IN THE UNITED STATES DISTRICT

COURT MIDDLE DISTRICT OF GEORGIA

VALDOSTA DIVISION
RICHARD JERRY
McLEOD,
167S Liberty Church Road
Boston, Georgia 31626
Plaintiff :
:
vs. : CIVIL ACTION FILE NO.
:
BILLY INGRAM, INDIVIDUAL : CLAIM UNDER U.S.C.
42 AND AS BROOKS COUNTY : SECTION 1983
ZONING ADMINISTRATOR, 1985
610 South Highland Street 1986
Quitman , Georgia 31643 (Monell Claim)
And
:
BROOKS COUNTY,
c/o Patricia Williams, Clerk
610 S. Highland Street
Quitman, Georgia 31643
And
:
MYRA EXAM., INDIVIDUAL :
AND AS BROOKS COUNTY

: COMMISSION CHAIRPERSON,
Post Office Box 272
Quitman, Georgia 31643
And
:
S. L. JONES, INDIVIDUAL :
AND AS BROOKS COUNTY

: COMMISSIONER,
Post office Box 272
Quyitman, Georgia 31643
:
JAMES MAXWELL, INDIVIDUAL :
AND AS BROOKS COUNTY :
1 COMMISSIONER,
2 Post Office Box 272
3 Quitman, Georgia 31643
 1 :
2 WILLIE CODY, INDIVIDUAL, :
3 AND AS BROOKS COUNTY :
4 COMMISSIONER
5 Post Office Box 272
6 Quitman, Georgia 31643
7 :
8 JOE WINGATE, INDIVIDUAL, :
9 AND AS BROOKS COUNTY :
10 COMMISSIONER,
11 Post Office Box 272
12 Quitman, Georgia 31643
13 And
14 :
15 MIKE DEWEY, INDIVIDUAL :
16 AND AS BROOKS COUNTY :
17 SHERIFF AND AGENT OF :
18 BROOKS COUNTY
19 10-0 Screven Street
20 Quitman, Georgia 31643
21 And :
22 JOE WHEELER, INDIVIDUAL, :
23 AND AS BROOKS COUNTY :
24 DEPUTY SHERIFF,
25 1004 Holloway Drive
26 Quitman, Georgia 31643
27 And
28 :
29 EUGENE OWEN, INDIVIDUAL :
30 AND AS BROOKS COUNTY :
31 SHERIFFS DEPUTY,
32 1004 Holloway Drive
33 Quitman, Georgia 31643
34 And
35 :
36 WILLIE CLEMMONS, INDIVIDUAL :
37 AND AS AGENT OF :
38 BROOKS COUNTY,
39 308 South Lee Street
40 Quitman, Georgia 31643
41 And
42 :
43 EDWARD WILLIAMS, INDIVIDUAL :
44 AND AS AGENT OF :
45 BROOKS COUNTY,
46 180 Big Star Drive
47 2
1 Thomasville, Georgia 31757

2 And
3 CHANDLER GIDDES, INDIVIDUAL :
4 AND AS AGENT OF :
5 BROOKS COUNTY,
6 180 Big Star Drive
7 Thomasville, Georgia 31643
8 And
9 :
10 LAURA HALL INDIVIDUAL :
11 AND AS AGENT OF :
12 BROOKS COUNTY
13 2134 Pinetree Boulevard
14 Thomasville, Georgia 31792
15 And
16
17 ROB OGLESBY
18 DBA NATES PLACE/
19 NATES HONOR ANIMAL RESCUE
20 4951 Lorraine Road
21 Bradenton, Florida 34211

22 And
23 FRAN OGLESBY
24 4951 Lorraine Road
25 Bradenton, Florida 34211
26 Defendants
27 All Defendants are named individually and in their official capacities as county employees unless

28 otherwise noted.
29 1. JURISDICTION
30 Jurisdiction over Plaintiffs civil rights claims is conferred on this Court by 42 U. S. C. 19883,

31 1985, 1986, 1988 and 28 U. S. C. 1343 (a)

32 2. Jurisdiction over the state law claims is conferred by U. S. C. 1367 (a)

33 3. The actions that are set forth in this complaint occurred in Brooks County Georgia and Thomas

34 County Georgia, Therefore venue with this Court is proper

35 I. Parties
36 1. Plaintiff, Richard Jerry McLeod has at all times relevant to this action been a citizen of the state

3
 1 of Georgia. He resides on a five acre tract of land located in a rural area of Brooks County
2 Georgia.

3 He has a hearing impairment and maintained a large number of service dogs and additional

4 companion which were illegally seized and confiscated due to the wrongful acts of the defendants

5 as described below.

6 2. Defendant, Billy Ingram is Brooks County zoning administrator. He is sued individually and in

7 his official capacity while acting under color of law under U.S.C. 42 1983. 1985, 1986.

8 3. Defendant , Myra Exum is Brooks County Commission chairwoman, She is sued individually

9 and in her official capacity while acting under color of law at all times relevant under U.S.C.

42 10 1983, 1985, 1986.

11 4. Defendants, S. L. Jones, James Maxwell, Willie Cody and Joe Wingate are Brooks County

12 Commissioners. They are each sued individually &in their official capacities acting under color

13 of law at all times relevant under U.S. C. 42 1983, 1985, 1986.

14 5. Defendant, Mike Dewey is Brooks County Sheriff. He is sued individually and in his official

15 capacity as Brooks County employee acting under color of law while enforcing Brooks County

16 zoning ordinances. He is sued under U.S.C. 42 1983, 1985, 1986.

17 Defendant, Joe Wheeler is Brooks County Chief deputy sheriff, He is sued individually and in his

18 official capacity as a brooks County employee acting under color of law, He is sued under

U.S.C 19 . 42 1983, 1985, 1986.

20 6. Defendant, Eugene Owen is a Brooks County Deputy Sheriff. He is sued individually and in his

21 Official capacity as a Brooks County employee acting under color of law. He is sued

under 22 U.S.C. 42 1983, 1985 and 1986.

23 7. Defendant, Edward Williams is executive director of Thomasville Thomas County Humane

24 Society. He is being sued individually and in his official capacity as an agent of Brooks County

25 acting under color of Law, He is sued under U.S.C. 43 1985, 1986.

26 8. Defendant, Chandler Giddes is animal control director of Thomas County. He is being sued

4
1 individually and in his official capacity as an agent of Brooks county acting under color of law.

2 9. Defendant, Laura Hall is veterinarian and is sued individually and in her official capacity as an

3 agent of Brooks County acting under color of law. She is being sue under U.S.C. 42 1983, 1984,

4 and 1985.

5 10. Defendant, Rob Oglesby is a citizen of Bradenton Florida and director, manager of Nates

6 Animal Rescue subject to Georgias Long Arm Statute. He was the receiver of plaintiff

7 confiscated dogs transferred to him by Edward Conspired is being sued individually and as an

8 agent of Brooks County and the Thomasville Humane Society acting under color of law. He is

9 being sued under U.S.C. 42 1983 and 1985, and under Georgia statutes,

10 11. Defendant, Fran Oglesby is an employee of Nates animal Rescue She orchestrated

11 defamatory TV interviews harmful to the plaintiff She is being sued individually and as agent of

12 Brooks County and Thomasville Humane Society acting under color of law and is subject to

13 the Georgia Long Arm Statute, U.S.C. 42 1983, and other provisions of Georgia Law.

