IN Tru I]NITED STATES DISTRICT COURTMIDDLE DISTRICT OF GEORGIA

MACON DTVISION

PsyD.,

Plaintffi (propria persona)

v.

DOCTORS HOSPITAL OF AUGUSTA, LLCHeyward Wells, Doctors Hospital administrator;James Cole, Doctors Hospital Chief of Security;Thomas Dorn, Doctors Hospital social worker;Trisha Foster, Doctors Hospital patient advocate;Richard Cartie, MD Doctors Hospital medicaldirector of pediafric critical care;Chris Haga, Doctors Hospital admissions director;Donna Masters, Doctors Hospital nurse manager;Terrell Yelverton, Doctors Hospital nurse;Julie Lewis, Doctors Hospital nurse;Jimmy Wren, Richmond County Deputy Sheriff;Lisa Rambo, Georgia Southwestern JudicialDisfiict Juvenile Judge;Patick Eidson, Macon County DFCS attorney;James Hurt, Macon County DFCS attorney;Karan Albritton, Macon County DFCS supervisor;Susan Barr, Macon County DFCS social worker;Jane Doe, Richmond County social worker;Janet Doe, Richmond County social worker;Edna Messer, Pediatric Associates offrcemanager;Stacee Fussell, CASA supervisor ;Estella Lusane, Court Appointed Special Advocate;each spouse ofedch defendant,in their individual capaclty,

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civilActio"Ng s 14-CV- 0 0S

Jury Trial Demanded

Defendants

Complaint

This is a civil action commenced pursuant to 42 U.S.C. $ 1983 to redress the

deprivation of rights certain of which are expressed and guaranteed within the

Constitution or supreme Law of the Land.

their sons F.C., R.C., and D.C.,

Plaintiffs are natural persons seeking to hold Defendants accountable for

depriving Plaintiffs of their inalienable rights under color law and Defendants' failure,

neglect, or refusal to protect Plaintiffs from said deprivations although it was within their

power to do so.

The Plaintiffs' son was unreasonably seized, his Fourth and Fifth Amendment

rights violated due to a culmination of malicious actions set into motion by a pediatric

physician working in concert and collaboration with state actors, several nurses,

administrative hospital staff, the hospital's admissions director, the Doctors Hospital

patient advocate, a hospital social worker, two Richmond County, Georgia DFCS social

workers, two Macon County social workers, a Juvenile Judge, at least two Macon County

DFCS attorneys, the Doctors Hospital security, and a Richmond County Sheriff's Deputy

without reasonable cause or emergency circumstances justifying such deprivations.

The above entitled court is hereby respectfully directed to take judicial notice that

each of the principal actors named as Defendants herein, at all material times and places

mentioned herein, were cognizantly acting in concert under color of law to the manifest

injury and deprivation of Plaintiffs' Constitutionally secured rights.

Jurisdiction and Venue

1. The Plaintiffs, (redacted father) and (redacted mother), individually and as

parents of F.C., R.C., and D.C., who reside in Macon County Georgia at a confidential

address with a mailing address of P.O. Box 311, Ideal, Georgia 31041, bring this civil

rights lawsuit pursuant to 42 U.S.C. § 1983 to redress the deprivation of their rights by

the Defendants secured to them and expressed within the United States Constitution.

2. Jurisdiction of this Court is invoked under 42 U.S.C. § 1983 and the supreme

Law of the Land. Venue properly lies in this Court given that all of the parties reside in

this federal district.

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Parties

3. Plaintiffs (redacted father), (redacted mother), and their young sons F.C., R.C.,

and D.C. are Americans residing near the city of Ideal within the State of Georgia.

Aforementioned Plaintiffs are beneficiaries of the public trust known commonly as the

Constitution and the supreme Law of the Land.

4. All Defendants are "persons" within the meaning of 42 U.S.C. § 1983 and at

all relevant times were acting under color of law.

5. Defendant DOCTORS HOSPITAL OF AUGUSTA, LLC (a legal fiction) is

located at 3651 Wheeler Rd., Augusta, Georgia 30909. Summons may be sent to the

registered agent in Georgia as follows: DOCTORS HOSPITAL OF AUGUSTA, LLC, c/o

"The Corporation Process Company", 2180 Satellite Blvd., Suite 400, Duluth, Georgia

30097.

6. Defendant Heyward Wells, at all times and places material hereto, was acting

in the capacity of an employee within the Doctors Hospital. Defendant Wells may be

served summons at : Doctors Hospital of Augusta, 3651 Wheeler Rd., Augusta, Georgia

30909. He is being sued in his individual capacity.

7. Defendant James Cole, at all times and places material hereto, was ostensibly

acting in the capacity of Security Chief within the Doctors Hospital. Defendant Cole may

be served summons at : Doctors Hospital of Augusta, 3651 Wheeler Rd., Augusta,

Georgia 30909. He is being sued in his individual capacity.

8. Defendant Thomas Dorn, at all times and places material hereto, was

ostensibly acting in the capacity of a social worker within the Doctors Hospital.

Defendant Dorn may be served summons at : Doctors Hospital of Augusta, 3651 Wheeler

Rd., Augusta, Georgia 30909. He is being sued in his individual capacity.

9. Defendant Trisha Foster, at all times and places material hereto, was

ostensibly acting in the capacity of a patient advocate within the Doctors Hospital.

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Defendant Foster may be served summons at : Doctors Hospital of Augusta, 3651

Wheeler Rd., Augusta, Georgia 30909. She is being sued in her individual capacity.

10. Defendant Dr. Richard Cartie, at all times and places material hereto, was

ostensibly acting in the capacity of medical director of pediatric care within the Doctors

Hospital. Defendant Cartie, may be served summons at : Doctors Hospital of Augusta,

3651 Wheeler Rd., Augusta, Georgia 30909. He is being sued in his individual capacity.

11. Defendant Chris Haga, at all times and places material hereto, was ostensibly

acting in the capacity of admissions director for Doctors Hospital. Defendant, Chris

Haga, may be served summons at : Doctors Hospital of Augusta, 3651 Wheeler Rd.,

Augusta, Georgia 30909. He is being sued in his individual capacity.

12. Defendant Donna Masters, at all times and places material hereto, was

ostensibly acting in the capacity of nurse manager within the Doctors Hospital.

Defendant, Donna Masters, may be served summons at her primary place of

employment: Doctors Hospital of Augusta, 3651 Wheeler Rd., Augusta, Georgia 30909.

She is being sued in her individual capacity.

13. Defendant Terrell Yelverton, at all times and places material hereto, was

ostensibly acting in the capacity of a nurse within the Doctors Hospital in Augusta,

Georgia. Defendant Yelverton may be served summons at his primary place of

employment: Doctors Hospital of Augusta, 3651 Wheeler Rd., Augusta, Georgia 30909.

He is being sued in his individual capacity.

14. Defendant Julie Lewis, at all times and places material hereto, was

ostensibly acting in the capacity of a nurse within the Doctors Hospital. Defendant Lewis

may be served summons at her primary place of employment: Doctors Hospital of

Augusta, 3651 Wheeler Rd., Augusta, Georgia 30909. She is being sued in her individual

capacity.

