IN THE SUPERIOR COURT OF FULTON COUNTY

STATE OF GEORGIA
ELIZABETH DENISE CALDON,
Plaintiff,

v.
BOARD OF REGENTS OF THE
UNIVERSITY SYSTEM OF GEORGIA,
Defendant.

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Civil Action No.

2009-CV-165267

MOTION TO SET ASIDE JUDGMENT

Comes now Plaintiff Denise Caldon and moves pursuant to OCGA 9-1160(d)(2) to set aside the final judgment incorporated in the Order of the Fulton
County Superior Court for Summary Judgment, Order of the Georgia Court of
Appeals pretermitting whether Plaintiff had a claim under OCGA 45-1-4, the
Georgia Whistleblower Act (GWA), and Denial of Motion for Reconsideration, and
shows the Court as follows:
1.
The Courts in this action expressly applied at-will employment common law
in place of the GWA, OCGA 45-1-4. The trial court held that Plaintiff could bring no
GWA claim because Defendants offered an alternate common law at-will pretext for
her termination. Exh. 1, Order of Summary Judgment.
2.
At the time the final judgment was entered, the Georgia Court of Appeals
considering this summary judgment order admitted it did not know the standard for

considering entry of summary judgment on a claim under the GWA. Exh 2, p. 7 at

n.6. The Court of Appeals further conceded that it upheld the order of the court
below pretermitting the issue whether Plaintiff had a claim under the statute
under which this action was brought, OCGA 45-1-4. See Exh 2, . p 8, Exh. 3, Order
denying motion for reconsideration.
3.
Since the entry of the final judgment, the Board of Regents of the University
System of Georgia likewise admitted that Plaintiffs claims under the GWA were
never considered in her Application for Review, alleging improper termination nine
days after Plaintiff refused to continue falsifying for pension calculation purposes-in violation of OCGA 47-3-1411 --the personal leave reports of then-President
David Bell of Plaintiffs employer Macon State College, under the aegis of Defendant
Board of Regents of the University System of Georgia. Exh. 4, Deposition of Regent
Doreen Stiles Poitevint highlighted excerpts; Exh. 5, CBS interview of Regents
Counsel Burns Newsome, November 14, 2013.
4.
Furthermore, since the entry of final judgment, the Georgia Supreme Court
clarified that the plain meaning of OCGA 45-1-4 must be given effect
notwithstanding the application of any alternative doctrinesand that such

O.C.G.A. 47-3-141 provides, any person who knowingly makes any false statements or falsifies or
permits to be falsified any records of the Retirement System in any attempt to defraud the
Retirement System, as a result of such act, shall be guilty of a misdemeanor and on conviction shall be
punished by a fine not exceeding $500.00, imprisonment not exceeding 12 months, or both.
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alternate theories may not pre-empt the GWA, as erroneously stated by the Superior
Court and the Court of Appeals. Colon v. Fulton County (Ga. 2013).
5.
Defendant Board of Regents committed fraud by asserting in this action that
Plaintiff did not make a prima facie case for retaliation under OCGA 45-1-4, when
in fact the Regents never at any point considered Plaintiffs allegations or evidence
of retaliation for reporting fraud, waste and abuse in state government. Exhs. 2, 4 &
5: Court of Appeals opinion, p.6; Poitevint Depo; Newsome CBS interview
(admission that whistleblower retaliation was never considered in upholding
Plaintiffs termination by Defendant Board of Regents).
6.
Upon information and belief, moreover, fraud was committed within the
meaning of OCGA 9-11-60(d)(2), as well as evidence tampering under OCGA 1610-94, when Plaintiffs computer was removed from her office at Macon State
College immediately upon her illegal termination in order to eliminate evidence of
knowing falsification of reports by and to a state agency in violation of OCGA 1610-20 & 47-3-141, raising issues never brought before the Court. This fraud related
to knowing falsification of state agency reports has been previously withheld from
public disclosure under a contested Consent Order that has been applied to the
entire file in this action (notwithstanding whether the materials relate to evidence
of knowing falsification of state records in the form of personal leave reports and
resulting fraud in pension calculations), four Oppositions by the Attorney General to
Plaintiffs Motions to Lift the Protective Order (including three oppositions by the

Attorney General that falsely state that the entire file in this action falls under the
contested Consent Order barring release of embarrassing materials and HIPPA),
and four orders denying Plaintiffs motions. See, e.g., Exh 6, Caldon Third Motion to
Lift Protective Order, filed pro se2; Exh 7, Attorney General Opposition.
7.
The Colon case has brought to light both the improper application of the GWA
by the courts, directly relevant to this action, and allegations of evidence tampering
through the improper withholding of relevant evidence and false representations by
the Attorney General in actions against the State in violation of OCGA 16-10-20,
16-10-8, 16-14-1 et seq. &16-10-94.3 See, e.g., Exh 8, Atlanta Journal-Constitution,
Ethics Memo Raises Big Questions, July 19, 2014 (question of improper withholding
of documents by Attorney General).
8.
Similar to the controversy arising out of Colon, failure to make public
disclosure of relevant evidence allows violations of state law under OCGA 45-1-4
& 16-14-14 et seq to continue, and to pretermit Plaintiffs valid claims under these
statutes.

