son's organs were missing. that their son's clothing was missing, as well as, the failure of Defendant Lowncles County Deputies ead Defendant GBL Ageats to interview Defendants BRIAN BELL and BRANDON BELL, plaiatiffs filed petition the Connty Coroner's Office for Lowndes County seeking te have the coroner convene 2 coroner's inqusst, 109. In response, Pleintifs aforasnid request ond petition, Bill Warson, Coroner tor Lowndes Connty, Georgia, refused to convene a coroner's inquest on the grounds ther he regarded the findings of Defoudant MARYANNE GAFFNEY-KRAVT to be conehisive. Upon information and belief, the aforesaid comner’s refusai to conduct a.coroner’s inquest was the rest of unlawful intimidation om the part of Defendants Lowarles County School Superintendent WILLIAM “WES” TAYLOR, Defendant Federal Burcan of lavestigation (“FBT") Special Agent and father of BRANDON and BRIAN BTS. RICK BELL, and Lowndes County Sheriff CHRIS PRINE. 110. Upor infortmation and belief, Coroner Bill Waison received unlawftl and malicious thrests from defendant Lowndes County School Supetintendenrt WILLIAM “WES” TAYLOR, defendant Federal Butea of investigation ("FBI") Special Agent and fether of Brandon and Brion Bell, RICK BRIT. amd Lowndes County Sheriff Chris Prine, all as a part of the aforesaid conspiracy ta interfere with plaintiffs? assess to the courts and effets to seek legal redress, TIRST CAUSE OF ACTI RICO Cause of Action The Plaintiffs re-allege and incorporate herein, as if’ set forth in Tul, each and every allegation contained in the preceding paragraphs and further alloge: LIL, Plaintiffs KENNETH JOHNSON and JACQUELYN JOHNSON ate bnsband and wife, not divorced, and are the parents of KENDRICK LAMAR JOHNSON, who died on Fanuacy 10, 2013, a the age of 17 years, lenving no spouse oF children. Page 26 of 41112, Prior ip January 10, 2013, deferdeut BRIAN BELT. attacked plaintif's decedent while on a school bus that had taken the high schoo!’ s football team to a game that was being played out of town, As a result of the brief fight which followed, defendant BRANDON BELL fold plaintifis’ decedent that “it ain't over.” In addition, deiendaat RICK BELL a¢vised plainciff's decedent fhat he should come to bis home to fight his sou defendant BRIAN BELL because the fight ou the bus was not a fair fight, 113. At all times relevant herein, defendants BRANDON BELL, BRIAN BELL and RICK BELL had been seeking revenge For Uke Tight at hal taken place om the aforesaid school bus. 114, On January 10, 2013, defendants BRANDON BELL, BRIAN BELL, RICK BELL, RYAN HALL, JOHN DO! and JANH ROE | planned, engineered, aud thus caused an unjustified asseult upon plaintiffs’ decedent. Upon information and belief, the assault arose from BRIAN BBLE's and BRANDON BELL’s disapproval of Kendrick Lamar Johnson's possible relationship with JANE ROE 1, a wwhite feanale. 15, The aforesaid assavlt upon plaimifis” decedent was also in zesponse to a parentul command mady by defendant RICK BELL, who alsa cugaged in parcutal ratification of the miscomdust by defendants BRANDON BEL. and BRIAN BELL. Accordingly, defeadant RICK BELL is also Lzble for the wioagfal death of plaintiffs" decedent pursuat 0 O.C.G.A. See, 51-22. 116, Asa direct and proximate result of the defendants BRANDON BELL, BRISNBEIL, RICK BRI, RYAN HALL, JOHN DOH and JANH DORs unlawfal and veekless disregard for the vighls of others, plaintigiy’ decedent suffered n-violoxt and neadiess death. 