15. Defendant Jimmy Wren, at all times and places material hereto, was

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ostensibly acting in the capacity of a Richmond County employee under color of state law

and exercising the public trust powers belonging to an office styled as 'Office of the

Sheriff '. Defendant Wren acted in the capacity of Richmond County, Georgia Sheriff's

Deputy. Defendant Wren may be served summons at his primary place of employment:

400 Walton Way, Augusta, Georgia 30901. He is being sued in his individual capacity.

16. Defendant, Alicia Coogle Rambo, is an attorney and Juvenile Judge within

the Southwestern Judicial Circuit. Defendant Rambo, may be served summons at her

primary place of business: Sumter County Courthouse, P.O. Box 607, Americus, GA

31709. Defendant Rambo, at all times and places material hereto, was ostensibly acting

in the capacity of a Sumter County employee under color of state law and exercising the

public trust powers belonging to an office styled as 'Juvenile Court Judge.' She is being

sued in her individual capacity.

17. Defendant, Patrick Eidson, is an attorney for DFCS. Defendant, Patrick

Eidson, may be served summons at his primary place of business: 101 Walnut Street,

Suite A, P.O. Box 570, Leesburg, GA 31763. He is being sued in his individual capacity.

18. Defendant, James W. Hurt , is an attorney for DFCS. Defendant, James W.

Hurt, may be served summons at his primary place of business: 111 W. 13th Ave.,

Cordele, GA 31015. He is being sued in his individual capacity.

19. Defendant Karan Albritton, at all times and places material hereto, was

ostensibly acting in the capacity of a supervisor under color of state law within the office

styled as 'DFCS' , 'The DEPARTMENT', or 'Department of Family and Children

Services'. Defendant Albritton may be served summons at her primary place of

employment: Macon County DFCS, P.O. Box 457, 413 Clifton Bradley Road,

Oglethorpe, Georgia 31068. She is being sued in her individual capacity.

20. Defendant Susan Barr, at all times and places material hereto, was ostensibly

acting in the capacity of a social worker under color of state law within the office styled

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as 'DFCS' , 'The DEPARTMENT', or 'Department of Family and Children Services'.

Defendant Barr may be served summons at her primary place of employment: Macon

County DFCS, P.O. Box 457, 413 Clifton Bradley Road, Oglethorpe, Georgia 31068. She

is being sued in her individual capacity.

21. Defendant Stacee Fussell, at all times and places material hereto, was

ostensibly acting in the capacity of an office manager for CASA (Court Appointed Special

Advocates) . Defendant Fussell may be served summons at her primary place of

employment: SOWEGA CASA, P.O. Box 732, Americus, GA 31709. She is being sued

in her individual capacity.

22. Defendant Estella Lusane , at all times and places material hereto, was

ostensibly acting in the capacity of an Officer of the Court under color of state law and

exercising the public trust powers belonging to a CASA (Court Appointed Special

Advocate). Defendant Lusane may be served summons at her primary place of

employment: SOWEGA CASA, P.O. Box 732, Americus, GA 31709. She is being sued

in her individual capacity.

23. Defendant Edna Messer, at all times and places material hereto, was

ostensibly acting in the capacity of an office manager for Pediatric Associates. Upon

information and belief Ms. Messer faxed private medical documents to state actors Estella

Lusane and Stacee Fussell without Lawful authority to do so. Defendant Messer may be

served summons at her primary place of employment: Pediatric Associates, 116 South

Houston Road, Warner Robins, GA 31088. She is being sued in her individual capacity.

24. The true names, legal identity, and address's for summons for all of the

named Defendants' spouses and the two Richmond County DFCS social worker

Defendants, Jane and Janet Doe, are unknown at this time, but will be added by

Amendment when ascertained, each in his or her individual capacity.

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Judicial Notice Statement

25. The above entitled court is respectfully directed to take judicial notice that

each of the principal actors named as defendants herein, whether bound by the solemn

Oath or affirmation mandated at Article VI of the supreme Law of the Land in fact or not,

did willfully exercise powers belonging to an office of public trust and, by such conduct,

manifestly accepted the duties, obligations, and liabilities attendant to a trustee of such

(public trust) powers.

26. The above entitled court is hereby further respectfully directed to take

judicial notice that it has been undeniably established as a fundamental maxim of Law

that the supreme Law of the Land is wholly within the purview of the foundational

precepts set forth in the American Declaration of Independence which makes

unmistakably clear that, by operation of Law, the primary and superseding duty

(obligation) imposed upon anyone giving exercise to public trust powers is to "....secure

(make safe)...the rights of Life, Liberty, and the pursuit of Happiness [with which all

(wo)men are endowed by their Creator] - which encompass a whole plethora of other

more specific rights relevant thereto.

27. Plaintiffs assert herein that Defendants, acting in concert and in such

respective official capacities, not only failed to perform said primary and superseding

obligation to Plaintiffs but manifestly acted contrary to said protective requirement with

willful intent. Said primary obligation also carries the inherent ancillary duty to prevent

such deprivations from occurring or reaching culmination. Plaintiffs further assert herein

that Defendants were noticed, at all material times and places, that their conduct was

unlawful and injurious to the secured rights of Plaintiffs and that any defense raised on

the basis of "ignorance of the law" or "innocent intent" is undeniably without factual

foundation.

28. The above entitled court is hereby further respectfully directed to take

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judicial notice that the spouses of the principal actors named as Defendants herein,

whether acting in active or passive capacity, are properly joined as party defendants

hereto pursuant to the long established precepts of coverture, marriage, accessory

contract, and division of spoils as well as abundant stare decisis upon the subject(s) of

accessory, tontine wagering, and misprision - all of which are relevant to the intrinsic

nature of the instant action now before the eyes of the court.

Facts

29. On December 4th, 2012 at approximately 4PM Plaintiffs' two year old son ,

F.C., accidentally burned the tips and tops of both of his feet.

30. F.C.'s parents immediately washed their son's wounds, applied honey (a

medically appropriate action), loosely wrapped his feet, and delivered him to the

Coliseum hospital in Macon, Georgia.

31. Coliseum medical staff again washed and wrapped F.C.'s feet recommending

F.C. be seen by medical staff at the Doctors Hospital in Augusta, Georgia.

32. F.C. and his father arrived at the Doctors Hospital in Augusta at around

10:30PM and were told that F.C. would go into surgery in the morning around 8AM on

December 5th, 2012.

33. The surgery would entail wound cleaning, debriding, application of skin

grafts, and wrapping.

34. F.C.'s mother and grandfather arrived to the Doctors Hospital later that night.

35. At around 8:30 AM on December 6th, 2012 the surgeon's assistant, Brian

Shirley, entered F.C.'s hospital room to personally inspect F.C.'s wounds. Brian Shirley

acquired parental consent to perform surgery on F.C..