Plaintiff Caldon has proceeded without representation of counsel in this matter since the Court of
Appeals order of July 27, 2011.
3 The Attorney General also represents the Board of Regents, including with respect to the
misrepresentations in the review of Plaintiffs Application for Review and the failure to consider
allegations of retaliation for whistleblowing activity with respect to the reported falsification of
personal leave reports in violation of OCGA 47-3-141.
4 Given the continuing pattern of evidence tampering and knowingly false reports by and to state
agencies related to this action, Plaintiffs Complaint is due to be amended to include claims under the
Georgia RICO Act, OCGA 16-14-1 et seq.which is further reason to set aside the judgment
pursuant to OCGA 9-11-60(d)(2).
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Wherefore, premises considered, Plaintiff moves for the final judgment of July
27, 2011 to be set aside and this case re-opened for proper consideration of the facts
and law pertaining to Plaintiffs claims brought under the GWA.

Respectfully submitted, this 24th day of July, 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) 543-7777 p
(706) 543-1844 f
(706) 207-6982 m

Exhibit 1
IN THE SUPERIOR COURT OF FULTON COUNTY
STATE OF GEORGIA
ELIZABETH DENISE CALDON,
Plaintiff,

v.
BOARD OF REGENTS OF THE
UNIVERSITY SYSTEM OF GEORGIA,
Defendant.

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Civil Action No.

2009-CV-165267

ORDER GRANTING DEFENDANTS MOTION FOR SUMMARY JUDGMENT

This matter having come before this Court on Defendants Motion for
Summary Judgment and following review of the pleadings, briefs, and record of this
case, the Court finds that there is no genuine issue of material fact as to the reason
for Plaintiffs termination. Plaintiffs conduct and her email on September 24, 2008
constitute insubordination as a matter of law, and that insubordination led to her
termination later that day. Therefore, Plaintiff has failed to establish a claim under
the Georgia Whistleblower Act, O.C.G.A. 45-1-4, and summary judgment is
required.
It is hereby ORDERED that judgment be entered in favor of Defendant.
SO ORDERED this 13th day of August, 2010.
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HONORABLE DORIS L. DOWNS
SUPERIOR COURT JUDGE

Exhibit 2

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Exhibit 3

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Exhibit 4, Highlighted Deposition Excerpts of Regent Doreen Stiles Poitevint

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Exhibit 5, CBS report on Caldon Whistleblower case

Former employee: Board of Regents hiding records that

show mismanagement
Posted: Nov 14, 2013 5:15 PM EST
<em class="wnDate">Thursday, November 14, 2013 5:15 PM EST</em>
Updated: Jan 03, 2014 5:27 PM EST
<em class="wnDate">Friday, January 3, 2014 5:27 PM EST</em>

By Jeff Chirico - email

MACON, GA (CBS46) Denise Caldon, of Macon, has repeatedly tried to unseal court records that she
said contains evidence that the Board of Regents has mismanaged a college
campus and employment appeals.

MORE
Continue reading >>
Investigation exposes admission that Regents don't read employee appeals

"It will open a Pandora's box, there are so many issues," said Caldon.
Caldon was fired in 2008 after she said she refused to continue falsifying
documents at the request of her supervisor, David Bell, former president of
Macon State College, now Middle Georgia State College.
"After I put in writing that I would no longer falsify his leave reports, 9 days later I
was terminated after 15 years of dedicated service," said Caldon who worked as
Bell's administrative assistant.
In court papers, Caldon alleged Bell neglected his duties and she covered to
protect him.
"He would never make a full day of work," said Caldon. "It was common
knowledge on campus that we had to limit his meetings. Limit his speaking
engagements."
Caldon unsuccessfully appealed her termination to the Board of Regents, then
filed a whistle blower lawsuit against the Board but lost.
Fulton County Superior Court Judge Doris Downs sealed the evidence in the
case which Caldon has sought to unseal four times. Each time, the office of

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Attorney General objected.

