IN THE SUPERIOR COURT

OF DEKALB COUNTY
GEORGIA
ANTHONY S. TRICOLI,
Plaintiff,
vs.
ROB WATTS; RON CARRUTH; JIM
RASMUS; MARK GERSPACHER;
SHELETHA CHAMPION; HENRY
HUCKABY; JOHN FUCHKO; STEVE
WRIGLEY; BEN TARBUTTON; THE BOARD
OF REGENTS OF THE UNIVERSITY
SYSTEM OF GEORGIA; SAM OLENS, THE
ATTORNEY GENERAL OF GEORGIA; and
ROBIN JENKINS
Defendants.

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CIVIL ACTION NO. 14-CV-4911

JURY TRIAL DEMANDED

MOTION FOR STAY OF ORDER GRANTING DISMISSAL AND

ORDER LIFTING STAY OF DISCOVERY

Comes now Plaintiff Anthony Tricoli pursuant to OCGA 9-11-15

& 16-14-6(a)(3), and the Motion for Interlocutory Injunction and

Amended Verified Complaint not addressed by Court, and the Open
Records requests not answered by Defendants, moves for a Stay of the
Order Granting Dismissal subject to resolution of the pending
unaddressed factual and legal issues, including but not limited to
Plaintiffs amendments, and shows the Court as follows:

In its Order Granting Dismissal (the Order), the Court purported

to dismiss Plaintiffs entire RICO action as well as the additional claims

for fraud and breach of contractin the course of which over $9 million
in federal and state agency funds has gone missing, as admitted by the
USG Defendants. However, that Order does not address either the
grounds for injunctive relief filed prior to the Order or the amended
claims related to Defendants continuing Georgia RICO predicate acts
and efforts to conceal multiple breaches of Anthony Tricolis
employment contract.

Issues raised by the Motion for Interlocutory Injunction (the

Motion) and the supporting Amended Verified Complaint that are not
addressed in the Order of dismissal--signed the same day the Motion
was filed--include admissions that Defendants committed the criminal,
knowing falsifications of state agency reports alleged in the Complaint
in which over $9 million disappeared. The overlooked issues also
include admissions that Defendants altered USG policies to conceal the
criminal RICO violations as well as breaches of both USG policy and
Tricolis contract that occurred before his coerced resignation. In
addition, Defendants have not responded to Open Records requests
with respect to documents showing additional policy violations and

breaches of the contract, as well as additional criminal

misrepresentations of state agency business in violation of OCGA 16-
10-20.

Overlooked authority for the injunction

The Georgia RICO statute specifically authorizes a Superior Court

to order the reorganization of any governmental entity to address a

pattern of criminal RICO predicate acts--as in the instant case where,
pursuant to admitted falsifications of the Georgia Perimeter College
budget, it is undisputed that over $9 million in state and federal funds
remains unaccounted-for. OCGA 16-14-6(a)(3) & 16-14-3(6).

That injunctive relief is separate and independent from the claims

for damages authorized by the RICO Act at OCGA 16-14-6(c).

Moreover, the injunctive relief requested against the state officials who
are defendants in this action, and specifically authorized against the
named Defendants by OCGA 16-14-6(a)(3), is not affected by any
claim of sovereign immunity. Ga. Dep't of Natural Res. v. Ctr. for a
Sustainable Coast, Inc. (Ga., 2014) (citizens aggrieved by the unlawful
conduct of public officers must seek relief against such officers in their
individual capacities).

In addition, the injunctive relief specifically authorized against

governmental entities by the RICO statute is, by definition, an express

waiver of sovereign immunity with respect to those injunctive relief
claims against the University System of Georgia (USG). OCGA 16-14-
6(a)(3) & 16-14-3(6) (reorganization of RICO enterprise, defined to
include governmental entity, specifically authorized).

Pursuant to this clear authority, Plaintiff filed a Motion for

Interlocutory Injunction (the Motion), seeking an order restoring

Plaintiff Tricoli to his position as president of Georgia Perimeter College
(GPC), based on admissions by Defendants that they had committed
RICO predicate acts with respect to knowing falsifications of the GPC
budget and after-the-fact misrepresentations of official reports and
alterations of official USG policy in an attempt to conceal the prior
criminal violations.