36. At around this same time Defendant Cartie had also entered the hospital room

and asserted that F.C. had not been vaccinated for tetanus and, "would now be now."

37. Plaintiffs refused to provide informed consent for the tetanus vaccination of

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their son to Defendant Cartie.

38. Defendant Cartie did not personally observe or examine F.C.'s injured feet.

39. Defendant Cartie failed to verify F.C.'s medical condition instead relying on

"reports" even though F.C. was within three feet of Defendant Cartie.

40. Defendant Cartie never demanded any other procedure be performed other

than tetanus vaccination.

41. A tetanus vaccine is not and can not be, under any circumstance, an

emergency medical intervention.

42. Defendant Cartie was frustrated by Plaintiffs steadfast insistence on

exercising their inalienable right to refuse the demanded tetanus vaccine for their son.

43. Due to defendant Cartie's abusive and bullying demeanor, Plaintiffs made it

known to medical staff that Defendant Cartie was "fired" insofar as being their son's

pediatrician.

44. Defendant Cartie became affronted when Plaintiffs "fired" him.

45. Defendant Cartie's wounded pride and frustration with Plaintiffs led him to

initiate a series of deceptions and brutal punishments directed at F.C. and his parents

(Plaintiffs).

46. Defendant Cartie, directly assisted by Defendant Donna Masters, ordered that

the scheduled wound cleaning and surgery be delayed until Plaintiffs consented to a

tetanus vaccine for F.C.. Said additional surgical delay was approximately four hours in

duration and had absolutely no medical basis whatsoever.

47. Defendant Cartie intended to punish and did punish Plaintiffs for invoking

their inalienable right to refuse his demanded an demonstrably unnecessary medical

intervention.

48. Due to Defendant Cartie's malicious order to delay medically necessary

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debriding and surgery, approximately 18 hours had passes since F.C.'s wounds had been

cleaned and dressed.

49. Of paramount importance, in suspected tetanus exposure cases, is the

requirement to immediately wash , debride, and wrap the wound to effect an aerobic

environment in which tetanus (Clostridium tetani ) can not survive or colonize to the

point of endangering the patient.

50. Action consistent with an honest concern about F.C. being exposed to tetanus

would be the immediate wound cleaning and debriding followed by skin grafts which

Defendant Cartie delayed an additional 4 hours in order to punish Plaintiffs and without

any medical justification for doing so.

51. Defendant Cartie's ordered “delay” ended when F.C. began to cry in

discomfort and his parents (Plaintiffs) became visibly and consistently agitated that their

son be seen to immediately.

52. F.C.'s father asked nurse Kathy Ecks why his son's surgery was being

delayed. Nurse Ecks indicated that it was due to the "vaccine issue".

53. Defendant Masters reported that the delay in surgery was due to another

surgery which was more exigent. However, both hospital staff and medical notes indicate

that the delay was ordered, with malicious intent, by Defendant Cartie.

54. Defendant Cartie ordered F.C.'s surgery to be delayed in order to

"encourage" Plaintiffs to consent to vaccinate.

55. At around 10 AM December 5th, 2012 Plaintiff (redacted father) met with

Defendant Chris Haga so that Defendant Haga could personally inspect Plaintiff''s

(redacted father) ID.

56. Plaintiff (redacted father) disallowed the copying of his ID citing that ID

theft is prevalent within medical institutions and that a copy of his ID would enable or

encourage the theft of his ID.

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57. Plaintiff (redacted father) allowed Defendant Haga to physically examine his

(redacted father) ID.

58. Defendant Haga never indicated any concern to Plaintiffs that the ID had

been anything other than authentic.

59. Plaintiffs were "self-pay" which prompted Defendant Haga to insist that

Plaintiff (redacted father) apply for Medicaid and sign another admissions document in

which no terms and conditions had been struck out.

60. Plaintiff (redacted father) had previously signed a Doctors Hospital

admissions document wherein he ((redacted father)) struck out several disagreeable terms

and conditions prior to signing.

61. During this brief meeting with Defendant Haga, Plaintiff (redacted father)

refused to apply for Medicaid or to sign admissions documents with disagreeable terms

and conditions.

62. At around noon on December 5th, 2012 it is believed that Defendant Cartie

collaborated with two Richmond County DFCS social workers, Defendants Jane Doe and

Janet Doe, to intimidate, harass, and threaten Plaintiffs. Defendants Jane Doe and Janet

Doe plainly asserted that Plaintiffs son could be taken into the care and keeping of the

Public Trust if Plaintiffs did not provide consent for the tetanus vaccine. Plaintiffs

maintained their position of non-consent for the tetanus vaccine despite the Richmond

County DFCS agents' hostilities and threats directed toward Plaintiffs.

63. Defendant Cartie and the hospital staff Defendants, by involving DFCS

employees to investigate without emergency medical justification, set into motion a

course of action he/they knew or reasonably should have known would result in the

violation of the Plaintiffs' Constitutional rights.

64. Defendants Cartie's and Master's hospital notes indicate paranoid ideations to

justify the inhumane treatment of Plaintiffs. Defendant Cartie's notes fail to mention

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exculpatory evidence (to negate such imaginings and ideations) including the obvious fact

that Plaintiff (redacted mother) was breastfeeding F.C. and was accompanied by her father

while at the Doctors Hospital. Dr. Cartie's reports were demonstrably created in bad faith.

65. Plaintiffs asked Defendant Donna Masters to contact the Doctors Hospital

CEO, (Doug Welch). Defendant Masters indicated that the CEO would be in touch with

them "today or tomorrow".

66. Doctors Hospital CEO Doug Welch was never heard from or seen by

Plaintiffs.

67. Then, based on information and belief, Defendant Cartie, working in concert

with Defendants Chris Haga, James Cole, Donna Masters, and Heyward Wells employed

Richmond County Sheriff Deputy Wren to intimidate and interrogate Plaintiffs under the

pretext that an ID card had been “reported” as appearing to have been tampered with or

altered.

68. The only person to have seen Plaintiff (redacted father) ID prior to Defendant

Wren was the Doctors Hospital admissions director Defendant Chris Haga.

69. Defendant Cartie's summoning of a Deputy Sheriff and the Defendants Jane

and Janet Doe, further evidences "bad faith" reporting by Defendant Cartie in order to

impose his will, via state actors, on the Plaintiffs.

70. These several intimidation tactics failed to result in Plaintiffs' consent to

vaccinate.

71. Evidence indicates that Defendant Cartie then proceeded to consult and plan

with Macon County DFCS supervisor, Defendant Karan Albritton, to take custody of not

just one but all three (according to Defendant Cartie's hospital notes) of Plaintiffs' sons.

72. On or around 8PM on December 5th, 2012 Defendant Julie Lewis entered

Plaintiffs' hospital room accompanied by armed guards including Defendant Jimmy Wren

to announce that F.C. would now be vaccinated. Plaintiffs again refused to consent to the

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tetanus vaccination.

73. Defendant Lewis asserted to the Plaintiffs that the vaccination was court

ordered and, as if a state actor, she served the so-called court order (Exhibit A) to

Plaintiffs.