According to Caldon, a source inside the Board of Regents told her the
administration was concerned about losing their own jobs for allowing a president
to serve under his medical condition for three years.
A piece of sealed evidence, CBS Atlanta found in the public file contains a
deposition in which Regent Doreen Poitevint admitted that Regents don't review
appeals filed by terminated employees before voting on them.
"They make the faculty and staff and students believe that their appeals are read
and they are not," said Caldon.
Bill Simon, conservative blogger for Political Vine, wrote a court brief on behalf of
Caldon's push to unseal the records. He said it's hypocritical for Attorney
General Sam Olens to tout his commitment to open records and then prevent the
public from seeing what's in Caldon's court file.
"He's engaging in false, deceptive, misleading legal tactics to cover up
wrongdoing at the Board of Regents," said Simon.
Lauren Kane, Olens' spokesperson said the Attorney General's office stands by
its pleadings and pointed out Caldon's attorney had agreed to a consent order
sealing the record, something Caldon said she never signed off on.
Board of Regents' Vice Chancellor Burns Newsome said an internal
investigation found Bell had done nothing wrong but admitted that the
investigation wasn't documented.
Newsome said he and his staff didn't consider Caldon's claims of
retaliation when recommending the Board of Regents deny her appeal in
2008.
Since being fired, Caldon said she has lost her home, her savings and her
medical insurance but continues to fight to protect the jobs of others.
"I just wanted them to fix what they've been doing to all the faculty, staff and
students. They need to right a wrong," said Caldon.
Copyright 2013 WGCL-TV (Meredith Corporation). All rights reserved.

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Exhibit 6, Motion to Lift Protective Order

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Exhibit 7, Attorney General Opposition to Motion to Lift Protective Order

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Exhibit 8
Posted: 12:00 a.m. Saturday, July 19, 2014

Ethics memo raises big questions

COMMENT(4)
12 174 72 304

Related
Interactive timeline: Gov. Nathan Deal's ethics case
Georgia Personnel Rules Governing Political Activity
Georgia Campaign Law Governing Political Activity
Deal: Staffs contact with ethics chief was harmless
Holly LaBerges memo and the queasy politics of ethics
Sam Olens on the hot seat over Holly LaBerge memo
Olens defends decision on ethics memo as Deal and Carter spar
Deal: Why were we all in the dark on bombshell ethics memo?
Ethics chief claims Deal aides pressured her, threatened agency
PDF: Read the memo accusing Gov. Deal's aides of pressuring the state ethics
chief