The Motion also addressed requests for documents in the

possession of Defendants under the Georgia Open Records Actwith

respect to additional RICO predicate acts for which the RICO Act
authorizes injunctive reliefrequests to which Defendants to this day
have failed to respond. The Motion also noticed filing of an Amended
Verified Complaint in support of the motion, including additional claims

of knowingly falsified state agency reports, violations of the Georgia

Computer Systems Protection Act, and abusive litigation by the Attorney
General. See Exhibit A, Amended Claims of the Verified Amended
Complaint.

That Motion for injunctive relief was filed on November 19, 2014.

On November 21, as reflected by the Clerks file stamp, the Court filed an
Order Granting Dismissal (the Order). The Order contains a hand-
written date indicating that the Judge signed the Order two days earlier,
on November 19, the same day the Motion was filed. The Order makes
no reference to the Motion filed on the same day. Moreover, no legal
argument in the Order dismissing Plaintiffs RICO action addresses the
Motion for injunctive relief under OCGA 16-14-6(a)(3).

There is no question that the Motion was filed prior to the filing of

the Order, two days after the date of signing, on November 21, 2014.
Exhibit B, file-stamped Order. While it would seem difficult to consider
all the matters contained in a 30-page Motion filed on November 19 in
an Order signed the same day, there is no question that the Order was
signed prior to the filing of the Amended Verified Complaint noticed in
the Motion, or the amended claims with reference to the verified fact

allegations that may not be barred pursuant to OCGA 9-11-15. See

Exhibit A.

Moreover, the grant of a motion to dismiss requires the Court to

find there is no set of allegations that could support the claims, and
therefore of course requires consideration of the claims themselves.
There is no question that the Court did not consider the Amended
Verified Complaint noticed in the Motion, since the amended allegations
and claims noticed in the Motion had not yet been filed when the Order
was signed on November 19.

Not only must the allegations and claims be considered before

granting a motion to dismiss, the claims and allegations must be

construed drawing every inference in favor of the party making the
claim. Liberty County Sch. Dist. v. Halliburton (Ga. App., 2014). Obviously,
they could not have been construed in the light most favorable to the
Plaintiff if the Court entered its Order without any opportunity to
review the verified amended claims and allegations brought in support
of the Motion for injunctive relief prior to entry of the Order of
dismissal. Moreover, the injunctive relief sought by Plaintiff is not
addressed by any aspect of the Orders holdings on sovereign immunity.
OCGA 16-14-6(a)(3).

Therefore, consistent with the Plaintiffs correspondence with the

Court related to this omission, Plaintiff requests a STAY of the Order

addressing the Complaint filed on May 7, but that omits the Motion for
Injunctive Relief filed on November 19, omits the fact allegations and
claims noticed in the Motion that are not addressed in the Order, and
omits the associated Amended Verified Complaint.

In addition, Plaintiff requests an order to LIFT the Stay of

Discovery pursuant to Defendants Motion to Dismiss so that Plaintiff

can do discovery on the matters for which Defendants have failed to
respond to Open Records requests.

Procedural Background

On September 19, 2014, Plaintiff filed the Affidavit of Anthony

Tricoli, documenting knowingly false representations of the GPC budget

at the same time that GPC and USG Defendants were sharing emails
contradicting the official reports to Anthony Tricoli, resulting in over $9
million in spending that remains unaccounted for, as documented in the
USG Special Report, as well as knowingly false media reports by USG
Defendants based on the GPC budget.

On September 22, 2014, at a hearing before the Court on

Defendants Motion to Dismiss, the Attorney General insisted that there

was no written contract on which to base Plaintiffs breach of contract
claims.

Also on September 22, Plaintiff served Defendants with Requests

for Admission related to Plaintiffs written contract, after the fact

changes of USG policy to conceal breaches of that contract, and knowing
misrepresentations of these and other matters under state jurisdiction
in violation of the Georgia Criminal Code, OCGA 16-10-20 & 16-14-
3(9)(A).

Plaintiff also initiated a series of Open Records requests focused

on the existence of a written employment contract incorporating USG

policies, and on the USGs performance evaluations of Tricoli required
by USG policy, in which no issue of the GPC budget was ever mentioned.
In addition, they confirm that USG Chancellor Hank Huckaby did not
perform the performance evaluation required by USG Policy 2.3 prior to
the April Board of Regents meeting as required by USG Policy 2.4.2.
Huckabys policy violations and breaches of the employment contract by
omission were occurring at the same time that the false reports of the
GPC budget were being submitted to Tricoli, and while the true status of

the budget was being concealed from Tricoli through a chain of emails
back and forth between GPC and USG Defendants.