74. Plaintiffs were in absolute shock that events were unfolding as they were.

75. Plaintiffs were sleep deprived in addition to being perpetually, harassed,

terrorized, and their concerns ignored by hospital staff and state actors throughout the day.

76. Plaintiffs were completely aware that their rights were being violated at the

time they were being violated and noticed (verbally) Defendants Lewis, Wren, and others

that their (Plaintiffs') rights were being violated and their (Defendants) actions were

"wrong".

77. The court order titled, "ORDER FOR SHELTER CARE" (Exhibit A) stated ,

"The medical staff explained the significance of the shots and father refused the shots for

the child therefore putting the child's life, possibly, in danger."

78. The mere possibility of danger does not constitute an emergency or exigent

circumstance that would justify the seizure of F.C. or any other human being.

79. At no time did any of the medical staff verbally convey any information,

positive or negative, regarding the tetanus vaccine to the Plaintiffs.

80. Defendant Cartie, at no time, provided any information, significant or

otherwise about the tetanus toxoid ( DT vaccine).

81. The so-called "ORDER FOR SHELTER CARE" contained no language to

indicate probable cause or that exigent circumstance existed to justify the seizure of F.C.

Said order was authorized by Defendant Lisa Coogle Rambo and prepared by Defendant

Patrick Eidson.

82. Defendants Lisa Rambo's and Eidson's "ORDER FOR SHELTER CARE"

was not supported by Oath or affirmation as is mandated by the Fourth Amendment.

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83. Defendant Lisa Rambo, asserting herself to be a Judge, is expressly required

at Article VI (Supremacy clause) of the Constitution to support the Fourth Amendment.

84. Defendant Lewis indicated to Plaintiffs that they may leave the Doctors

Hospital without their son or they could stay with F.C. as long as they did not attempt to

flee the Doctors Hospital with F.C.

85. Defendant Lewis advised Plaintiffs to abandon their son F.C. to her and other

hospital staff.

86. Plaintiffs refused to abandon their injured and traumatized son.

87. Defendants Lewis and Cartie, being a nurse and medical doctor, respectively,

knew or should have reasonably known that refusal to vaccinate did not and could not

have caused F.C. to be in imminent danger regarding the instant matter.

88. At no time did any of the named Defendants assert to Plaintiffs, by word or

action, that failure to consent to a tetanus vaccine or failure to receive a tetanus vaccine

presented an imminent danger or exigent circumstance regarding F.C..

89. Medical staff Defendants could not impose their will upon Plaintiffs without

armed state actors presenting the threat of armed and lethal force to Plaintiffs.

90. Defendant Lewis demanded F.C. be taken to another room to be forced

vaccinated. Under threat of lethal force and by threat of being separated, via force, from

their son, Plaintiffs complied, under duress, and proceeded down the hall to what

appeared to be a storage room.

91. Defendant Terrell Yelverton prepared to administer the vaccine while

Defendant Lewis and Defendant Wren looked on.

92. Defendant Yelverton became confused by the court order (Exhibit A) and left

the room for some 25 minutes at which time he returned and injected F.C. with two

substances: TIG and DT. These were administered bi-latterly amidst intense screaming

and crying from F.C. while Plaintiffs attempted to console their son.

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93. According to the manufacturer of the TIG, "Pediatric Use: Safety and

effectiveness in the pediatric population have not been established."

94. After F.C. received the forced medical intervention, armed guards were

posted near the Plaintiffs' room and at the exits for the rest of the night and the next day

creating a veritable prison for the Plaintiffs.

95. Plaintiffs' later research indicated that the unwanted and forced medical

intervention contained neurotoxins and ototoxins none of which were disclosed to

Plaintiffs by Defendant Cartie or any other of the medical staff..

96. F.C. was later diagnosed with a hearing loss and, to this day, is severely

delayed in his ability to speak .

97. On December 6th, 2012 at around 1PM Plaintiffs son was seized by

Defendants Albritton and Barr, armed guards looking on, and taken to an unknown

location.

98. As Plaintiffs left the Hospital room Plaintiffs observed Defendant Masters

and another nurse crying.

99. Emotionally distraught Plaintiff Sharon Cross asked visibly distraught and

crying Defendant Masters, “Are you happy now?”. Defendant Masters responded, “No.”

100. Defendant James Cole then escorted Plaintiffs and F.C.'s grandfather out of

the Doctors Hospital at which time Plaintiffs traveled home without their son and without

knowledge of their son's condition or location. As Defendant Cole escorted Plaintiffs

from the Doctors Hospital to the parking lot he indicated that he regretted that this had

happened to Plaintiffs and that he felt it was “wrong.”

101. Defendants' son had never long been without his mother or father and was

now deprived of both, deprived of his mother's nourishment in the form of breast milk

and emotional support. This deprivation of their rights to familial association during a

traumatic time (post burn recovery) when F.C. most required his parents' and familial

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support.

102. On December 7th 2012 Plaintiffs visited their son at the Macon County

DFCS in Oglethorpe, Georgia.

103. At this time Defendant Susan Barr entered into negotiations to have

Plaintiffs' son returned. One of the conditions of return was for Defendant Barr to be

allowed to enter and search Plaintiffs' domicile prior to returning F.C. to his parents.

104. Under duress, Plaintiffs agreed to allow Defendant Barr to enter and walk

through the Plaintiffs' domicile located in Macon County, Georgia.

105. During this unreasonable search Defendant Barr requested to speak with

Plaintiffs' sons R.C. and D.C. without Plaintiffs present.

106. Under duress Plaintiffs allowed Defendant Barr to interrogate minors R.C.

and D.C.

107. An interrogation of a minor by a state actor without parents' freely given

consent, without probable cause, and without an exigent circumstance is an unreasonable

seizure under the Fourth Amendment.

108. Defendant Barr unreasonably seized Plaintiffs' two older sons, R.C. and

D.C., so as to interrogate them.

109. On December 7th, 2012 approximately 27 hours after F.C. was unlawfully

seized from Plaintiffs, F.C. was returned to his grandparents by an unidentified DFCS

employee.

110. While briefly in government custody F.C. was neglected by Defendants

Albritton and Barr resulting in his wrist being injured causing him great discomfort and

mental anguish. A police report was made about this injury.

111. Upon hearing about Plaintiffs' son being unreasonably seized, another

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medical doctor (a practicing surgeon) submitted a formal complaint against Defendant

Cartie citing Cartie's "abuse of power" to the the Georgia Medical Board. Furthermore,

said complaint indicated, “Necessary surgery was delayed for a tetanus vaccine – which

is not an acutely necessary medical treatment.”

112. Seeking to reacquire their son, Plaintiffs , on December 10th, 2012, attended

a hearing in which Defendant Lisa Rambo and Defendant James Hurt decided to allow

plaintiffs' son to go back home to his family under the condition that Plaintiffs contract

for 12 months of "services" from DFCS or the so-called "DEPARTMENT.”