14 11. Defendant, Willie Clemmons is a Quitman city police officer acting under color of law as an

15 Agent of Brooks County. He is being sued individually and as an agent of Brooks County under
16 U.S.C. 42 1983, 1985 and 1986

17
18
19 COMPLAINT
20
21 Now comes the above plaintiff and shows the Court the following:
22 I.
23 STATEMENT OF
24 FACTS
25 1.
26 Plaintiff Richard Jerry is a seventy eight year old male living on a five acre parcel of
27 land in the southwest corner of Brooks County Georgia. This tract of land is the
28 remainder of a farm owned and occupied by plaintiffs family for more than one hundred
29 years.

5
1 Plaintiff lives alone with a life estate on this property situate twelve miles from town and
2 suffers from a severe hearing impairment and other physical impairments commonly
3 associated with advanced age.
4 This action is the result of the progression and culmination of more than ten years of
5 harassment and attempted intimidation by the Brooks County governing officials, their
6 agents and associates.
7 These acts are described by the following:
8 1.
9 ILLEGAL TAKING ATTEMPT
10 Brooks County Commissioners attempted to clear portions of McLeods property and
11 construct two fifty foot dead end streets in an unpopulated area through his property
12 without any permission, condemnation or compensation. These proposed streets served
13 no public purpose.Plaintiff McLeod was required to expend three years of litigation
14 representing himself before finally prevailing in preventing this illegal taking.
15 2.
16 BROOKS COUNTY SHERIFF refused TO INVESTIGATE CRIME OF ARSON TO
17 McLEOD DWELLING
18 Plaintiff McLeods one hundred fifty year old personal dwelling and ancestral home was
19 destroyed by fire. This structure was qualified for listing on the National Register of Historic
20 Places.
21 The investigation by the Georgia State Fire Marshall concluded the fire was the work of an
22 arsonist. Despite the severity of the crime Brooks County Sheriff Mike Dewey declined and
23 refused to initiate any investigation or interview known suspects. He declined to assign a
24 investigator to the case and instructed his investigator not to talk with McLeod or return
25 his phone calls. McLeod has been very vocal with his criticisms of Sheriff Mike Dewey.

26 3.
27 CLAIM OF VIOLATION OF ALLEGED COUNTY ORDINANCE555
28 Brooks County zoning administrator Billy Ingram arrived at Plaintiff McLeods property

6
1 in March of 2015 and claimed he was in violation of an alleged ordinance restricting the
2 number ofhunting dogs or show dogs one was allowed to have on rural agricultural
3 zoned property.
4 Ingram admitted McLeod had no hunting dogs or show dogs. No complaint had ever
5 been made regarding McLeods dogs during his ten year tenure as zoning administrator,
6 that the subject alleged zoning ordinance had never been enforced against anyone in
7 Brooks County and that he was aware of widespread violations if the law were enforced as
8 written, (4)that he had no intentions of enforcing the law against anyone other than Mcleod
9 and (5)hat he had no personal knowledge of the name of any individual who may have
10 precipitated the present complaint. Despite the foregoing facts Mcleod was issued a
11 citation for violation of the ordinance and ordered toappear in the Magistrate Court.
12 Ingrams words were I am just doing what they told me to do - if I dont do it they will
13 get someone else.
14 At the Magistrate Court McLeod presented factual evidence that the alleged ordinance
15 had never been advertised in the newspaper, had never been legally adopted, never
16 codified or published as mandated by Georgia statutes. The magistrate judge turned a
17 deaf ear to the evidence and entered a guilty verdict against McLeod. McLeod filed a
18 timely appeal and requested the magistrate court to transmit the record to the superior
19 court for a de nova review. Assistant Judge Gerald Spencer refused
20 to allow the record to be transmitted to the superior court; - instead writing to McLeod that
21 he had denied McLeods appeal for not following the law. More than thirty days later
22 Magistrate JudgeJoyce Miskiel sent a second letter to McLeod stating that his appeal had
23 been denied. The officialGeorgia Appellate rules specify that magistrate court must first
24 transmit the record. Magistrate Court Jurisdiction over the case ends with the filing of a
25 notice of appeal. McLeod has filed A Complaint with the Georgia Judicial Qualifications
26 Commissions alleging that Judges Spencer and Miskiel

7
1 conspired to neglect and avoid their statutorily mandated duties in a conspiracy to block
2 McLeods timely and legitimate appeal. McLeod has subsequently obtained certified
3 copies of themagistrate courts record and hand delivered it to the superior court for
4 review. The appeal of alleged ordinance citation is now pending in the Brooks County
5 Superior Court.
6 4.
7 THE ILLEGAL RAID, CONFISCATION, AND SEIZURE OF McLEODS DOGS
8 Brooks County sheriff Mike Dewey, Chief Deputy Joe Wheeler and the Brooks County
9 Commissioners (having knowledge that alleged animal control ordinance was
10 unenforceable and void) vindictively conspired with Edward Williams, Chandler Giddes
11 and others to devise a nefarious plan to seize and confiscate McLeods dogs under color
12 of law. This nefarious plot between the Brooks county authorities, Williams, executive
13 director of Thomasville Thomas County Humane society and Chandler Giddes was of
14 necessity originated in Thomasville Georgia out of necessity since Brooks County has no
15 animal control operation. Neither the Brooks County Commissioners, Sheriff Mike Dewey
16 nor Edward Williams and Chandler Giddes showed any deference to or consideration of
17 the obvious facts that such a raid and confiscation of McLeods dogs which are McLeods
18 personal property violated McLeods due process rights under the FOURTH, FIFTH AND

19 FOURTEENTH AMENDMENTS of the United States Constitution.

20 (a) Defendants Williams and Giddes desired to procure large numbers of dogs for their
21 Florida Partners including Rob Oglesby doing Business as Nates Patch and Nates
22 Honor Farm in Bradenton, Manatee County Florida. Oglesby has an insatiable demand for
23 these dogs through his marketing/adoption of dogs in the lucrative South Florida Market.
24 (b) Defendant Williams has previously testified under oath that he has been doing
25 business continuously with Rob Oglesby and his Nates Patch animal rescue corporation
26 continuously for four or five years. This same information is shown in Open Records