On October 10, 2014, Plaintiff filed Notice of Evidence of Written

Contract in support of Plaintiffs Motion for Sanctions, based in part on

the Attorney Generals representations that there was no written
contract. Plaintiff submitted to the Court extensive evidence of the
written contract expressly subject to USG policies, as well as evidence
the USG had gone back and changed many of those policies to make
them consistent with the USGs conduct after the fact.

On November 4, 2014, Plaintiff filed his Supplement to the

Evidence of Written Contract and Motion for Sanctions, including

Defendants Responses to Plaintiffs Requests for Admissions, admitting
many of the criminal RICO predicate acts alleged in the Complaint. In
particular, the Attorney General of Georgia admitted that GPC budget
officials submitted knowingly false budget reports contradicted by their
own emails about a looming crisis, and that the USG changed many of
the policies related to the breach of Tricolis contract after the fact.

On November 19, Plaintiff filed a Motion for Interlocutory

Injunction based on the admission of RICO predicate acts for which the
Georgia RICO statute authorizes injunctive reliefincluding injunctive

relief with respect RICO enterprises that are governmental entities.

OCGA 16-14-6(a) & OCGA 16-14-3(6). In particular, the RICO Act
specifically authorizes the reorganization of any [governmental entity]
enterprise. OCGA 16-14-6(a)(3). Plaintiff subsequently filed an
Amended Verified Complaint based on the factual allegations and
documentation contained in Plaintiffs post-hearing pleadings, which in
turn are based on documents obtained through Open Records requests
and on the Attorney Generals admissions in response to Plaintiffs
Requests for Admissions.

On November 19, 2014, Judge Coursey signed the Order Granting

Dismissal (the Order). On November 21, that Order was filed with the
Clerk.

Content and Omissions of the Order



The Order does not indicate that any matter was considered after
September 22 hearing, despite pleadings containing admissions by the
Attorney General and supporting documents obtained through Open Records
requests. Order, p. 1. That leaves a great deal of pleadings and exhibits in
addition to the Motion that escaped review, including admissions of

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extensive criminal conduct confirming allegations of the original Complaint.

The Order also holds the state departments and agencies protected by
sovereign immunity, without addressing their amenability to injunction,
particularly with respect to OCGA 16-14-6(a). Order, p. 1.
The Order appears to make an additional factual statement upholding
the fraud by which Tricoli was duped into resigning his contracted position
on the promise of a USG central office position, a statement that has no
support whatsoeverthat Tricoli did not receive the promised USG job
because of additional reports of misconduct. Order, p. 2. There was a false
report of misconduct that is part of the overall pattern of criminal fraud
alleged. There has been no misconduct alleged supporting either the breach
or non-renewal of Tricolis contract, much less any additional misconduct
justifying those actions.
The Order states that Tricoli had no written contract of employment,
ignoring the extensive evidence filed by Tricoli contradicting this
sanctionable, false denial by the Attorney General that has no reasonable
basis in law or fact. Order, p 3. This appears to confirm the impression that
the Court did not consider any pleading filed after the September 22 hearing,
including Plaintiffs Motion for Sanctions and Supplement.

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The Court skirts the voluminous evidence offered to show a written

contract incorporating the policies of the USG by saying that after Tricolis
forced resignation, he had no contract. Order, p. 3 (Tricolis employment
contract as President of GPC ended with his resignation). The Court also
relies on a holding in Liberty County that there is no relief for a state agency
failure to issue a new contract on grounds of discrimination, an opinion that
does not address injunctive relief under the RICO statute (and which also
afforded the plaintiff alternate non-contract claims for defendants
misconduct). Liberty County Sch. Dist. v. Halliburton (Ga. App., 2014).
In any case, these rationales do not apply to the instant case, as they
do not address the documented breaches of both the contract and USG
policy during the term in which the contract was in effect, and the admitted
alterations of USG policy after the fact in an attempt to conceal the
wrongdoing. In fact, the Courts rationale stretches to find a negative
inference instead of following Liberty County:
"A motion to dismiss for failure to state a claim upon which
relief may be granted should not be sustained unless (1) the
allegations of the complaint disclose with certainty that the claimant
would not be entitled to relief under any state of provable facts
asserted in support thereof. Id.
The Order also does not address USG attempts to disguise otherwise
admitted breaches through after-the-fact changes of USG policy, as admitted