117, Plaintiffs have suffored anc continue to suffer as a resuit of, and though losing their ‘youngest son aud fhrowgh this homicide, 118, Each of the Defendants named hercin and whose specific conduct 4s identified in the preceding section entitled “Facts Common te All Claims,” Paragraphs 42 f0 11D, inclusive, engaged ia a conspiracy 10 conduct an orchestrated and comupt eilirt to cover up the misconduct of certain individuals, Page 27 of 41more particularly that of defendants BRANDON BELL, BRIAN BELL, RICK BELL, RYAN HALL, JOHN DOY and JANE DOH, aad as a consequence, was directed toward the Plaintis, as desetited horein. As such, said defendants’ conduct was intentional, uolawfal, ond miclicious, It is s0 outrageous ‘that itis not tolerated by civilized society 119. The foregoing acts and conduct constituted @ RICO Enterprise and a conspiracy in violation ofthe RIGO Act. O.C.G,A, §16-L41. et sg 120, In their conduct, euch of the Defendants named herein, and as spocifically sct forth ia Pacagrephs 42 to L10, herein, acted intemtionally, imowingly, with oppression, fraud and aualice and in reokless and conscious disregard of the rights of the Plaintiffs, The acts and conduct af the Defeadauts constitrte a coutinuotis and ongoing pattern of recketeering activity. within the meaning of RICQ.in such manner as fo damage the property sad person of Plaintiffs and their decedent, 121, At all material times, the Defendants engaged ia conduer in violuiiow of the laws of Georgia, ané, particularly, submitted more than 2 acts of racketeering activity as identified in O.C.G.A. §16-14-3(9K0B), Which consists of any act or threat involving munier and obsinotion of justioe, chargeable under tie laws of the United States or any of the several states, in which is punishable by ‘imprisoument-for more thas onc year. 122, The aforenamed defendants, and dhe other nuukefeering defendants cagaged in condact in violation of the laws of Georgia and, particularly, the mazed more than 2 ucis of Recksteoring activity a8 fdified in: (a) OCGA, $16-14-5@MAXIv), whish consisted of infizencing witnesses, ix violation of Code Ssction 16-10.9° (h) O.C.G.A. §16-14-3(9(A)(x¥), which consisted of conduct relating to pesjury and other falsifications in violation of Article 4 of Chapter 10 of this title and Code Sections 16-10-20, and 16-10- 91; Poge 28 of 41©) O.C.G.A. §16-14300VA)GeD, which ceasisted of conduer relating to tamperings will, evidence, in vioiation of Code Section 16-10-94; and @ 0€. witnesses, and informants, in violation of Code Section 16-10-33. $16-14.300)A)Garuif), which consisted of conduct relating te lampering with 122, Each of the Defendants named herein participated in a conspiracy, which was designed! to feilitete the cover-up of an assault and murdey of Kendzick Lamar Johnson. The various ways in whieh cach of the defendants connibuted to the conspiracy is ns follows: (@) Defendants BRANDON BELL, BRIAN BELL, RYAN HALL, JOHN DOT 1, JOUN DOB 2 JANE ROE 1, JANE ROE 2, and RICK BELL, with the aid and panteipation of the other Reckerooring Defendants, conspired (o assault, Kendrick Laumsr Johnsen, Giough the direct participation of JANE ROT: 2 and, upon luring him into an area where he in fact vans assaulted, thus causing him to be killed, and thercafter participeted in taking measures to conceal his body; () Defendants BRANDON BELL, BRIAN BELL, RICK PRI.L, JOHN DOE 1, and JOHN DOE 2 with the aid of the other Racketcoring Defendants, conspired in, and did in Pact tamper with evidenco, by moving the body, and removing and destroying Kendsick Johnson's clothing, {c) Delendanis CHRIS PRINE, SHANNON SALTERS, RAY MCGRAW, JACK WINNINGHAM, WANDA EDWARDS, STRYDE JONES, AARON PRITCHETT, LOGAN HENDARSON, RANDY LIGHTSEY, MICHAEL ADAMS, JACK PRIDDY, KERRY QUINN, CHRIST? GRIFFIN, BRYCE WHITENER, CHRISTOPHER BURKE, TROY BLACK, HOWARD HISHER, MARK MASKULE, ROY HART, JOHN MARION FRANK SIMMONS, STEVE TURNER, AMY BRASWEI., MIKE CALLATIAN, LINDSAY MARCHANT, WES HORNE, and JOHN DOE 3, ‘were, 05 law enforcement officers, under ¢ duty to investigate BRANDON BBLL aud BRIAN BELL's possible participation, but pursuant to their conspitacy, refused to