8
1 Requests obtained from Thomasville Thomas County Humane Society records.
2
3 Determined not to be thwarted by their absence of any authority in Brooks County,
4 Williams and Giddes solicited and recruited a Brooks County citizen to file a formal
5 complaint concerning the number and alleged condition of Macleods dogs. Edwards and
6 Giddes solicited Ashley Small,a person known to them to file a complaint concerning
7 Mcleods dogs.
8
9 (d) Small lives with her husband on Pinion Point Hunting Preserve located more than five
10 miles south of McLeods property in a house provided by the landowner. Her husband is a
11 worker on the hunting property which is reported to maintain private unlicensed (license
12 not required) kennels housing more than one hundred hunting dogs. The preserve also
13 maintains a deer processing facility for the convenience of their members and guests.
14 Under Brooks countys interpretation and the plain language of the alleged dog ordinance
15 the keeping of these dogs would be a violation and prohibited.
16 (e) Small is not a neighbor of McLeod and there is only one residence between her
17 residence and the McLeod property in the span of five miles. Small observed some of
18 McLeods dogs had occasionally temporarily escaped from their enclosure and were along
19 the roadside.
20 (f) On or about the first of March 2016 Small began baiting McLeods dogs, enticing them
21 to escape their enclosure. Based on evidence found at the scene this bait included full
22 unopened bags of frozen biscuits, fish sticks, zip lock bags of meat products., small
23 portions of deer carcasses and other food. The empty containers of these items were
24 subsequently discovered i9n weeds just outside the fence on McLeods property.
25 (g) On the morning of Smalls alleged complaint she was traveling north on Ramsey road at
26 daybreak, came to a stop approximately fifty feet prior to the intersection, discarded the
27 partial remains of a deer carcass and proceeded across the intersection of Grooverville
28 Road entering Liberty Church Road. Small subsequently turned her vehicle around

9
1 and drove back south to Ramsey Road in order to photograph the dogs feeding on the
2 discarded deer carcass.
3 (h) Small reportedly called Brooks County Sheriff to report dogs running at large. When
4 two deputies arrived to investigate all but one of the dogs had returned to the enclosure.
5 (I) The deputies stated that it appeared the dog had been feeding on a discarded deer
6 carcass deposited on the side of the roadway and issued a citation for dogs running at
7 large and date for a state court appearance was set.
8 (I) Edward Williams and Chandler Giddes realized this due process action by Brooks
9 County was not adequate to authorize seizure of McLeods dogs and devised a plan to
10 disregard constitutionally mandated due process and bypass the normal required legal
11 process.
12 (j) Chandler Giddes proceeded to contact the Georgia Department of Agriculture (GDA)
13 and filed a false report claiming that McLeod was operating an illegal unlicensed anima
14 l rescue facility.
15 (k) The GDA dispatched an inspector to investigate Giddes complaint and inspect
16 McLeods dogs. This inspector determined the report to be false. The inspector was
17 permitted to enter McLeods property, inspected McLeods dogs and determined Giddes
18 complaint to be false. In the report of this inspection at request of this GDA inspector she
19 reported that THERE WERE NO VIOLATIONS of the Georgia Animal Control Act and the
20 case was closed unless she heard something further from the Brooks County sheriff. Copy
21 of this report was obtained from the GDA under the Georgia Open Records Act. This GDA
22 inspector was accompanied by Billy Ingram, Brooks County zoning administrator and a
23 deputy sheriff.
24 (k) An official report by a GDA inspector stating there were no violations of the Georgia
25 Animal Protection act obviously means there was no evidence of any animal cruelty.

1O
1 THE ILLEGAL WARRANT, RAID AND SEIZURE
2 (a) On March 9th 2016 little more than twenty four hours after the GDA inspector had
3 declared that there were no violations of the Georgia Animal Protection Act, the Brooks
4 County Sheriffs Swat Team, the as yet unnamed does, and the aforementioned named
5 and listed defendants swarmed over McLeods property to illegally seize his dogs.
6 (b) A deputy sheriff Eugene Owen presented a warrant claiming he was seizing and
7 confiscating McLeods personal property (his dogs) because Macleod was in violation of
8 the Brooks County Ordinance limiting him to ten dogs. The warrant further stated Mcleod
9 was being arrested for animal cruelty although no explanation was given as to what
10 evidence had been generated since the GDA inspector had issued a report of no violations.
11 The Warrant attached was issued by the same magistrate, Judge Joyce Miskiel,who
12 had conspired to block Plaintiff McLeods appeal of her prior ruling on McLeods alleged
13 violation of the invalid animal control ordinance. This is the same Judge who is the subject
14 of McLeods complaint to the Georgia Judicial Qualifications Commission. Hardly a
15 detached neutral.
16 (d) The warrant is invalid due to the facts that Judge Miskiel by her previous actions
17 shows hat she is not a detached neutral as required by the Fourth and Fourteenth
18 Amendments of the United States
19 Constitution and its Due Process Clause. There was no probable cause for granting a
20 warrant claiming animal cruelty when the GDA inspector issued official report of NO
21 VIOLATIONS of Georgia Animal Protection Act immediately preceding the Judges granting
22 of the warrant. The magistrate judge and the law enforcement personnel have refused to
23 give the plaintiff a copy of any alleged affidavit supporting granting of the subject warrant.

24 NO VOLUNTARY SURRENDER OF DOGS

25
26 There was no voluntary surrender of McLeods dogs. Plaintiff Mcleod was forced to
27 surrender his dogs under duress virtually at the point of a gun. He was also told that if he

11
1 failed to surrender the dogs he would be arrested and charged with animal cruelty; however
2 if he did surrender dogs he would not be arrested.
3 (a) Plaintiff Mcleod was told by deputy Owen and Edward Williams that if he would just
4 cooperate and help them capture the dogs and hand them over the fence he would not be
5 arrested or prosecuted or charged with any crime; however if he did not comply he would
6 surely be arrested and charged with animal cruelty. Faced with the real alternative that his
7 beloved dogs would be killed by the armed deputies, shot and possibly killed by
8 tranquilizing darts possessed by the officers and the dogs being dragged with nooses
9 around their necks Mcleod was forced to comply for the welfare of his dogs.
10 (b) Deputy Owen subsequently added an additional charge of obstruction as result of
11 McLeods demands that he be allowed to keep some of his dogs -[obviously not the acts

12 of a voluntary surrender].
13 Plaintiff McLeods dogs were recklessly crammed into small cages stacked three deep
14 and kept in a metal horse trailer for the most of the day. The temperature was
15 unreasonably warm reaching 85- 90 degrees as can be verified by weather reports.
16 Any pet owner subjecting his animals to such treatment would have been arrested and
17 charged with animal cruelty.
18 (d) Several of Mcleods dogs were shot by tranquilizing darts by a shooter who lacked any
19 concern for the dogs and had no adequate training for operation of the tranquilizing gun. It
20 was simply a sporting exercise for him. Three of Plaintiff McLeods dogs were killed by the
21 darts and accompanying trauma.
22 (e) A veterinarian Dr. Laura Hall participated in the seizure and witnesses the trauma and
23 death of these dogs. It is common knowledge that some dogs when shot with tranquilizer
24 darts require an immediate antidote to be administered or death occurs, Dr, Hall
25 neglected/declined to administer any antidotes resulting in the cruel death of these animals
26 (a criminal Act).

12
1 NO CHARGES HAVE BEEN FILED
2 Although False accusations of misdemeanor ordinance violations and misdemeanor
3 animal cruelty were made by deputy sheriff Eugene Owens no formal charges have ever
4 been filed. Georgia statutes require filing of ordinance violations in magistrate court and no
5 such charges were filed. Misdemeanor animal cruelty charges are required to be filed in
6 State Court within a ninety day period after arrest. This period has expired and no charges
7 have been filed.