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by the Attorney General after this was extensively documented by Plaintiff

in the Notice of Filing of Evidence of Written Contract and Supplement.
The Order dismisses all tort claims. Order, p. 4. The tort claims in the
case are for fraud, fraudulent inducement, intentional infliction of emotional
distress. The Georgia Tort Claims Act (GTCA) does not bar these tort
claims against the state under the exceptions to the waiver of sovereign
immunity for specified tort claims at OCGA 50-21-24(7). The dismissal of
such tort claims against individual state employees, which Plaintiff does not
contest, does not impact RICO claims against individual state officers,
which clearly can be brought. Caldwell v. State, 321 SE 2d 704, 253 Ga. 400
(1984) (civil RICO action allowed against state official and employees
conducting the Georgia Department of Labor as a RICO enterprise); McCoy
v. Georgia Dept of Administrative Services, (Ga. App. 2014) (civil RICO
judgment against Georgia DFCS workers for fabricating charges and
evidence in the course of their state employment).
Instead of addressing the RICO statute or the case law deciding RICO
claims, the Order relies on a tort action decided under the GTCA. Order, p.5;
Board of Public Safety v. Jordan, 556 S.E.2d 837, 252 Ga. App. 577 (Ga.
App., 2001). However, the plaintiff in Jordan did not allege falsification of
state agency reports. In fact, Jordan admitted his dismissal was proper, but

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alleged defendants caused him emotional distress by bringing accurate facts

to the attention of the media to induce negative stories about him. Jordan,
252 Ga. App. at 582-83. That case certainly does not contain any allegations
supporting claims for criminal mail, wire, and computer fraud, or knowing
falsifications of state agency reports, as in the instant case, and those issues
were not addressed or decided in Jordan.
Moreover, while the Order purports to state this rationale for
dismissing Tricolis RICO claims under the pretext that they are tort claims,
instead, the Court never stated any grounds for dismissing the actual tort
claims against the state alleged by Tricoli because there are no GTCA
exceptions for the torts of fraud, fraudulent inducement, or intentional
infliction of emotional distress.
However, in extending GTCA exceptions to tort liability to cover
criminal RICO predicate acts, the Court specifically held that knowing
falsifications of the GPC budget, a crime under OCGA 16-10-20, are
discretionary acts immunized under a tort exception for negligence in
financial oversight. OCGA 50-21-24(11). Order, p. 5. The Court
specifically held that such knowing, criminal falsifications, and their
dissemination in violation of federal mail and wire fraud statutes are
immunized under the tort exception for defamation OCGA 50-21-24(7).

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The trickery in procuring Tricolis resignation was immunized as tortious

interference with contract rights, though there is no equivalence of elements
of a tortious interference claim with fraud, fraudulent inducement, or
extortion, much less theft by deception and Section 16-10-20 violations,
mail, wire and computer fraud. The Order did not address the amended
claims for computer fraud in violation of the state statute, the Georgia
Computer Systems Protection Act, as the Order was signed prior to the filing
of the amended claims noticed in the Motion filed on November 19.
The Order does not address any of the criminal statutes violated,
crimes that are listed as predicate acts under the RICO statute, except to say
that knowing falsifications of state agency reports, mail and wire fraud,
extortion, criminal violations of the GCSPA, and theft by deception are
within the ambit of the Boards discretion inherent to the exercise of its
administrative functions. OCGA 50-21-24(2). Order, p. 5-6.
In addition, without any explanation or analysis, the Order says RICO
claims are premised on the same conduct as the torts hypothesized by the
Court, so that the GTCA governs the claims that are based on criminal
violations--and not the RICO Act under which the claims are brought.
Nonetheless, the Order does not anywhere say that the claims fail to satisfy
elements of RICO criminal predicate acts, and therefore a civil RICO cause

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of action is authorized. OCGA 16-14-6(c). In addition to not consulting the

RICO statute, the Order does not mention the case law authorizing civil
RICO claims against state officials. Caldwell v. State, 321 SE 2d 704, 253
Ga. 400 (1984) (civil RICO action allowed against state official and
employees conducting the Georgia Department of Labor as a RICO
enterprise); McCoy v. Georgia Dept of Administrative Services, (Ga. App.
2014) (civil RICO judgment against Georgia DFCS workers for fabricating
charges and evidence in the course of their state employment). Instead, the
Order merely relies on a negative inference with respect to Plaintiffs claims
in order to grant the dismissal.
In the only actual reference to the RICO statute under which the
claims are brought, the Order claims there is no waiver of sovereign
immunity found in OCGA 16-14-3(g) [sic]. Order, p. 6. The Order does
not say what Section 16-14-3(6) does mean, if defining a criminal RICO
enterprise to include governmental entities does not mean the RICO Act may
reach into state agencies, as the courts found in Caldwell and McCoy.
The Order does not consider other indicia of waiver of sovereign
immunity found throughout the overall structure of the Georgia RICO Act:
OCGA 16-14-2 (legislative intent to prevent harm to state and
subversion of state economy).