113. Defendant James Hurt "prepared a "72 HOUR HEARING

ORDER/PROTECTIVE ORDER" at Exhibit B. Defendants Lisa Rambo authorized and

made operative, under color of law, this so-called "Protective Order" with her signature.

114. On page two of the "72 HOUR HEARING ORDER/PROTECTIVE

ORDER" are printed the following five actual threats to unreasonably seize F.C. :

A) The parents are to successfully complete parenting classes and immunization

education. Any deviation will result in the child being taken into emergency

custody, and the non-complying parent will be subject to civil contempt.

B) Comply with all home schooling regulations required by the Macon County

Board of education. Any deviation will result in the child being taken into

emergency custody, and the non-complying parent will be subject to civil

contempt.

C) Ensure child receives all medical attention recommended by any medical

provider. Any deviation will result in the child being taken into emergency

custody, and the non-complying parent will be subject to civil contempt.

D) Sign any releases for information requested by the Department. Any deviation

will result in the child being taken into emergency custody, and the non-

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complying parent will be subject to civil contempt.

E) Cooperate with DFCS and any related agencies. Any deviation will result in the

child being taken into emergency custody, and the non-complying parent will be

subject to civil contempt.

115. Threats A Through E, if carried out, would be unreasonable seizures in

violation of the law as expressed at the Fourth and Fifth Amendments.

116. Under duress, coercion, and Defendants Rambo's and Hurt's threats to

unreasonably seize their son, Plaintiffs agreed to do as they were directed by Defendants

Lisa Rambo and James Hurt.

117. The "72 HOUR HEARING ORDER/PROTECTIVE ORDER" evidences

that the law as it is expressed at the Fourth and Fifth Amendments are of no import to

Defendants Lisa Rambo and James Hurt.

118. Given that their son was neglected and injured while briefly in the care and

keeping of the Public Trust, Plaintiffs had the reasonable expectation that F.C. could again

be harmed or even killed if again taken by these negligent state actors.

119. Plaintiffs were coerced into signing the so-called “Family Plan” document

thus contracting, under duress , with DFCS. Said document was not willingly agreed to

or willingly signed by Plaintiffs. Said document is, essentially, an unconscionable

contract.

120. Exhibit C is a partial transcript of the coerced meeting Plaintiffs had with

DFCS and CASA Defendant Estella Lusane regarding the so-called “family plan”. This

”family meeting" with DFCS was not voluntary. Plaintiffs clearly stated to Defendants,

Lusane and Albritton, that their rights were and continue to be violated and that they

(Plaintiffs) were threatened that their non-cooperation would result in their son being

seized, whereafter he could, again, be harmed or possibly killed. Plaintiffs showed video

and pictures of F.C's injured wrist to Defendants Albritton and Lusane.

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121. At no time did Plaintiffs ever sign a document or agree to any demands

made by any of the named state actors of their own free will.

122. Defendants Lisa Rambo, Edna Messer, Estella Lusane, and Stacee Fussell,

by way of the document, "Appointment of Court Appointed Special Advocate" or

“CASA” (Exhibit D) deprived plaintiffs of their Fourth Amendment rights to be secure in

their private medical documents. Plaintiffs' Fifth Amendment rights were also violated

insofar as any possible incriminating elements those unreasonably seized documents may

have provided to the Defendants.

123. Said “CASA” document was specifically used by Defendants as if it were a

subpoena or warrant.

124. Defendant Messer has refused to explain to Plaintiffs exactly why she

allowed private medical records to be conveyed to state actors Rambo, Lusane, and

Fussell.

125. The "CASA" document , the "ORDER FOR PROTECTIVE CARE"

document, and the "72 HOUR PROTECTIVE ORDER" documents evidence extreme

disregard for restrictions on state actors as provided by the Fourth Amendment.

126. Aforementioned documents authorized by Defendant Lisa Rambo evidences

absolute disobedience to the Constitution directly resulting in its beneficiaries, the

Plaintiffs, being deprived of their rights.

127. Plaintiffs have written letters to several of the state actor Defendants

noticing them of specific Amendments which they (Defendants) are violating in addition

to Article VI of our Constitution. Said state actors responded to Plaintiffs' claims of duress

and rights violations with more rights violations and perpetually threatening to

unreasonably seize Plaintiffs' son for non-compliance with the so-called court order.

128. On several occasions Plaintiffs contacted (in writing) multiple employees of

19

Doctors Hospital to inquire as to how and to whom complaints are made to the hospital

regarding abusive treatment.

129. Employees contacted include Defendants Foster and Masters. Also

contacted was Doctors Hospital chief of security and Defendant James Cole. All three of

the aforementioned Defendants refused to answer Plaintiffs' questions as to how to make

a formal complaint to the hospital.

130. Also contacted (in writing) was Ellen Hintz who is employed by HCA

(HCA allegedly owns Doctors Hospital) as an ethics compliance officer. Plaintiffs asked

Ms. Hinz how to file a formal complaint regarding the abuses suffered within Doctors

Hospital. Ms. Hinz refused to answer Plaintiff's questions.

131. Exhibit E is titled, "What Hospitals Are Doing To Keep Their facilities

Safe" and was written a few months prior to the unreasonable seizure of F.C..

132. According to this article Defendant Cole asserts that he makes training a top

priority while Johnny Meiles asserts that his hospital has a policy or procedure in place

for any "security" event.

133. Both Mieles and Cole indicated, "how they work closely with the Richmond

County Sheriffs Office."

134 . The Doctors Hospital of Augusta has in place a formal or informal policy or

custom of working with state actors resulting in the deprivation of Plaintiffs' rights.

135. Plaintiffs made it abundantly clear, both verbally and in writing, to the

Doctors Hospital and its staff that no private medical information was to shared with

anyone including Medicaid.

136. Defendants DOCTORS HOSPITAL and the named medical staff

Defendants were fully aware that F.C. would receive Medicaid benefits if F.C. was seized

by state actors and that Plaintiffs' private medical information would be made available to

Medicaid.

20

137. Defendant Barr or someone within DFCS, without Plaintiffs' consent and

after F.C.'s unreasonable seizure, activated Medicaid for F.C. retroactive to December

1st, 2012.

138. On January 21st, 2013 Defendant Dr. Cartie shared Plaintiffs' private

medical data with a third party by billing Medicaid $356. Medicaid paid Dr. Cartie

$132.67.

139. On February 2nd, 2013 Defendant Cartie's co-worker by the name of Eric E.

Newman shared Plaintiffs' private medical data with a third party by billing Medicaid for

$75 and received $17.78.

140. Eric E. Newman was also specifically restricted by Plaintiffs from sharing

any information with Medicaid.

141. These egregious acts by Defendant Cartie and his co-worker, Eric Newman,

of sharing private medical information with Medicaid, after being forbidden by Plaintiffs

to do so, again indicates a pervasive and institutional-wide indifference to the

Constitutionally secured rights of Plaintiffs.