do so, or did so in a manner to shield and protest BRANDON BELL and BRIAN BELT. from criminal prosecation for reasons relating to race. Page 29 of 41iscrituination und heir rolationship as the children af Defendant and PBF Agent RICK BELL, and thus the chikiren ofa fellow law enforceascut officer; (@ Dofeadats CHRIS PRINE, SHANNON SALTERS, RAY MGGRAW, JACK WINNINGHAM, WANDA EDWARDS, SIRYDE JONES, AARON PRITCHIT, LOGAN HENDERSON, RANDY LIGHTSEY, MICHAEL ADAMS, JACK PRIDDY, KERRY QUINN, CHRIST! GRIFFIN, BRYCE WHITENER, CHRISTOPHER BURKE, TROY BLACK, HOWARD FISHER, MARK MASKULE, ROY HARI, JOHN MARION ERANK SIMMONS, SIBVH TURNER, AMY BRASWELL, MIKE CALLAHAN, LINDSAY MARCUANT, WES HORNE, and JOHN DOE 3 were under a duty to contact and notify the Lowndes County Coromer’s Office, but filed to do so. As a port of a conspiracy to tamper with the evidenec at a crime secna, as well as, intimidate and tamper with witnesses; (© Defendants CHRIS PRINE, STRYDE JONES. WILLIAM “WES TAYLOR and JAMES D. THORNTON, were under a duty to disclose truthful information to plaintifis regarding the cirommstances under which their child, Kendrick Lamar Johnson, was killed, but fatled to do so by providing them with false information as.a means of deferring them from pursuing legal recourse and other available remedies as provided under law; (D Defendants CHRIS PRINB, SHANNON SALTERS, RAY MCGRAW, JACK WINNINGHAM. WANDA KDWARDS, STRYDE JONES, AARON PRITCHETT, LOGAN HENDERSON, RANDY iIGHTSEY, MICHAEL ADAMS, JACK PRIDDY, KERRY QUINN, CHRIST? GRIFFIN, BRYCH WHITENER, CHRISTOPIBR BURKE, TROY BLACK, HOWARD FISHTR, MARK MASKUTP, ROY HART, JOHN MARTON FRANK SIMMONS, STEVE TURNER, AMY BRASWELL, MIKE CALLAHAN, LINDSAY MARCEANT, and WES TTORNE each had a duty (0 prevent each other from participating in a conspiracy, which was designed to obstruct justice by engaging in a cover-up of the evidenee pointing ‘9 the participation of BRANDON BELL and BRIAN Page 30 of 41BELL in en cffert fo shield and protect ‘BRANDON BELL and BRIAN BELL from etitninal prosecution ‘or reesous lating te save discritninalion and their relationship as the children of Defendaat and TBI Agout RICK BELL, and thus tho children ofa follow law enlorestnent officer; (g) Defendant SCOTT FORTHE, a media specialist with the Defendant LOWNDES COUNTY SCHOOL DISTRICT, with the aid and assistance of the other Reckotocring Defeadants, participaved in tae conspizacy to cover-up evidence of Kendrick Lamar Johnson BRANDON BELL's and BRIAN BELL’s whervabouls on January 10-11, 2013 by illegelly tampering with evidence throveh editing, deleting, md altering the video recordings that were generated from the Lowndes High School's surveillance systomi (@) Defendant STEVE OWENS, owner of Owen's Transport Service, and with the aid and assistance of the other Rackctecring Defendants, participated in the couspizaey to coverup evidence portaining to Kendrick Lamar Johnson's doath by illegally tampering writ evidence through the destruction of Kendtick Lamar Johnson’s clothing and internal organs, (® Defandmts MARYANNE GAFFNEY-KRALT und RODNEY BRYAN, employees of the Georgia Bureau OF Investigation’s Coatral Crime Lab lovated in Dsy Branch, Georgia, with the aid and assistance of the other Racketeering Defendants, participated in she conspiracy to coverup evidence pertaining to Kendrick Tamar Johnson's death bys (Q) illegally tampering with evidence through the destruction of Kendrick Johnson's fnternal organs 2) illegally tampering, with evidence though the destruction of Kendrick Jehasoa’s clothings (3) theft of evidence through the desiruclion of Kendrick Johnson's clothing ead énrernal ongaas; Page 31 of 47(4) falsification of official records and suborning perjury through the submission of a {falsified autogsy report which centained intentional