8 BROOKS COUNTY AND ITS AGENTS HAVE REFUSED TO RETURN PLAINTIFFS

9 PERSONAL PROPERTY
10 DEFENDANTS, Brooks County Sheriff Mike Dewey, Agents of Brooks County
11 including Edward Williams, Rob Oglesby, Does and their agents and co conspirators have
12 refused to return Plaintiff McLeods illegally seized dogs which are his personal property.
13 O.C.G.A.17-5-2 requires return of seized property when a person is released without a
14 charge relating thereto unless it is contraband. Plaintiff Mcleods dogs are not contraband,
15 are his personal property and must be released to him immediately. The refusal to return
16 plaintiffs personal property violates the Georgia Statutes as well as the Fourth, Fifth, and
17 Fourteenth Amendments of the United States Constitution.
18 Plaintiff Macleod exercised due diligence seeking return of his dogs which are his
19 personal property. As soon as PLAINTIFF McLeod was released from custody he made a
20 personal appearance at the Thomas County Humane Society on March 14 th, 2016 and
21 requested he be allowed to reclaim his dogs. Defendant Edward Williams, acting as agent \\
22 for Brooks County refused plaintiffs request and even refused to allow him to visit his dogs -
23 falsely stating that all his dogs were under quarantine. An internet search revealed that the
24 majority of Plaintiff McLeods dogs had already been transported to Rob Oglesby in
25 Bradenton, Florida.

13
25.1 II.

25.2 CAUSES OF ACTIONS

25.3 FIRST CAUSE OF ACTIONS
25.4 (AGAINST ALL DEFENDANTS)

5 1.

6 (CONSPIRACY)
7 DEFENDANTS Edward Williams learned that Plaintiff McLeod possessed a large
8 number of dogs on his rural farm property located approximately thirty five miles southeast
9 of Thomasville in Brooks County Georgia. Realizing an opportunity to conspire with Brooks
10 County officials to stage a dramatic rescue operation of dogs to garner much needed
11 publicity for Thomasville Thomas County Humane Societys fund raising activities and to
12 provide a fresh supply of marketable dogs to Rob Oglesby defendants Williams, Giddes and
13 their co conspirators proceeded with the following actions:

14 1. Entered into a conspiracy, first with Chandler Giddes to contact the Georgia
15 Department of Agriculture (GDA) and file a false complaint stating that Plaintiff Mcleod was
16 operating an unlicensed animal rescue operation in violation of Georgia Statutes.
17 Defendant Williams and Giddes were required by their employment status to know the
18 definition of an ANIMAL RESCUE FACILITY Therefore; it is clearly apparent they knew
19 Giddes was filing a false report of a crime in violation of O.C.G.A. 16-10-26 .
20 2. Defendants Williams and Giddes continued their conspiracy by contacting and
21 conspiring with Brooks County officials to claim authority under an invalid Brooks County
22 ordinance limiting number of dogs in rural areas zoned as agricultural use. Realizing the
23 invalid nature of the alleged zoning ordinance the foregoing named defendants and their
24 Brooks County co conspirators knew the alleged ordinance was unconstitutional and
25 unenforceable. Their only other conceivable option was to fabricate a false claim of animal
26 cruelty in order to fabricate a false claim of animal cruelty and seize

14
1 Plaintiff McLeods dogs to supply defendant Rob Oglesby with a fresh supply
2 of marketable dogs.
3 3. Although claiming authority to seize Plaintiff McLeods dogs under color of legal
4 authority claiming violation of a county ordinance; Brooks County and its officials were
5 aware the ordinance proposing to limit the number of dogs one was allowed to possess was
6 unconstitutional and unenforceable. The ordinance which stated that one was prohibited
7 from keeping more than ten hunting dogs or show dogs in an agricultural zone was know to
8 be unconstitutional and unenforceable
9 The ordinance was never codified or published as required by Georgia Statutes, was never
10 enforced against anyone during its alleged ten year existence, and is currently on appeal in
11 the Superior Court of Brooks County. None of Plaintiff McLeods dogs were even hunting
12 dogs or show dogs as specified in the alleged ordinance. In the contrary; Plaintiffs
13 McLeods dogs were service assistant dogs and companion dogs.
14 4. No inventory or receipt for the illegally seized dogs was made or presented to Plaintiff
15 McLeod as required by law.
16 5. Plaintiff McLeods service dogs and companion dogs served a vital service to help
17 McLeod cope with his hearing impairment disability, serving as signal dogs to warn of any
18 danger as well as providing needed companionship. As a result of this illegal seizure of his
19 dogs plaintiff McLeod has suffered significant irreparable harm and uncompensated
20 damages. The foregoing torturous acts overtly and covertly committed by the defendants
21 deprived plaintiff McLeod of his legally owned personal property without due process of law
22 constituting an illegal taking as described in the Fifth and Fourteenth Amendments of the
23 United States Constitution and violated the Equal Protection Clause of the Fourteenth
24 Amendment of the United States Constitution.
25 The Defendants conspired with Rob Oglesby and Does to transfer custody and
26 ownership of

15
1 Plaintiff McLeods dogs to unlicensed animal rescue facilities and foster homes outside the
2 state of Georgia. The State of Georgia by its statutes requires any organization acquiring or
3 receiving a transfer of a dog from any animal shelter or organization or facility must
4 consent to and abide by the following rules:
5 (a) Apply for and be granted a Georgia License to operate within Georgia as an animal
6 rescue group, organization or individual. This license is to be renewed annually.
7 (b) Any animal rescue organization, group or individual is required to SUBMIT to the
8 Georgia Department of Agriculture a Consent to Jurisdiction form agreeing that it
9 agrees to be subject to the jurisdiction of any court in any county in the state of Georgia.
10 7. Defendant Rob Oglesby d.b.a. Nates Patch/ Nates Honorary resides in Bradenton,
11 Florida,has received the majority of Plaintiff McLeods dogs. Neither Defendant Rob
12 Oglesby or his affiliated companies or corporations are licensed in the State of Georgia as
13 Animal Rescue entities as required by Georgias Animal Protection Act.
14 8. Neither Defendant Rob Oglesby nor any of his affiliated entities have submitted a
15 Consent to Jurisdiction form to the Georgia Department of Agriculture as required by
16 Georgias Animal Protection Act. However; However Rob Oglesby and his affiliates are
17 subject to tje jurisdiction of Georgia courts under Georgias Long Arm Statutes.
18 All of the Named Defendants in this action have collectively conspired to transfer and
19 transport Plaintiff McLeods dogs south of the Georgia border into Florida, then offload the
20 dogs to Defendant Rob Ogesbys transport vehicle and transport to his facility. This crude
21 subterfuge provides further provides undisputed factual evidence of all the named
22 Defendants fraudulent conspiracy and attempts to evade and elude the mandates of
23 GEORGIA LAWS AND THE JURISDICTION OF ITS COURTS.
24 9. Plaintiff submitted a Georgia Open Records Request to the GDA requesting copies of
25 Consent to Jurisdiction forms and names of all out of state animal rescue entities who have
26 applied for and been granted a Georgia license to receive dogs from Georgia shelters or

16
 1 facilities. The response to this request revealed a complete absence of any application for of
2 grant of any license to Defendant Rob Oglesby or of any of his entities. The response
3 from GDA further shows a complete absence of any Consent to Jurisdiction form
4 submitted by Defendant Rob Oglesby or any of his affiliated entities.{however; Oglesby is
5 still subject to jurisdiction of Georgia Courts due to mandates of Georgias Long Arm
6 Statutes}.
7 The foregoing undeniable and indisputable acts by the individual and aggregate
8 defendants constitute acts of conspiracy committed with malice aforethought with intent to
9 conceal evidence and to evade and elude the jurisdiction of the Georgia Courts and inflict
10 damages upon the plaintiff. The defendants actions in orchestrating and actively
11 participating in this conspiracy must be punished by this Court.
12 SECOND CAUSE OF ACTION AGAINST ALL DEFENDANTS

13 2.