First Cause of Action

Unreasonable Seizure and False Imprisonment

in Violation of the Fourth Amendment to the U.S. Constitution

(42 U.S.C. §1983 Claim)

142. Plaintiffs re-allege and incorporate by references all allegations set forth in

the paragraphs above as if set out fully herein.

143. Defendants Richard Cartie, Heyward Wells, James Cole, Thomas Dorn,

Trisha Foster, Chris Haga, Donna Masters, Terrell Yelverton, and Julie Lewis worked

collaboratively and in concert with state actors and Defendants Lisa Rambo, Patrick

Eidson, Karan Albritton, Susan Barr, Jimmy Wren, Jane Doe, and Janet Doe, under color

of law, to deprive Plaintiff's of their right to be free from unreasonable seizures without

probable cause, without a de jure warrant, without exigent circumstances, without

21

parental consent , and by threat of force of arms. Defendants Richard Cartie, Heyward

Wells, James Cole, Thomas Dorn, Trisha Foster, Chris Haga, Donna Masters, Terrell

Yelverton, and Julie Lewis worked collaboratively and in concert with state actor Jimmy

Wren, under color of law, to falsely imprison F.C. and his parents within the Doctors

Hospital of Augusta, Georgia.

144. Aforementioned Defendants violated clearly established Constitutional

rights of which a reasonable person in their positions knew or should have known.

Second Cause of Action

Unreasonable Seizure and Search of Private "papers" in Violation of the

Fourth Amendments to the U.S. Constitution

(42 U.S.C. §1983 Claim)

145. Plaintiffs re-allege and incorporate by references all allegations set forth in

the paragraphs above as if set out fully herein.

146. Defendants Lisa Rambo, Estella Lusane, Stacee Fussell, and Edna Messer

acting in concert and in such respective official capacities, not only failed to perform

primary and superseding obligation (to protect Plaintiffs' and F.C.'s rights) to Plaintiffs

but manifestly acted contrary to said protective requirement and with willful intent to

deprive Plaintiffs of their rights. Said Defendants willingly and knowingly made

operative a "CASA" document (Exhibit D) resulting in Plaintiffs being deprived of their

Fourth and Fifth Amendment rights.

147. Defendant Edna Messer was a willful participant engaged in joint action

with state actors in effecting the deprivation of Plaintiffs' rights. Defendants violated

clearly established Constitutional rights of which a reasonable person in their positions

knew or should have known.

22

Third Cause of Action

Deprivation of Due Process in Violation of

the Fifth Amendment to the U.S. Constitution

(42 U.S.C. §1983 Claim)

148. Plaintiffs re-allege and incorporate by references all allegations set

forth in the paragraphs above as if set out fully herein.

149. Defendants Richard Cartie, Heyward Wells, James Cole, Thomas Dorn,

Trisha Foster, Chris Haga, Donna Masters, Terrell Yelverton, Julie Lewis, Edna Messer,

Lisa Rambo, Patrick Eidson, James Hurt, Karan Albritton, Susan Barr, Jimmy Wren, Jane

Doe, Janet Doe, Stacee Fussell, Estella Lusane, and the Doctors Hospital, under color of

law, deprived Plaintiffs of their due process rights expressed and guaranteed at the Fifth

Amendment. Defendants violated clearly established Constitutional rights of which a

reasonable person in their positions knew or should have known.

Fourth Cause of Action

Deprivation of Due Process in Violation of

the Fifth Amendment to the U.S. Constitution

(42 U.S.C. §1983 Claim)

150. Plaintiffs re-allege and incorporate by references all allegations set forth in

the paragraphs above as if set out fully herein.

151. After unreasonably seizing F.C., Defendants Albritton and Barr neglected to

remove the Doctors Hospital I.D. bracelet from F.C.'s wrist. The bracelet, fitting too

tightly, girded the complete circumference of F.C.'s wrist causing substantial pain,

discomfort, and anxiety for him. Therefore, Defendants Albritton and Barr, while acting

under color of law, deprived F.C. of his due process rights to personal security and bodily

integrity.

23

Fifth Cause of Action

Unreasonable Search of Plaintiffs' home and unreasonable

seizure of Plaintiffs' two eldest sons in Violation of the

Fourth Amendments to the U.S. Constitution

(42 U.S.C. §1983 Claim)

152. Plaintiffs re-allege and incorporate by references all allegations set forth in

the paragraphs above as if set out fully herein.

153. Defendant Barr unreasonably searched Plaintiffs' domicile and seized

Plaintiffs' eldest sons, R.C. and D.C., in violation of the Fourth Amendment.

154. Defendant Barr entered the Plaintiffs home without a warrant, without

Plaintiffs' voluntary consent, and without any evidence of exigent circumstance to justify

said "search". 155. Defendant Barr, by way of coerced consent , entered Plaintiffs'

home and interviewed Plaintiffs' sons without parents present and without freely given

parental consent.

156. The interrogation of both Plaintiffs' sons by Defendant Barr was an

unreasonable seizure of both sons. Defendant Barr's entering of plaintiffs' domicile was

an unreasonable search.

Sixth Cause of Action

Unreasonable Seizure of Plaintiffs' son, F.C., in Violation of the

Fourth and Fifth Amendments to the U.S. Constitution

(42 U.S.C. §1983 Claim)

157. Defendant DOCTORS HOSPITAL of AUGUSTA , LLC is animated by

natural persons demonstrating an informal policy or custom which resulted in depriving

Plaintiffs of their Fourth and Fifth Amendment rights to not be unreasonably seized.

158. Defendant DOCTORS HOSPITAL of AUGUSTA, LLC consulted and

collaborated with state actors to unreasonably seize and falsely imprison F.C. and both of

24

his parents without probable cause, without exigent circumstance, and without parental

consent.

159. Defendant DOCTORS HOSPITAL of AUGUSTA, LLC is a state created

statutory fiction, animated by, among others, state licensed attorneys, and receives public

monies by way of Medicaid and Medicare. However, said Defendant is not a state actor

insofar as being authorized to exercise public trust powers.

160. DOCTORS HOSPITAL of AUGUSTA, LLC (more accurately, the natural

persons animating said LLC) must request or enable state actors to intervene on

Defendant's behalf to impose Defendant's will through state actors, under the color of law

presumption, to deprive Plaintiffs of their rights.

161. Defendant DOCTORS HOSPITAL of AUGUSTA, LLC utilizes an

informal custom, in direct conflict with its own corporate policy, setting into motion or

enabling to be set into motion events knowingly intended to deprive Plaintiffs of their

inalienable rights via its bad faith and improper utilization of the Richmond County

Office of the Sheriff , Richmond County DFCS, and Macon County DFCS.

Damages

Defendants acting in concert and without warrant, probable cause, exigent

circumstances, or parental consent:

a. breached the domestic tranquility of Plaintiffs' family, friends, community and

the security thereof – resulting in hurtful and excessive distress, aggravation and anguish.

b. caused Plaintiffs to suffer from excessive and unwarranted diminution of both

their reputations and enjoyment of their lives.

c. caused physical injury to F.C.'s arm while in the care and keeping of the Public

Trust.

d. caused Plaintiffs to suffer debilitating trepidation insofar as interacting with

25

pediatricians, nurses, hospitals, and private medical practices. Trepidation based upon the

reasonable expectation that said interactions may result in Plaintiffs' sons being, again,

unreasonable seized, neglected, harmed, or killed while in the care and keeping of the

Public Trust.