misrepresentations regarding the trae canse of Kendrick Johnson's deat; @ Dsfendants LARRY HANSON, as City Manager for the Defendant: CITY OF VALDOSTA, with the wid and assistance of the other Racketeering Defendants, participated in the conspirecy’ tn eower- ‘up evidence pertaining to Kendrick Lamar Johnson's death by obstructing justice (ough bis dertand that Plaintiffs obtein a cout order from a judge of the Superior Court of Lowadss County es a condition to ceahuming their child’s remains from a city-owned cemetery, all of witich was not requited by lav, but which was falsely represeuted to the Plaintiffs for the purpose of altempting lo prevent Plaintiffs from obtaining an independent autopsy of Kendrick Tamar Iohmsom: snd (&) Defendants CHRIS PRINE and STRYDE JONES, with the aid and assistance of the olber Racketeering Defendants, participated in the conspiracy to coverup evidence pertaining ta. Kendrick Lamar Johuson’s death by: (1) obsivcting justice by falsely charging and malicionsly prosecuting Dalion Cheuncey for allegedly providing felsc information to law enforoement officials when the real ‘purpose of the asrest and prosecution was to intimidase and this sileace ‘hin regarding {information fhat lie may have had regarding the true cause of Kendrick Johnson's death, as well as, the ideatity of the persons responsible for causing same; jon of an affidavit (2) falsification of official records and perjury through the sabrn ‘Which couteined falsified information for the sole purpose of obtaining, a1 arvest warrant that was promised pon the desir to {ntimidste end thus silence Dalton Chameey segatding informetion thet he may have had regarting the true cause of Kendeick Tchuason’s death, as well as, the identity of dhe persons responsible for easing same: and Page 32 of 41(3) wines tampering that vas conducted, and bascd upon the desire to intimidate and thus silence Dalton Chauncey regarding information that he may have had regarding th true cause of Rendrick Johnsons death, as well as, the ideutiy of the persons responsible for eausing same. () Defendan's RICK BELL, with the eid and assistanes of the ofher Racketeering Defendants, ‘participated in the couspitacy 10 cover-up evidence pertaining lo Kendrick Lamar Johnson's death by: (1) obstructing justice by tampering with witneaes when he met with Defendant RYAN ALL and Aaliyah Chitin prior to Deir scheduled appearance befixe a Tederal grand Jury fot the express purpose of attempting to influenve their testimony; and. (2) tampering with witnesses hy attempting to intimidere a wimess from testifying ‘truthfully and completely eo fo all matters kuown to them and which are deemed 10 be relevant to the investigition pertaining to Kendrick Lamar Sohnsen’s death, 123, Bach and every one of the foregoing “predicate acts," comprising cach of the violations of the o inal laws of the United States and the violations of the Statv eriminal laws, is related to the overall fraudulent scheme and conspiraey of and by the Racketeering Defoadants to engege ins RICO Enterprise. 324, Air the U, 8. Department of Justice made knovn its inferrion fo conduct an investigation inva the death of Kendrick Johnson, the Racketeering, Defondents undertook measures end encouraged cach offer not to eveal their pactcipation in the RICO Katerprise. SECOND CAUSE OF ACTION VIOLATION OF PLAINTIFFS? RIGHT TO DUR PROCESS UNDER STATE LAW (Against All Defendants) “Tho Plaintiffs re-allage and incorporate horefn, as fPset forth in all, each and every allegetion contained in the preceding paragraphs and furcher allege: Page 33 of 1124, Atall material times, the Dofendaats CHRIS PRINE, RAY MCGRAW, JACK WINNINGHAM, WANDA EDWARDS, SIRYDE JONES, AARON PRITCHETT, LOGAN HENDERSON, RANDY LIGHTSEY, MICHAEL ADAMS, JACK PRIDDY, KERRY QUINN, CUIRISTI