14 FRAUD
15 Plaintiff repeats and realleges each allegation set forth previously in this pleading
16 against all defendants just as if contained herein.
17 (a) All of the Defendants have participated in an elaborate premeditated scheme and plan
18 to secure dogs for sale in the lucrative south Florida market area while masquerading as the
19 good guysOn Defendant Rob Oglesbys web site he advertises McLeods dogs for sale for
20 the sum of $300 each.
21 He further advertises that he has three locations in the Bradenton, Manatee County Florida
22 area. ach and all of the defendants in this action are part of this fraudulent scheme and
23 resulting illegal acts whether they are active or passive participants and regardless of
24 whether they were witting or unwitting participants and thus should be punished as active
25 participants.
26 (b) The Defendants acts of seizing Plaintiffs dogs for there varied personal interests and

17
1 financial enhancements constitute acts of Fraud punishable under the laws of Georgia and
2 the United States Constitution. The Acts of the defendant violate the Fifth Fourth and
3 Fourteenth Amendments of the United States Constitution.
4 ( c) Defendants Edward Williams and Chandler Giddes acting as an agents of Brooks
5 County made fraudulent statements to plaintiff stating that Plaintiff McLeod would be
6 granted due process and be allowed to redeem his seized dogs in a fraudulent attempt to
7 convince plaintiff not to resist the illegal seizure.
8 (d) Defendant Williams, acting as agent for Brooks County refused to allow Plaintiff any
9 access to inspect his impounded and seized dogs stating that the dogs were quarantined,
10 Defendant Williams knew this statement to be blatantly false and that many if not the
11 majority of the plaintiffs dogs had already been transferred to Rob Oglesby or other Does.
12 And were advertise for sale , adoption for a fee of $300 each. These were the same dogs
13 that the defendants had described as starved and malnourished in their media blitz
14 . However; these dogs were suddenly worth $300 each??
15 These false statements and fraudulent acts by the defendants authenticate that their
16 primary purposes are raising money from donations personal financial enhancement from
17 sale of Plaintiffs dogs and embellishment of their public images. These acts and
18 statements were made recklessly with malice aforethought without any regard for the truth
19 and constitute acts of fraud and should be punished accordingly.
20 THIRD CAUSE FOR ACTION
21 (AGAINST ALL DEFENDANTS)

22 3.

23 THEFT
24 Plaintiff repeats and realleges each allegation set forth previously in this complaint
25 just as if they were contained wherein.The United States Courts have consistently held and
26 established binding precedents that the taking of ones property without due process of law
27 and without just compensation is THEFT

18
 1 .
2 The Georgia statutes also provide a remedy for a claim against persons who willfully
3 damage the owners personal property or commit theft. All of the aforesaid named
4 defendants have with malice aforethought and recklessness engaged in the theft of
5 plaintiffs dogs and must be required to return his dogs which are his personal property,
6 compensate him for damages and be punished for their illegal conduct in order to
7 deter such activities in the future.
8 When a person buys or receives property (particularly when it is offloaded from truck on
9 the side of the highway as in the dog transfer to Rob Oglesby) he has a duty to make certain
10 that the seller or transferor has good title to the goods and that they are not stolen.
11 Rob Oglesby, in his greed to illegally acquire McLeods dogs for resale clearly breached that
12 fundamental duty.

13 FOURTH CAUSE OF ACTION

14 4.

15 CONVERSION
16 Plaintiff repeats and realleges each allegation set forth previously in this complaint just as if
17 they were included herein.
18 Defendants have individually and collectively committed numerous acts of
19 CONVERSION by illegally taking, seizing and confiscating plaintiffs dogs which are his
20 personal property and converting the Plaintiffs property to their own personal use to
21 enhance their financial gain and embellish their own public persona.. In violation of the
22 FOURTH, FIFTH, AND FOURTEENTH AMENDMENTS of the United States Constitution
23 and O.C.G.A. 16-8-4 The aforesaid defendants have deprived the plaintiff of the use of his
24 personal property. The dogs stolen from the plaintiffs property have been raised from birth
25 by the plaintiff and had been trained to protect plaintiffs property from all intruders, to signal
26 and alert him to danger and to provide love and companionship.

19
1 FIFTH CAUSE OF ACTION
2 (ALL DEFENDANTS)
3 5.
4 FRAUDULENT CONCEALMENT
5
6 PLAINTIFF alleges and re alleges each allegation set forth previously in this complaint just
7 as if they were contained therein.
8 (a) The aforesaid defendants engaged in a campaign of fraudulent actions and fraudulent
9 concealmentby refusing to provide access to plaintiffs dogs or to provide access to any
10 documents inventory or other information on disappearance of plaintiff McLeods dogs which
11 are his personal property.
12 (b) When Plaintiff made an appearance at Thomasville Thomas County Humane Society
13 and asked for permission to inspect his dogs and ask for an accounting and inventory of the
14 seized dogs the defendant Williams refused access, stating that Plaintiffs dogs were under
15 quarantine thereby falsely misrepresenting material facts with scienter.
16 The Plaintiff learned from Rob Oglesbys internet posting that the majority of his dogs
17 had been transferred to Rob Oglesby in Bradenton, Florida shortly after the illegal seizure
18 and confiscation in a clearly apparent effort to conceal their location from the plaintiff.
19 (d) Plaintiff has sent numerous Open Records requests to defendants Williams and
20 Giddes seeking information on the disposition and disposal of his dogs but the defendants
21 failed to respond. The defendants were eventually ordered by a judge to supply the
22 requested records. However; the response was one which showed glaring omissions;
23 claiming exemptions of trade secrets, work in progress and
24 other claimed confidential information. No such exceptions are contained in or granted by
25 the Act for an animal shelter. The documents that were supplied consisted of a
26 confused maze
27 of duplications and omissions in an obvious attempt to confuse and delay. Further litigation
28 will be necessary to compel defendants compliance with the Georgia Open Records Act.