Prayer for Relief

Wherefore, the Plaintiffs respectfully request that this Court to:

1. Declare that the actions of Defendants violated the Plaintiffs' rights certain of

which are expressed and guaranteed withing the U.S. Constitution;

2. Find that the Defendants intentionally and unlawfully violated the Plaintiffs'

inalienable rights certain of which are expressed and guaranteed within and by the

Constitution;

3. For general and special damages according to proof at the time of trial;

4. For costs of suit and interest incurred herein;

5. For punitive damages for Defendants' conduct in willful and wanton disregard

for the rights of the Plaintiffs;

6. Any further injunctive or declaratory relief this court deems just and proper;

7. Award monetary damages payable to Plaintiffs in Constitutional lawful money

gold and / or silver coin as expressed in Article I Section 10 of the Constitution;

8. That Plaintiffs' demands for all issues to be decided by the Jury demanded;

9. If Defendants move to dismiss this suit then Plaintiffs demand this case to be

heard by the Jury demanded and only dismissed if the Jury considers this case to be

lacking in merit.

26

Dated this 7th day of January, 2014,

Respectfully submitted,

(redacted father) , MBA(redacted mother), PsyD. P.O. Box 311Ideal, Georgia 31041Phone: (redacted)Email: section1983suit@gmail.com

Plaintiffs (propria persona)

27

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P*Fqrjr--1tji

onDsmnnAo*im*o*s g+*.*ras haa*r ' ,nl!

bw*r-,^l*Exhibit A

JlffiE,rliciFFt't|confurdill|FtCxrrt

({l6l0flfitr t(xltttllotyd |0.(ia r.rr:1

Exhibi t B

/6t0tnffi$rstF[pilONYOF,

INTTIBJUVENII,E COURT OFSTATEOF "^ 14lar*-

IN TIIE TNTERBSTOF:

FEIFCRO$S SEX: MALE

Child Under the Age of l8

DOB: il29l2010 CASE# 09+IU-VI9

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

Thc sbove and foregoing m*Hr is bofolt the Court for a 72 Hour

upon tr (Conplaint[Pctition) filod by thc Georgia neeartnent of Human

ond tbrrouglr tbs lvlacm Counry DFAC$ allqlng tlc above nsned child to be

IfrEscnt in / for Court werc:

( ) child:

0O Motun SHARONHARVBY

(X) LsgslFsthr: DANCROSS

( ) Attomcy:

( ) Attomey:

(X) DFC$: KARm.l ALBRITTON & SUSAN BARR

il CASA:

Jamer W.

Bascd qon tbc cnidme pruembd [or consent of the prentis)], the

tblt tltcrc ir probable carsc to bcliovo thc abovo nrm6d child is depdved

O.C.O.A. Soction 15.11-2(tXA): Thc child was bsrn in wudodq h tb€

her rnaidm narnc. The prnots uo mnrricd urd togdttr. Thc child uras bruncd,

doctor ar the Augrutr Bum Clinic odvired thal tlu chitd needed a ffianu

woold havc n 25% chance of death if he rcceivsd tstmrg fto,m his wounds.

r+lould aot eoffcnt

Nciths tlis child nor his riblirgr have e\rcr rtccivcd imruurizatlons.

Thc uhil&tn sre hornc-dcboolod but not in complianoe $th the Macon

Boad of Educdion rquircmonts.

Exhibit B

Continuation in the porot's crr$ody wilhout idenrentim to have the

imrnrmization wE lrot hhls best inH'est

fhc ffepartnent sougtrt a Protectivc Order in liar of seeking custody

hearhU,

TI-IBREFORE IT IS THE ORDER OF THE COURT that custody is

restorcd to thE purtnb wirh opervirion by ttrc Dedarhnefit to ensure the

requirumerns are met:

The patmts eie to:

r Succqsfully complae Pailnting clascs and imrnunizntion educati. conply with 8ll honns echooting regulsdon$ Ioquircd by thc

County Bosrd of Educdionr &rnue ssid child reccivec alt mcdicsl ctentistl rscommcnded

rncdicsl provide,r. slgn any nclcreoo for futronnalion roquostod by the Doportmentr Coopcrau wi& DFCS nnd any rcktod agwies

Any deviation will resuh in thc child boing talrm into cmcrgency cusody,

non-complyitrg parent will bc subject to civil conternpt-

The Macon County ttopamcnt of Family snd children scrvic€s msdc

cffons to prescrvc snl repiry &c &mily PrlG to tbc placement of tfte ohild

cBne, lo p,rcryent or climin*c thc nFal fDr tbc rennoval of tbc child from the

make it posslblc for tbp child to rthm re&ly home.

IT Is SO ORDERED this

10.201?.

f day ofJnnuary 2013, nunc Pm hrnc

lnbeT'Kn*h"

LiasC. RmboIudgeof JwmileCowtMacon Cotmty, Georgn

"1

I - : - .

Exhibit B

F . ' . -

:i:j

g

onOrr prceareif UYIJamcs W. Htntcts#380100

Fltwpwin\DFCSrnracon 2012\Flint cros t2-2E0\?2 hour hcaring order 10- 19-l

Re: Unlswful Macon County , Georgia DFCS "Family Meeting" on February ,lth, 20l i

l)articipanls:rcdacted fatherrcdacted ntotherrcr,lacted g randf atherKlran , \ lhr i tont'r'rrthia lv{artinilcvcrlv I' larrisi : i i r r l la l , t tsant:

I)lrtial lranscription of this coerced meeting's audio recording:

Exhibit C

i\ ls. llarris: Can you briefly kind of tell the team how DFCS got involved rvith you all?\{other: I teel like my rights werc violated. I f-eel like my son's rights were violated. I contilrr:r,. i 'thal wa,v. \l'b drd havc Flint rcturnecl to us irnd now we are under the court ordc.r. We are here, \\, ,lundcr cturess. We are doing this because wc har,'e the threat of our child heing taketr from us ul irrr,,time. We are cooperating, complying with the court order. .lust want to get our family back tog:"ttr,our norrnal simple life with no intervcntion from an_vhody.