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OCGA 16-14-3(9)(A) (inclusion of Section 16-10-20, GCSPA, and

theft by deception as RICO predicate actsall of which address state
government and contradict the discretionary function immunities relied on
by the Court).
OCGA 16-14-4 (specifically provides for respondeat superior civil
liability for RICO predicate acts).
OCGA 16-14-6(a) (authorizing injunctive relief for RICO predicate
acts).
OCGA 16-14-6(a)(3) (specifically authorizing injunctive relief to
reorganize a governmental entity that is being controlled as a RICO
enterprise).
OCGA 16-14-6(c) (authorizing civil action and punitive as well as
treble compensatory damages for criminal RICO predicate acts).
OCGA 16-14-6(e) (equivalence of civil action and criminal
prosecution under the RICO statute). It is clear that government officials are
not immune from criminal prosecution under RICO, and bear civil liability
on the same basis, as demonstrated in Caldwell and McCoy.

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The Order cites respondeat superior immunity under the GTCA for
tort claims, while ignoring the explicit respondeat superior liability
authorized at OCGA 16-14-4 for RICO claims. Order, p. 6.
The Order likewise cites the OCGA 50-21-30 bar to punitive
damages for tort claims against the state in the GTCA, and does not address
the specific authorization of punitive damages against individual defendants
for criminal RICO predicate acts at OCGA 16-14-6(c). Order, p. 7.
Finally, the Order states that Plaintiffs injunctive relief is dependent
on underlying tort and contract claimswith no mention of the RICO Act
specifically authorizing injunctive relief at OCGA 16-14-6(a) for the
criminal conduct alleged. In fact, the Order never in any way addresses the
criminal nature of the allegations in the Complaint. The Order makes no
reference whatever to the Motion, and its grounds for injunctive relief
founded in the Georgia RICO Act, or of the claims and allegations of the
Amended Verified Complaint noticed in the Motion prior to the premature
filing of the Order.

Pending Issues the Order did not consider

It is quite clear under the circumstances of an Order signed the

same day the Motion was filed, and prior to the filing of the Amended

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Verified Complaint, that the Order cannot possibly address the factual
allegations or legal claims raised therein. That includes Defendants
admissions of criminal conduct with respect to the knowing falsification
of state agency reports of the GPC budget, a fiasco in which over $9
million in state and federal funds remains unaccounted-for.

Plaintiffs Amended Verified Complaint may not be foreclosed in

that fashion pursuant to OCGA 9-11-15, which allows claims to be

freely amended up until the time of entry of a pre-trial order.

It is also quite clear that every inference was not construed in

Plaintiffs favor prior to filing the Order Granting Dismissal, considering

that the Court could not possibly have read the Motion and considered
the claims of the Amended Verified Complaint in the Order signed the
same day the Motion was filed and prior to the filing of the Amended
Verified Complaint noticed in the Motion.

Accordingly, the Court could not possibly have considered the

additional RICO claims based on criminal violations that target

wrongdoing in state government in the portion of the Order finding
sovereign immunity to RICO claims, such as the exhibit in the Motion
consisting of a standard USG form requiring employee

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acknowledgement of criminal liability for GCSPA violations using state

computer networks.

Likewise, the Order cannot possibly have considered amended

claims for GCSPA violations, OCGA 13-16-11, and theft by deception

noticed in the Motion. In short, the Order dismissed claims without any
knowledge of their basis, which cannot constitute an inference in favor
of the claimant.

The Order also does not account for the fact that, pursuant to the

amended claims, injunctive relief does not depend on tort and contract
claims as stated in the Order (even if they did, that would not bar
injunctive relief). Order, p. 7. The Motion specifically seeks relief under
OCGA 16-14-6(a)(3), which specifically authorizes injunctive relief for
RICO predicate actsand specifically authorizes it against a
government entity RICO enterprise as defined in OCGA 16-14-3(6)a
clear authority for the injunctive relief against state agencies and
officers that is nowhere addressed in the Order.