20
 1 (e) The defendants Open Records Response claiming to show disposition of McLeods
2 dogs failed to list the name Rob Oglesby, Nates Patch or any of Oglesbys affiliates as
3 entities receiving any of McLeods dogs. This falsity is a deliberate act of fraudulent
4 concealment contrived and designed toevade, contravent, circumvent and elude Georgia
5 laws and the statutory requirements of the Georgia Animal Protection Act that requires
6 ALL out of state Animal Rescue entities to be Licensed with the Georgia Department of
7 Agriculture and requires such animal rescue entities to submit a Consent to
8 Jurisdiction form. The foregoing actions of the defendants constitute fraudulent
9 concealment of Plaintiffs dogs and the facts surrounding and pertaining to their disposition.
10 (f) Defendants Williams, Giddes and their co conspirators issued numerous press
11 releases and gave TV interviews making reckless and fraudulent statements including
12 Williams statements that many of McLeods dogs were feral and not adoptable.
13 The only conceivable conclusion a reasonable person can conclude from this statement is
14 that Defendant Williams and his co conspirators plan to euthanize many of McLeods dogs.
15 These dogs were born on McLeods property and have been arbitrarily classified as feral and
16 of no value based on his flawed opinion which is not supported by any facts or scientific
17 evidence.
18 (g) These dogs Defendants have arbitrarily, recklessly and with malice aforethought
19 classified as feral are the same dogs that were born on McLeods property, are adequately fed
20 every day, sit in Mcleods lap chase squirrels on the five acre property and serve as service
21 dogs for Mcleod who has impaired hearing disability and visual difficulties.
22 (h) The foregoing arbitrary, malicious and unsupported statements and allegations by
23 defendant
24 Williams are simply an effort to justify euthanization of McLeods dogs despite the fact he has
25
26 made claims that Thomasville Thomas County Humane Society is a no kill shelter
27 (I) On March 9th, 2016 while in the process of seizing and processing Mcleods dogs

21
 1 The straught Plaintiff Mcleod was lamenting to defendant Giddes the fate and probable
2 destruction of Plaintiffs dogs defendant Giddes proudly announced that I should not worry
3 because The Thomasville Humane Society only has a fifty per cent kill rate meaning that fifty
4 per cent of Plaintiff McLeods dogs would likely be euthanized. This statement by defendant
5 Giddes was obviously of no comfort to McLeod who has an intense love for his loyal dogs who
6 have provided him with many years of service and companionship. The Plaintiffs dogs
7 are like family members and are treated as such.
8 (j) The Georgia Animal Protection Act requires that all animal shelters maintain a euthanazia
9 record describing what dogs were euthanized, dates of the euthanazia , records of the
10 inventory of the euthanazia drugs used and other information. This record is required to be
11 made available for public inspection. Plaintiff McLeod has made numerous requests for copies
12 of these euthanazia records; however defendant Edward Williams has refused to supply the
13 requested records.
14 (k) It is obvious to any reasonable person that defendant Williams is deliberately hiding
15 something in the euthanazia records. What is he hiding and fraudulently concealing from the
16 public view?Unfortunately the answer may be found in a lawsuit filed as
17 Catherine Garris v. Thomasville Thomas County Humane Society Case No. IDO%-5811 Fl
18 App.. Garris, volunteer at the Humane Society
19 surrendered two dogs with the explicit instructions and agreement that if they could not be
20 adopted they would not be euthanized and she would be allowed to redeem the dogs. Despite
21 the agreement the dogs were euthanized without her knowledge.
22 (l) The Plaintiffs dogs are clearly apparently exculpatory, primary and essential evidence
23 necessary for the prosecution of this case and any other potential related litigation Although the
24 Georgia Supreme Court and other courts have consistently established binding predent that at
25 the first knowledge or notice of potential impending litigation one has a duty to preserve the
26 evidence. Despite this well established precedent the defendants in this case have proceeded

22
 1 at breakneck speed to dispose of all the evidence (McLeods dogs)by the fraudulent
2 concealment of moving them out of state to an unlicensed rescue facility, denying any
3 inspection of the dogs by the plaintiff. And refusing to provide any accurate records of their
4 disposition or disposal. These actions constitute acts of fraudulent concealment violating the
5 Federal Doctrine of Fraudulent Concealment and Georgia statutes providing remedies for
6 claims against acts of fraudulent concealment.
7
8 SIXTH CAUSE OF ACTION
9 (AGAINST ALL DEFENDANTS)
10 6
11 DEFAMATION LIBEL AND SLANDER
12 PLAINTIFF repeats and re alleges each allegation set forth previously in this complaint just as if
13 were contained herein.
14 All defendants have committed numerous acts of Libel, Libel Per Se, Slander,
15 and Slander Per Se orchestrating, perpretrating and engaging in the following acts,
16 (a) Defendants Edward Williams, Chandler GIDDES and Laura Hall held press conferences
17 or WALB TV,WCTV, WSG TV, and WTL FOX 49 television stations broadcasting verbatim
18 false reckless accusations. All of the broadcast interviews included pleas for cash donations to
19 help care for the animals which Defendant Williams had already proceeded to dispose of.
20 No dog food was needed - JUST SEND CASH.
21 (b) These interviews and press releases by the foregoing named defendants contained
22 reckless blatant lies,opinions and innuendo made with malice aforethought with the deliberate
23 intent to permanently destroy the reputation of the plaintiff and including baseless and false
24 claims that plaintiff was mentally ill. These claims standing alone create actionable claims for
25 defamation, libel and slander.
26 Defendant Williams continued his defamation, slander and libel by giving another television

23
1 interview broadcast on WALB TV on July 15th 2016. This interview contained a link to the
2 previous defamatory broadcast causing the original false and blasphemous broadcast to be
3 re+ broadcast committing new defamatory acts of slander and libel; all of which were
4 deliberately planned with malice aforethought and malicious and wanton intent..
5 (d) The aforesaid listed interviews presented by the defendants and their co conspirators were
6 broadcast at least twice on the broadcast dates and reaches millions of viewers throughout
7 Georgia and North Florida.
8 The aforesaid interviews of defendants Williams, Giddes and their co conspirators were also
9 published on the internet reaching millions of viewers nationwide.
10 (e) Defendant Edward Williams has additionally posted numerous defamatory and libelous
11 statements on Thomasville Thomas County Humane Society Web Site and on the Societys
12 Face book account potentially reaching millions of viewers. This action by defendant Williams
13 and other participating defendants was undertaken with malice aforethought designed, and
14 contrived to libel the plaintiff and to cast him in a false light in order to inflict permanent and
15 irreversible damage upon the plaintiff.
16 (f) Defendants Edward Williams, Chandler Giddes, Laura Hall and other co conspirators did
17 with malice aforethought issue a pres release to the Thomasville Times Enterprise newspaper
18 making a litany of false and baseless claims, unsupported opinions, false conclusions and
19 outright lies which they knew or should have known had no basis in fact and were not true.
20 These statements by the aforementioned defendants are acts of defamation,are libel and libel
21 per se unsupported by any credible evidence. This press release was also published in the
22 Tifton Gazette, Moultrie Observer, Valdosta Daily Times and other affiliated newspapers.
23 reaching tens of thousands of readers.
24 (g) The aforesaid press release was also published on each of the aforesaid newspapers
25 websites, remains available on their websites and has been made available to millions of
26 viewers. This press release is also shown on numerous social media sites and blog postings