Fathcr: (.oulcl I add to that?

lleverlv: You can.

l a t h e r : l ; i r s t a n d f i r r e m o s t l r v a n t l o m a k e a b s o l u t e l y c l e a r t h a t w e d o i n t e n d t o l u l l y c o m p l v u r t l r ' 1i l t i cc . l i ru r " l ' j rebu l le tpo in tso f thecour to rder . I t saysbe lowthef ivebu l le tpo in ts :An1 'dev ia l i , ' r , . . ,t 'r:sull in llte child being taken into emergency custody and the non-cromply-ing parent will be quh'tc, ;r'r\ rl c()ntempt. So it is pretty plain, in mv opinion ,that we've gotta do all five things and wcrc p:uiri:,iri 11 11pilg1 durcss because wc arc) being coerced to do it. \fu'hen I say duress. Mother and I hav,: rr , ,l l ' lt l (rrlttcerlt that our child rvill be taken away from us if we do not atlend rneetings and sign d{rt.nr,,, ,lhirt arc put irr front of us. lVe v,ill sign documents and attend meetings, whatever lhe court tlqt,i:',.l:CL+: l:u!_:ts_a!_<_d!!-ing_i!-UAdeLd!.!'ess hec,ture

",e /bel efuld wilt he harmed f not .fu": t:tttt.tttt-trltlLutltuJ:lclt I r.vanted to sharc something rvith lou. \lfti lc Flint was in foster cust(,,1, I'rrrl tl lrtttagt:d he r.vas infured. \\truld 1'ou like to sec: evidence of that?

i )l ( S. ct alia: No response and no indication of interest to learn about Flint beins hanned.

Father: I would like to show.vou wlmt happened to his arm.

l"athcr: ' lhc rcason I am sl torving \r lu this is becausc ir gives us the reascrnable e.xpectat ion thi l l r t ,is takcn fiont us he vvill be harmed{5iror. l 'cr l v idco and pics of Fl i rr t 's arm ro al l . )

Father: lt concems us that this has never been brouglrt up...

Kilran: Well that is thc first timc I have seen that or heard of that.

Notc: \!'r never heard mention of thrs incident again irom anyone.

IN THE JWENIIT, COUNT OF lUE ff)TITEWT^STERNJTDICIALINTEN COUNTY OT MACON

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

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

D9B:aEngil0

APPOIITTME.NT OT COURr APFOINTAD SPECIAL ADVOCAM

The cnurt hercby rypoinrr Esrclla Lusane ald cAsA sffi ss the courtspeciel Advocaie (cAsA) for tue abovo named dnor drild(rm) in thb caurgto O.C-G.A. Sectiorr 1.5-l t -9. It i8 nrilcr orrdcrcd th:

l. tJpn prcsentathn of this Gder, any agcnoy, ho$pital, school, orgdivisicur, or department of fre strb, doctor, nurso, ointhcr hsolth carct{fln€r't &cility, psychologi$, psych'rstrist, policc deporfncn! or mentalclinic gtnll peirrit tho cASA who preents thi$ ore b inspecr and corcqnnd-s or reporb rclatlng to thc child aador thc cbild's prnsng,pmtected tpalth informcion, withorr consmt be the child or the child's

2. The CASA assigned for {rc child(rcn) shall mlintEin any isfi}rmdionfrom any source as cmfidcntiaf d wilt not disclose srrcn iorormstiottoral or $ritbn rcports t0 &c coort and as directed by the court to otberthis pnoccoding.

3. Thc cAsA shEll b€ notifiod of my hoaring; shffing investigations, <lcpappeals' or orher puuodings oowning the child, and snll-be notifiedany action taksn on behalfof tic chlld by my pdty.

4' The cASA shau appear ar dl court or child wetFare hcarings or prccsrelcing to tre child ud rupresent the child's best intsrast ut *io hearingssth€flr'i$e eirderod by thc Court

5. 'fhis order shell rc{nain in frril frrrcc and effect until futhcr order of the

unlcss oth€revisc ordcrcd by thc coufl" thfu o/nd€r shalr tcrminatcany child uiho has rqched age lB, for any child foil qaom m order ofhar treen granted, or for any child rryboce parrunett legal custody or guais granted by this Coun to the ctild's parent, relsti\,s, G other adultthe C-rxnt

v6d

t i ns to

for

T Is so gRpqp ra,, ftFory os DWzs-1\

^fubKo"J)-t,iss C. Rambo, JudgeJuvenile court of tti southwestcm

"r*ml[ BllDAY

,/1.'s3

ile'f - ir{,OF.4e.cn* OOLhITY,

Exhibit D

", ir;rr f iospital-< Are Doing To Keep Their Facil it ies Safe - NBC 26 -... h[p:iiwww.nbc26.N I storyl2 | 73 836 I lwhat-hospiul

What Hoepitals Ar€ Doing To Keep Thrir Facilities SafcF o ' / € d M 1 7 . 2 0 1 2 6 1 6 P $ F S T

0y Jmalhan Dsvis

ll mly lakos a sedd for hagedy lo slrik€ ju3t lik8 lhe shootino that t@k ple on Tucdsy al Univcr3ityHosprta! .iohnrry Melles th€ Directo. of SKufty at Univtrsity h@pital tells re thev ksp a tight watch mpeople comino in and oul ot th€ hospital 6nd whai's going m lnside. He $ys thcre 6re proedures In place intlE event ot a searity enErg€ncy. lik6 Trc|day'! 3hmt|ng.

' I hs osngral public ahould raalia trlat ws del wilh emroscirs 6vcryday we trsin annually s any klnd ot

ev6nt thal you cn think cl. vve have polides md pmcedures in plae. And any ev6nt that takes plsce wepDbably h8ve swthing in drca to hedlo thst." sid M€llos

Molle$ says lhat 6ach s$Urily olllctr oo the uniwrslty's €fipus ls amd 6nd trsined lo use the,r werpon. Flesays tr€ining 16 ssious busilress lf offtcers don't 9q, e lri0h elough on the $hootiog t€st, they cs lrie their

Job Mellft aleo says evon und6r a tighl watci, th€re is no way to se €vorything at 6ll tire$ and 3lill.UnNffiW ls ssfe plac6

'll's almsl physicslly inrpos8rble wilh arry facility at f|is size lo checl everybody al every door I don't knw anyhGpital in this area or rn Gesgla thal have nEdi.;l deteclors 6t every Ehgla dod that you cm in I Ju3t wantlo lel you. and assure our sttt . pattsts, 8nd th€ CSRA thal you 6re a3 ssto as you willd be at any olheflarlitv rn the CSRA.' ssd Moies

Ch€f Jeres Cole at Doctors tlosp(al agrees

"Jusl likc msl hospilsls lhol don'l havc that EUs€ s(ml'lino lite thjr en happen an!ryhere. wtlether il tts al6 hogpltator ml l d. anwhere els€.

Cole sys he rukss trarnrng 8lop pr ionty. 'srd Cole.

''Wo hat/€ our ofiEers go through irarnlrq where lhey cen identify pos3ible hidden weap69 on s Individual

,And we 6end them on that lrarf,rng onc€ o year on@ every six trDnlhs. Just lo Inow {hal to be of the l@koulfo(. Th€ fiBnnensryE ild also wdh cooealed weapons " sard Cole,

Both Hogprtals dld want lo stEsg lhot thrs vras an rsot6ted inodent sd that thsy {m @\md {or any event thal$iddd ffiUr Thay also siared h@ lhey wofk closoly wrth lh€ Rrc'l|]6d Crunty Shdfts otrrc€

Exhibit E