GRIFPIN, BRYCF. WHITENER. CHRISTOPHER BURKE, TROY BLACK, HOWARD FISHER, MARK MASKULE, ROY ITART. JOTIN MARTON FRANK SIMMONS, STEVE TURNER, RODNEY BRYAN, AMY BRASWELL, MIKR CAT ATIAN, EINDSAY MARCHANT; WES HORNE, RODNEY BRYAN, AND MARYANNE GAFFNEY-KRAFT owed a duty to the Plaintifis to not only properly investigate the oircamstances surrounding the death of teir son, Kendrick Fama Johnson, and in the course thereo®, determine the identities of at individuals who were in any way responsible for eausing their son’s deeth, but also fo avoid mishandling the investigetion in such @ way as to lessea the likelihood of aayone beizg arested or sncvesstully prossvuted for ay such crime. 125, As Jaw enforcement officers and state actors, the aforesaid dofendants identified in cho ‘paragraph above violated the due process clanse under the State Constitetion for the State off Georgia by deliberately mishandling the investigation into the circumstances surrounding the death of Plaintiffs? aforesaid sun due to racial discrimination and a desire to protect the interests and children of a fellow law enforcement officer. 126, As a result of the failure of Racketeering Delendants to perform the investigation into the death of plaintifis" son as se forth in the preceding psrauraph, as well as, by interfering with their due -povcess tight to have access fo the courts for legal recites, the aforesaid defesdants have violated the duc Process cfause under the State Constitution forthe State of Gengia, 127, Said Defendants’ conduct, in their individual and official capacities, have damaged painGfff, and ay a consequence, are demandiag compensation in an amount thal stall be proved a: trial. THIRD CAUSE OF ACTION Page 3400 41VIOLATION OF PLATNTIFES’ RIGHT TO EQUAL PROTECTION UNDER SLATE LAW (Against All Defendants) ‘The Plaintiffs ro-allege and incorporate herein, as ifset fort in full, cach sad every allegation comined in the preceding patagtaphs and firther allege: 128, Atoll material times, the Defendants CHRIS PRINE, SHANNON SALTERS, RAY MCGRAW, JACK WINNINGHAM, WANDA EDWARDS, STRYDE JONES, AARON PRITCHETT, LOGAN HENDERSON, RANDY LIGHTSEY, MICHAEL ADAMS, JACK PRIDDY, KERRY QUINN, (CHRISTI GRIFFIS, BRYCE WHITENER, CHRISTOPELR BURKE, TROY BLACK, HOWARD FISHER, MARK MASKULE, ROY HART, JOHN MARION FRANK SIMMONS, STEVE TURNER, RODNEY BRYAN, AMY BRASWELL, MIKE. CALLAUAN, LINDSAY MARCHANT, WES HORNE, ROPNPY PRYAN, AND MARYANNE GAFFNEY-RRAFT owed « duly to the Plaintifl to not only properly investigate the circernstances surrounding the death of (heir son, Kendrick Lamar Tobnson, and in the course thereof, determine the identities of afl Individuals who were in any way responsible for causing their son's death, 129, As law enforcement clfivers ann! stale actors, the albtesaid defeudants identified in the paragraph cbove violared fre equal protection clause under the State Comstisntion for the Stare of Goorgia by neglecting their duty to properly investigate the circumstances surrounding the death of plaintifis? aforesaid son and, minimally in a manner that woul bave been the same as that afforded any other individuals had plains been Coucasian or menibers of the white race. 136, As a result of the failure of Defendants CHRIS PRINE, SHANNON SALTERS, RAY MCGRAW, JACK WINNINGHAM, WANDA EDWARDS, STRYDT.JONTS, AARON PRIYCHBIT, LOGAN HENDERSON, RANDY LIGHTSEY, MICHAEL ADAMS, JACK PRIDDY, KERRY QUINN, CHRISTI GRIFFIN, BRYCE WHITENER, CHRISTOPHER BURKE, TROY BLACK, HOWARD FISHER, MARK MASKULE, ROY HART, JOHN MARION FRANK SIMMONS, STEVE TURN, Page 35 of 41RODNBY BRYAN, AMY BRASWELL, MIKE CALLATIAN, LINDSAY MARCITANT, WES TIORNE, RODNEY PRYAN, AND MARY ANNE GAFENEY-K.2AI'T to perform the investigation into ‘the death of plaintifis’ son as set forth in the preveding paragraph, as well as, by interforing with their duc process right to have access to the county fr legal redness, the aforesaid defendants have vieloted the equal protection clause under the State Constitution for the State of Georgia. 