24
 1 constituting acts of libel and libel per se. All of the foregoing acts of defamation including libel,
2 libel per se and slander per se were premeditated and undertaken with recklessness,
3 wantonness and malice aforethought in order to inflict the maximum pain and suffering upon
4 the plaintiff.
5 (h) Defendant Rob Oglesby, who operates an animal rescue facility not licensed in Georgia as
6 mandated by the Georgia Animal Protection Act could not afford to miss the golden opportunity
7 to take advantage of the free publicity surrounding the illegal seizure and confiscation of
8 McLeods dogs. Defendant Oglesby and his companies have received the majority of Defendant
9 McLeods dogs and they are offered for sale on his website for sale at the rate of three hundred
10 dollars each ($300) Defendant Oglesby and his defendant co conspirators prearranged and
11 orchestrated fo a camera crew to meet him with his van load of dogs
12 illegally seized from Plaintiff McLeod for a Television interview.
13 (I) at this press conference Oglesbys defendant co conspirators made numerous reference to
14 McLeods starving dogs but was unable to provide any views of any dog that appeared
15 malnourished or starved.
16 Oglesbys co conspirator proceeded to make numerous statements that McLeod was mentally ill
17 and was guilty of operating a puppy-mill. None of these slanderous statements were supported
18 by any evidence or had any basis in fact. These statements by the foregoing defendants
19 constitute acts of slander and slander per se.
20 Defendant Oglesby was offering these alleged malnourished dogs for sale the following day for
21 $300 each.
22 (j) These Tv interviews by Rob Oglesbys defendant co conspirator Fran Oglesby were
23 broadcast on two television stations in the Bradenton and Sarasota Florida areas and constituted
24 acts of slander and slander per se by the foregoing Oglesby defendants. All of these broadcasts
25 included pleas for donations to help feed the animals which were to be sold for $300 each.

25
 1 These TV broadcasts wereviewed by millions of viewers throughout the central and south
2 Florida areas.
3 (k) These foregoing TV broadcasts were subsequently posted on the stations websites and
4 made available for viewing and listening by millions of persons. These web posting resulting
5 from defendants Rob Oglesby and Fran Oglesbys defamatory statements constitute acts of
6 slander, slander per se, libel and libel per se. These defamatory acts by the aforesaid
7 defendants were prearranged and premeditated with wantonness,recklessness and were made
8 with the malicious intent of inflicting the maximum amount of pain and suffering upon plaintiff
9 McLeod. The statements by the aforesaid defendants were made in order to cause
10 irreparable and permanent damage to plaintiff to portray plaintiff in a false light and destroy his
11 reputation.

12 SEVENTH CAUSE OF ACTION

13 (ALL DEFENDANTS)
14 7.
15 ANIMAL CRUELTY
16
17 Plaintiff repeats and realleges each allegation set forth in all previous pleadings set forth in
18 just as if they were contained herein.

19 All of the defendants individually and collectively are responsible for the acts of animal
20 cruelty inflicted upon Mcleods animals as they were all active participants in the illegal seizure
21 and confiscation and must share equally and individually in the resulting damages and
22 punishment..Several of McLeods dogs were shot by with a tranquilizing gun by defendant
23 Willie Clemmons, (the shooter) while acting as an agent of Brooks County. The tranquilizing darts
24 used by defendant Clemmons can often prove fatal by piercing the lungs of small dogs. Three of
25 the dogs shot by defendant Clemmons died as result of being shot by these tranquillizing darts.
26 The necropsies of the dead dogs showed evidence of large red spots on the lungs of all three
27 dogs consistent with the penetration of a tranquilizing dart to the lung. Tranquilizer darts are only

26
 1 to be used when a dog is vicious and presenting an immediate threat.
2 Plaintiffs dogs were not threatening anyone and only wanted to be left alone to enjoy the
3 companionship and love of their master and to chase squirrels on their fenced five acre wooded
4 property.
5 It is universally recommended that when using tranquilizing darts the operator must have a
6 supply of antidote available to administer to prevent death. Dr. Laura Hall a veterinarian was
7 present at the property site and made no attempt to administer any antidote to save the life of
8 McLeods service dogs. All of the plaintiffs dogs were in good health when he was arrested and
9 forced to leave the property.
10 To add insult to injury the most outrageous of all actions by the collective defendants is the
11 plan to cover up the actual cause of death of the three dogs- falsely claiming in press releases
12 that they died from worms in the brain - an extremely rare occurrence which rarely if ever occurs
13 in dogs according to the most recent scientific literature.
14 These unwarranted and unbearable acts of animal cruelty by the defendants should be
15 punished with actual damages, compensatory damages and the most severe punitive damages
16 for these premeditated acts of aggravated animal cruelty causing the deaths of plaintiffs three
17 dogs.
18 EIGHTH CAUSE OF ACTION
19 (ALL DEFENDANTS)
20 8.
21
22 EMOTIONAL DISTRESS
23 Plaintiff repeats and realleges each allegation set forth previously in this complaint just as if set
24 forth herein.
25 The previous causes of actions enumerated in this complaint have resulted in pecuniary
26 losses due to theft, concealment, and destruction of plaintiffs personal property, and
27 trespass to his property resulting in severe depression, anxiety and
28 paranoia. PLAINTIFFS emotionsl distress began with a sense of horror that the defendants

27
 1 masquerading as animal advocates could possibly engage in such illegal acts. Periods of anger,
2 shame, chagrin, embarrassment, worry and nausea followed. Plaintiff is now left in a state of
3 disappointment and extreme grief just as a person may experience from the sudden loss of
1 multiple loving family members. These conditions are a direct result of the defendants illegal
2 actions in the seizing, theft, conversion, fraudulently concealing and disposing of his beloved dogs
3 which were part of his family and were his personal protectors.
6 The defendants have with malice aforethought orchestrated and executed a vindictive
7 defamatory media blitz of false accusations libeling and slandering the plaintiff resulting in ongoing
8 and added emotional distress. The Plaintiff should receive just and adequate compensation for
9 these irreparable and continuing losses and damages.
13
14 NINTH CAUSE OF ACTION
15 (ALL DEFENDANTS)
16 9.
17 VIOLATIONS OF AMERICANS WITH DISABILITIES ACT
18 (a ) All of the plaintiffs adult dogs were service dogs trained or in the process of being trained by
19 the plaintiff. They were indispensable to his health, safety and well being. Plaintiff McLeod is
20 seventy eight years of age and suffers from a severe hearing impairment and poor vision. He is
21 unable to detect the direction of a sound or the type of sound. The majority os his property is
22 composed of woods and plaintiff depend on these service dogs to alert him to presence of
23 snakes,prowlers or other dangers.
24 (b) The federal ADA rules specify that a dog trained to alert its owner with impaired hearing
25 qualifies as a service dog, The ADA also specifies that an owner is allowed to train his own
26 service dog and there is no specific limit to number of dogs one may claim as service dogs.
27 The plaintiffs seized dogs are indispensable as McLeods signal dogs alerting him to the

28
 1 sound of a vehicle or horn at his gate or the sounds and direction of approaching danger.
2 His bulldogs slept in his doorway allowing plaintiff to sleep assured that he would not be
3 subject toany danger. Plaintiffs property is isolated with no nearby neighbors and no reliable law
4 enforcement.
5 Both the Federal government and the State of Georgia statutes mandate significant penalties and
6 punishments for persons who steal, maim, kill or injure service animals
7 (d) The defendants have maimed and killed three of my service dogs and stolen the rest of them
8 and should be punished severely to deter them from such reckless and illegal acts in the future.
9 (e) The ADA rules specify that a service or assistance animal has a value far beyond the
10 traditional market value of a companion animal, Having his eyes, ears and mobility taken away
11 constitute serious offenses.
12 Therefore; the plaintiff should be compensated for his loss and the defendants should be punished
13 for their reckless, wanton malicious actions.