Similarly, while the Order acknowledges that the Attorney

Generals denials of the existence of a written contract cannot bear

factual or legal scrutiny, the Order skirts the breaches of Tricolis
contractas well as blatant violations of USG policy that were later

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camouflaged through a series of after-the-fact policy changesthat

occurred while the contract and applicable USG policies were in effect.
That certainly does not qualify as construing every inference in
Plaintiffs favor on those claims.

Most importantly, the Order completely ignores the criminal

nature of Plaintiffs actual allegations and causes of actionwhich bear

little resemblance to the hypothetical tort theories with which the Order
replaces them. That, also, clearly cannot qualify as construing every
inference in favor of the plaintiffparticularly with respect the
amended claims of which the Court had notice but never reviewed prior
to issuing its Order dismissing the RICO action on sovereign immunity
grounds that do not apply to the injunctive relief requested.

We are under extreme time constraints for resolving this issue

since the deadline for notice of appeal of the Order is December 20. Of
course we would have to include in any such appeal the issue of our
Motion being foreclosed by the case being closed after the Motion was
filed but without consideration of its merits.

In addition, Defendants have not responded to Plaintiffs Open

Records requests touching on knowing misrepresentations of the GPC

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budget at the heart of the USG, in the performance evaluations of Tricoli

required by USG policyboth the evaluations that took place leading up
to 2102, and the one that did not take place as required by USG policy
prior to Tricolis illegal ouster. For that reason, the Court should lift the
stay on discovery so that Plaintiff may pursue these records supporting
the relief he is requesting without resort to costly Open Records
requests that Defendants have ignored.
Irreparable harm from failure to consider the Motion

It is urgent that Tricolis November 19 request for injunctive relief

be considered. The motion was filed at that time based mainly on three
factors:
1) The Attorney General, though attempting to deflect blame onto
Tricoli, admitted in court records that GPC and USG officials
committed many of the RICO predicate crimes alleged in the
Complaint.
2) Tricolis counsel documented that the USG had gone back and
altered its own policies after the fact to disguise its own policy
violations when ousting Tricolion top of a USG self-audit in

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which $9 million remains unaccounted forforcing the Attorney

General to admit these discrepancies, as well.
3) The Interim president Tricoli seeks to replace, Robb Watts,
participated in the criminal misrepresentations of the budget,
does not meet the qualifications to serve as full-time president of
GPC, and has already spent a year longer in the interim position
than provided by USG policy. Meanwhile, there are indications
that the USG is moving to bring in a permanent replacement,
which would prejudice Tricolis attempt to regain the position
from which he was wrongfully ousted.

In light of Defendants failure to respond to the most incriminating

requests for documents under the Open Records Act, Plaintiff asks the
Court to remove the stay on discovery relative to Defendants Motion to
Dismiss, so that Plaintiff can obtain discovery relevant to the Motion for
injunctive relief in the face of Defendants failure to respond to requests
under the Open Records Act.

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Wherefore, premises considered, Plaintiff prays the Court to enter an

order staying the Order related to sovereign immunity for the damages
claims, setting a hearing on Plaintiffs pending Motion for Sanctions and
Motion for Interlocutory Injunction, and lifting the stay on discovery for
those purposes.

Respectfully submitted this 8th day of December, 2014.

STEPHEN F. HUMPHREYS, P.C.

/s/ Stephen F. Humphreys
___________________________
STEPHEN F. HUMPHREYS
Georgia Bar No. 378099
P.O. Box 192
Athens, GA 30603
1671 Meriweather Drive
Bogart, GA 30622
(706) 543-1844 f
(706) 207-6982 p

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CERTIFICATE OF SERVICE
Undersigned counsel hereby certifies that all Defendants in this action have
been served this Motion for Stay via electronic service, this 8th day of
December, 2014, as follows:
Samuel S. Olens
Dennis R. Dunn
Kathleen M. Pacious
Annette M. Cowart
Loretta L. Pinkston
Christopher A. McGraw
C. McLaurin Sitton
Office of the Attorney General
40 Capitol Square, SW
Atlanta, Georgia 30334-1300

STEPHEN F. HUMPHREYS, P.C.

/s/ Stephen F. Humphreys
___________________________
STEPHEN F. HUMPHREYS
Georgia Bar No. 378099

P.O. Box 192

Athens, GA 30603
1671 Meriweather Drive

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Bogart, GA 30622
(706) 543-1844 f
(706) 207-6982 p

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