131. Seid Defendants" conduct, in thei ‘individual and official capacitios, have damaged. plaints, ead 2s a consequence, are demanding compensation in an stnount that shall be proved at trial FOURTH CAUSE PLAINTIFFS’ PETITION FOR INJUNCTIVE RELIEK (Against Defendants Chris Prine and Maryanne Gaffaey-Kraft) ‘The Plaintifis re-allege and incorporate herein, ss if set forth in full, ech and! every allegation contained in the preceding paragraphs and further allege: 132, Atalll material times, dhe Defendant CHRIS PRINE, and investigators within the Lowndes County Sheriff's Department has the authotily to make an official request that Defendant MARY ANNE GAPTNEY-KRAPT exemining the tissue specimens collected by Dr, William Anderson during the course of his auinpsy, and thereafter re-exomining her findings to determine whether she should correct any aspect of het conclusions as a forcusic pathologist for the Georgia Bureau of Investigation, and, as ‘required by taw, 193, At all material times, Defendant MARYANNE GAFFNEY-KRAFT has a daty ty perform ‘the secvices sot forth by hoe tems of employment as n forensic pathologist for the Georgia Bureau of Investigation, ond, a5 otherwise required by law. 134, Followiag the aforesaid receipt of an autopsy report that wes based upon an autopsy that was performed by Dr. William Anderson of Orlandy, Florida, which disputed the official findings of the autopsy perforined by Defendant MARYANNE GAFFNEY-KRAFT several months before, Netindant Page 36 of 41MARYANNE GATTNEY-KRAPT was requested by Dr. Anderson to examine tusue specimens whea he removed thom from the semains of ple’ devedent, 155. Mezsover, basod upex the, the effivial findings ofthe astopsy performed by Defendant MARYANNE GAFFNEY-KRAFT, said defendant omitted any asanowledgimemt that she reviewed ot considered a medical report submitted by the EMI's (emergency medical techaieians) who observed Oe ‘body ef pists" decedent af the tine that it was Sst discovered, Thke medical report subsmited by the EMI's revealod the prosence of a bruise ata location which was consistent with Dr. Anderson’s findings 136. As taxpayers and citizens nthe Stale of Georgia, plants ure owed a duty oa the part of Dafendumt MARY ANNE GAPTNEY-KRAPT to oxercise reasonable judgment in carrying out her ole 3s 4: forensie pathologist associated with the investigation into the cause of decth of Plaintils” on, Kendick JLatoar Johnson, regardless of whesber said defendeat agrees withthe Findings of others within her Fold of expotise. 137. To date, Defendant MARYANNE GAFENEY-CRAFT nor any mnamber of the Georgia Bureau of Investigation, ites shown an iuolnation or desire to exaunine tissue specimens which Dr. ‘Andotson removed from an area of te remains of plalaiffs’ devedent and that was never “sostioned” and ‘us examined noraddvessed by Dofendact WARY ANNT. GAFFNEY-KRAPT. This fallur on the pat of Defendant MARY ANNE GAFFNEY-KRAFT constitutes a violation of slate lew requiring that death acd other such investigations be performed in a competent and reasonable manner. | 138, Plainifs have no sdequate legal remedy available lo them and tho injury that will esa is imminent and imeparcble. 