14 PLAINTIFF HEREBY PRAYS that damages be awarded for defendants violations of the
15 ADA rules and Georgia statutes.
16 10.
17 TENTH CAUSE OF ACTION
18 DAMAGES
19 SPECIAL DAMAGES, GENERAL DAMAGES
20 COMPENSATORY DAMAGES
21 WHEREFORE PLAINTIFF prays for the Court to award the sum of Two hundred fifty
22 Thousand dollars (250,000.) Special Damages to compensate plaintiff for loss of future income as
23 provided under O.C.G.A. 51-12-2. Plaintiff has been rendered permanently unemployable due to
24 the acts of slander libel and other nefarious and malicious actsby the defendants and the resulting
25 damage to his reputation.
26 2, Plaintiff prays for the Court to award General damages and compensatory damages as provided

30
 1 by O.C.G.A. 51-12-2to compensate Plaintiff for the mental pain and suffering, emotional distress
2 caused by the anguish, and distress caused by defendants intentional, wanton and reckless
3 conduct.
4 3. PLAINTIFF prays that the Court award damages in payment for his compensatory and general
5 damages including the following:
6 A. Damages for Mental Anguish and Distress
7 B. Damages for defamation slander and libel
8 C. Punitive damages
9 D. Attorney fees and cost of suit
10 E. Reimbursement of negative tax consequences of a jury verdict
11 F, Such other relief as the Court may deem equitable and just
12 The PLAINTIFF further requests that defendants be ordered to immediately return all of Plaintiffs
13 dogs without further delay as provided under the fourth, fifth and fourteenth amendments of the
14 United States Constitution ans as provided by O.C. G. A. 17-5-2. Plaintiff McLeod has not been
15 charged with a crime and his dogs are not contraband of any crime.
16 ELEVENTH CAUSE OF ACTION
17 (ALL DEFENDANTS)
18 11.
19 PUNITIVE DAMAGES
20 WHEREFORE PLAINTIFF hereby prays that the Court award punitive damages as the
21 foregoing facts alleged in this complaint support a claim for punitive damages.
22 1, Defendants have committee acts of conspiracy by their combined and cumulative acts
23 designed to eprive plaintiff of his personal property and its use and should be punished to deter
24 them from such future acts.
25 2. Defendants have committed the acts of theft, theft by receiving, and conversion illegally
26 taking Plaintiffs personal property and converting it to their own use to enhance their personal
27 and financial gain

31
 1 and should be punished to deter them from such future acts
2 3. Defendants have committed cumulative and continuing acts of actual fraud and fraudulent
3 concealment and are presently continuing these acts, The defendants have made numerous false
4 material misrepresentations of existing facts with knowledge that they were false and with reckless
5 disregard as to whether they were true. The plaintiff was forced to rely on these
6 misrepresentations in reasonable reliance of their truth to detriment of plaintiff.
7 4. Defendants inflicted wanton, voluntary and intentional mental emotional distress upon
8 the plaintiff. This extreme , and willful conduct by the defendants was contrived and designed to
9 inflict the most severe and outrageous damage possible upon the plaintiff and must be punished
10 to deter them from such acts in the future
11 5. The defendants committed acts of invasion of plaintiffs privacy and defamation by (1) intrusion
12 upon the plaintiffs seclusion and solitude, and into his private affairs; (2) public disclosure of
13 embarrassing facts about the plaintiff; (3) publicity which places the plaintiff in a false light in the
14 public eye.
15 6. Defendants pursued an aggressive media campaign making slanderous and libelous
16 statements in live television in addition to web based internet media and committed libel and
17 slander per se as evidenced in preceding paragraphs. These statements and false misleading
18 characterizations were made with malice aforethought with no regard for their veracity.
19 7. WHEREFORE The foregoing causes of action and the resulting consequences culminating in
20 irreparable harm to the Plaintiff constitute aggravating circumstances which must be punished as
21 provided by the Fourth, Fifth, and Fourteenth Amendments of the United States Constitution and
22 as provided by OC.G.A. 15-12-51. The foregoing previously enumerated causes of actions
23 provide clear and convincing
24 evidence of the defendants ongoing acts of conspiracy, fraud, theft, fraudulent concealment and
25 conversion while acting under color of law resulting in emotional distress and irreparable harm and
26 damages to Plaintiff McLeod.
27

33
 1 8. By these combined actions showing conscious indifference to the resulting consequences the
2 defendants explicitly prove their willful misconduct, malice, fraud, recklessness, wantonness
3 ,
4 oppression, and that entire want of care which raises the presumptions that they are above and
5 immune to the laws of the state of Georgia and to the United States Constitution.
V.
RELIEF SOUGHT
6 WHEREFORE PLAINTIFF PRAYS that the Court award damages as follows:
7 A. Damages for mental anguish and distress
8
9 B. Damages for defamation slander and libel
10 C. Punitive Damages
11 D. Attorney fees and cost of the suit
12 E. Reimbursement of negative tax consequences of a jury verdict
13 F. Such other relief as the Court deems equitable and just.
14 Plaintiff further requests that the Court order the defendants to return and deliver Plaintiff
15 McLeods dogs to him without further delay as they are not contraband of any crime.

CERTIFICATION AND CLOSING

Under Federal Rule of Civil Procedure 11 by signing below I certify to the best of my knowledge
information and belief that this complaint : (1) is not presented for any improper purpose, such as to
harass, cause unnecessary delay or needlessly increase the cost of litigation; (2) is supported by
existing law or a non -frivolous argument for extending, modifying, or reversing existing law (3) the
factual contentions have evidentiary support or, if specifically so identified will likely have evidentiary
support after after a reasonable opportunity for further investigation or discovery and (4) the complaint
otherwise complies with the requirements of Rule 11.
A. I agree to provide the Clerk's Office with any changes to my address where case related papers may
be served. I understand that my failure to keep a current address on file with the Clerk's Office may
result in the dismissal of my case.

34
Date of signing _______________

_______________________
Richard Jerry McLeod

23 CERTIFICATE OF SERVICE
24 I hereby certify a copy of the foregoing 1983 Civil Rights Violation pleading and request for waiver
25 of personal jurisdiction was mailed/delivered to each individual defendant at their accompanied
26 listed physical addresses and to all of their available email addresses where publicly available.
27
28 -----------------------------------
29 Richard Jerry McLeod
30 1675 Liberty Church Road
31 Boston Georgia 31626
32 229-263-7981

34