139, Asa consequence, plaintiffs prey thet this court will direct Defendant VERNON KTTNAN ad Defend MARYANNE GAFFNEY-KRAPTT fo inako arrangements forthe exarnination of the tissue specimens collected by Dr. William Anderson and upon doing, so, pive proper consideration to such evidence as dictated by ier honest and professional judactcat, Page 37 of 41EIFTH CAUSE OF ACTION INTENTIONAL TNPTACTION OF EMOTIONAL DISTRESS (As Against Defendants Ryan Hall and Richard Bell) ‘The plaintiffs re-ulleye umd incorporate herein, as if ser forth in full, each amd every allegation contained in the preceding paragraphs ofeach complaint or wended complaint and futher allege: 140, On a date currently anknowa to plaintiffs, but which cecurrad after January 29, 2014. the defendants RYAN HALL and RICK BELL met in « parking lot of Lowndes Thigh School, 141. Upon fnfermation ind betiet! Defendants RYAN HALL and RICK BRLT. camspired with ‘one atotier on said occasion for purposes of preventing fidse and misleading inlurmation to kaw enforcement officials, ineteding but not fimited to a federal grand jury 142, Upon information and belicf, Defendanss RYAN HALL and RICK BELL conspived with ‘one enother on suid oceasion for purposes of presenting false and misleading intimation to «federal _grond jury which had subpoenaed Defendant RYAN HALL to appear and give sworn festimiony in connection with am investigation into the death of plaintifis’ decedent, Kendrick Johnsex. 143, pea information and belief, Defendant RICK BELL delivered, or cause to be eelivered, printed materiais pertaiaing to the school attendance reconis of Defendant RYAN HALL as a part of conspiracy to mislead investigators, the grand jury. and plaintiffs into believing thet the death of plaintiff’ decedent was due to accidental eiroarastances, and that regardless of whether the denth of plaintisfs’ docodent was accidental or intentional, Defendant RYAN HALL was not involved due to his pprescueo et another location in the sehocl 144, The aforesaid conduct of Defendants RYAN IIALL und RICK BELL was both intentional, 25 wall es, extreme and outrageous 145, As a dircet and proximal result of tue aforesaid intentional ssisconduet of Defendants RVAN HALL and RICK BELL, plaintiffs wore forced te cndure severe emotional distress. Page 38 of 4146. Ia their condncr, said Defendants acted intentionally, knowingly, with oppression, Stand and malice and in reckless and conscious disregard of the rights of tie Plaintifis, ‘The Plaintifls are, therefore, centiled to punitive and exemplary damages fom each af the Defendants in such amour a shall bs necessary and appropziate to panish the Vofendants and to deter them aud anyone else from ever ‘committing similar indecencies anc acts of corruption, SIXTH CAUSE OF ACTION FRAUD THROUGH STATFMENTS AND SILENCE (As Against All Defendants) ‘Ths plaintidls re-allags and incorporate herein, as ser forth in full, ench and every allegation contained in the preveding parsgraphs of each complaint or amended complaint and further allege: 147. On January 19, 2013, Plaintifis contceted members of the Inw enforcement ogencies within Valdosta, Lawndes County, Georgis, inciding the City of Valdosta Police Depattment and the Lowaxdes County Sherif" Office, all Sor purposes of establishing the whereabouts of plaimtifi’ decedent, 148. On the moming of Femuary 11, 2073, Plaintil JACQUELYN JOHNSON contacted staff members of the Lowades High School for purposcs of establishing the whereabouts of theit son, Kendrick Jonson, 149, Tpen contacting personnel with each of the aforesaid law enforcement agencies, as well as, the Lowndes Counzy High School, Plaintiff JACQUELYN JOHNSON was adhised that they did net now, ot were unaware as to the whoreabouts of plaintiffs" son, Kendrick Jetunson. 150. On or about January 11, 2073, the body of Kendrick Jobson was discovered ia the old ayinesium at Lowndes high school, approximately eight (8) hours after Plaimtif? JACQUELYN, JORINSON had made inquiry to members of the aforesaid foval law enforcement agencies. 151. Upon information and beliaf, Lewades Couny School Superiateactent Defendant WES ‘TAYLOR, Lowndes County Sheriff Defendant CHRIS PRINE, Valdosta Police Chief Defendant Page 39 of 41FRANK SIMMONS, Defendaut RICK BELL, and Lowndes County Sheriff's Investigator Detiondent STRYDE JONRS, were each aware on January 10, 2013 that plaintifts’ son, Kenerick Johusoa had died or vais severvly injured on Jimuary 10, 2015, and that his body was on the eampus of Lowndes High School, 152, Upan information and belief, each of the aforesaid defendants were, by virtue of their role as public safety officers, school administrators and public officials, nudcr a duty to disclose +o plaintiffs the. location and condition of plaintiffs? decedent, 153. Contrary to said duty, each of fry aforesaid detimdents misled plaintiffs insofar as denying Anowledge of plaintiffs’ decedent’s whereabouts ot their possession of information that would have been responsive to plaintiffs” inquiry regarding the whereabouts of theit son, Kendrick Johnson, 154, Contrary to said duty, cach of the aforesaid defindants misled plaintifs insofar as refusing 1 disclose, ic. through thetr sitence, that they had knowledge or wore in possession of information that would have been responsive to plaintiffs’ inquiry regarding the whereabouts of theit son, Kenétick Jobson, 155. The aforesaid defendants carried out the aforementioned through the engagement and execution of ¢ conspiracy for purposes of misleading plaints regarding the whereabouts of ‘their son, Kendrick Johnsen, and for purposes of shietding and thes protecting Defendants BRIAN BELL, BRANDON BELL, and RYAN HALL fiom accepting resyonsibility for their part in causing che death of ‘Kondrick Fohasou, 156, As a direct and proximal result of the aforesaid misconduct by Defendants WES TAYLOR, CBRIS PRINB, FRANK SIMMONS, RICK BELL, ond STRYDE JONES, Plainiifis were restrained fiom taking setion that may have saved the lift of their son, Kendrick Johnson, of ead to the prompl {dentiffeation of their son’s cause of death, 2s well as the persons who were responsible. WHERIFORE, the Plaintifis request the following relief: Page 40 of 41a. Anaward of compensatory damages for each Plaintiff, i an amount Geored approptiate by the enlightened conscience of the tier of fact jointly and severally, against the Rackstwaring Defendants; b, An award of punitive damages, jofully and severally, against tho Defendants; . An awaed of pre-judgment ane post-judgment interest; 4, An award of costs, including, but not fimited to, discretionary costs, attomeys? fees andl ‘expenses incurred in pursuing this case; A declaratory jndpmont that thc Racketocring Defendants engaged in conduct in vielation of RICO; and £ Any other and forther relief this Court deems just and proper ‘THE C.B. KING LAW FIRM BY: Cra a ‘Attomey for Plaintiffs Prepared by: Chevene B. King, Jr, Post Office Drawer 3468 Albany, GA. 31706 229}436-0524 ‘Suule Bar No.: 420105 Page 41 of 41AFFIDAVIT OF CHEYENE 8. KING, JR, STATE OF GEORGIA COUNTY OF DOUGLERTY PERSONALLY APPEARED before me, an officer duly authorized by law to administer caths, Chevene B. King, Jr, who after first being duly sworn, states: L “My name is Chevene B. King, Jr, and Lam competent in all respoets to testity regarding the maiters set farth herein. J am the atforney of record for the plaintiffs in the above-siyled actions, and T have personal knowledge of the facts stated herein and know them to be tus. 2, Uhot on July 8, 2027, I visited the clerk's ollice for the Superio® Court of Lowndes County and determine that all court costs associated with any previously filed action reasserted ‘herein have been paid in fall, 3. The foregoing the submission was the result af a good faith inquity to the Clerk's office ‘by the undersigned, and was accompanied by the receipt of written confirmation, AFFIANT FURTHER SAYETH NOT. Swrorn to and subscribed before me, this (1 day of slvly 201 it Notary Public att, iy samnission esis, 9 228 [NOTARIAL SEAL]