By Aaron Gould Sheinin and James Salzer

The Atlanta Journal-Constitution
State ethics commission director Holly LaBerge was taking a vacation
from a job shed held less than a year when a text message popped
into her personal cellphone from Gov. Nathan Deals chief of staff.
So, since you are at the beach, with your feet in the sand and
probably something cold to drink. Does this mean we can resolve all
the DFG (Deal for Governor) issues by Monday?:), Chris Riley wrote
in a message sent July 16, 2012, concluding his text with the
emoticon for smiley face.
No one is smiling anymore. The seemingly innocent text led to a
phone conversation that has rocked state government and threatened
the credibility of top officials, including Attorney General Sam Olens.
It has also restoked an election-year fire that the governor had hoped
was all but extinguished over the commissions handling of
complaints against his 2010 campaign.
In a memo obtained by The Atlanta Journal-Constitution last week,
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LaBerge said Deals chief counsel pressured her to settle the cases
without a hearing and threatened to withhold rule-making authority
from the commission, a top priority for the agency.
The memo has raised pointed questions about the conduct of
LaBerge, the governors staff and Olens, who received a copy of the
memo but did not turn it over to former ethics staff members suing the
state.
Here are five big questions the memo raises:
1. Was it proper for chief counsel Ryan Teague and Riley to
contact LaBerge on an issue involving complaints against the
governors campaign?
State law and personnel rules prohibit state employees from
engaging in political activities at work or using state resources to aid
campaigns. The personnel rules specifically prohibit employees from
using coercive political pressure.
In her memo, LaBerge said she felt pressured by Teague to make
the complaints go away. At the time, the commission was
investigating a series of complaints against Deals 2010 campaign for
governor, centering on how he raised and spent campaign funds,
including how he paid attorneys fees and for air travel.
State and local officials have frequently been fined by the state ethics
commission over the past 20 years for doing campaign work or using
public resources for campaigns. Local officials are often accused of
using their office or government resources to push sales-tax or bond
votes. State staffers have been used to send out invitations to
fundraisers, and they regularly post tweets with Twitter handles like
Stone4Georgia or Beachforsenate.
When you are in a state facility and on state time, you have a duty to
the public, said Teddy Lee, a former longtime director of the ethics
commission. State employees dont always see it that way.
Deal vigorously defends his staffers, saying they were merely
contacting LaBerge to figure out the schedule for an upcoming
hearing on his case. Aides said Deal was heading out of town and
LaBerge had not returned messages from the governors campaign
lawyer.
It was two years that this had been going on. And they were simply
urging the staff to proceed in a timely fashion rather than postpone it
again, Deal said.
Neither Riley nor Teague responded to requests for on-the-record
comment.
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This isnt the first time an issue has been raised regarding Riley,
Deals longtime aide. Congressional investigators in 2010 accused
Deal, who had recently resigned his U.S. House seat, of violating
ethics rules by using his office to protect a lucrative state program
that earned his company big money.
The Atlanta Journal-Constitution found that Riley used congressional
email to contact state officials to discuss the plans and to set
appointments for Deal to meet with them.
2. Should LaBerge have turned over her memo earlier?
If LaBerge was concerned about political pressure from the
governors staff, as she now claims, she could have notified Olens or
even the U.S. attorney, who could have investigated them. Instead,
she kept her concerns confined to a handful of commission members
and did not disclose them to the news media.
LaBerge said she drafted the memo on July 17, 2012, after the
commissions chairman, Kevin Abernethy, suggested she write up her
contact with Teague and Riley.
Nine days later, the AJC sent LaBerge a request under the state
Open Records Act for access to and copies of all records, including
interviews, audits, emails, faxes and any and all documents including
case files related to two cases against Deal.
LaBerge released thousands of pages of documents, but not her
memo. Reporters from the AJC noticed some documents were
missing. It wasnt until after the AJC asked Olens to intervene that
LaBerge released thousands of additional pages. But again, the
memo wasnt included.
The memo should have been released in response to the submitted
open records request, said Hollie Manheimer, the executive director
of the Georgia First Amendment Foundation. Exceptions to
Georgias general rule of releasing public information are very, very
narrow, and none would have applied in response to this request.
Olens enforces the Open Records Act, and the AJC has had to go to
him on other occasions to get LaBerges agency to release public
documents. And when the AJC asked for the memo from LaBerge
last week, she referred the request to her private lawyer, Lee Parks.
LaBerge also kept the memo from Olens for about a year, depending
on whose version of events you believe. LaBerge said she gave the
memo to Olens staff in June 2013; Olens aides, however, said they
did not receive it until August or September 2013.
The timing is critical. In June 2012, a month before LaBerge
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memorialized her contact with the governors staff, two former ethics
commission employees filed whistleblower lawsuits against the state,
alleging that they were pushed out of the agency for attempting to
investigate the campaign complaints against Deal.
The lawsuits dragged on through months of motions and discovery.
But LaBerges memo was not turned over to the two plaintiffs, former
commission director Stacey Kalberman and her top deputy, Sherilyn
Streicker.
3. What should Olens have done with the memo once he got it?
From the beginning, Olens was in a tight spot. As attorney general he
was charged with enforcing open records laws. As the states top
lawyer, he was also responsible for defending LaBerge and the
commission against the whistleblower lawsuits.
Olens says the memo did not meet the demands for documents
made by the plaintiffs lawyers and did not have to be turned over.
Specifically, Olens said it didnt meet Kalbermans request for
correspondence or for Streickers demand for documents
concerning the violation of any law, rule, or regulation.
Many outside attorneys disagree.
Bob Wilson, a former DeKalb County district attorney who has
served as a special prosecutor for the state, said the fact that
LaBerges memo references text messages from Teague and
Riley clearly meets the threshold of correspondence.
Olens argument, Wilson said, will not hold water. It is ice that
will not carry his weight. This document should have been
produced.
But Ben Easterlin, a partner at King & Spalding in Atlanta, said
Olens made the right decision.
Considering the context and the timing of the request and the
specific wording of the request, I thought the memo would not
be responsive to any of the discovery documents that were
presented by the Kalberman and Streicker cases, Easterlin
said.
Although Olens determined the memo was not correspondence,
LaBerge copied text messages from her phone and pasted them into
the document. Whether Olens or his staff asked LaBerge to produce
those texts separately is unknown.
Olens has said he cant discuss the situation further because
LaBerge is technically still his client and she and her attorney have
refused to waive attorney-client privilege.
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Ultimately, the Attorney Generals Office gave the memo to the AJC
last week after it filed an Open Records Act request.
4. Should Olens or other state officials have called for an
independent investigation, and should they do so now?
Olens said he shared the memo with his chief prosecutor, who
concluded that no state laws had been broken.
State law allows the attorney general to designate a private lawyer as
a special assistant attorney general to handle a specific case. This
happens often with civil cases. Those lawyers, however, report to,
and are paid by, the attorney general.
Could any attorney Olens chooses, supervises and pays be
considered independent? Nothing in state law allows Olens to hand a
case off to a local district attorney, for example, and unlike federal
law, there is no mechanism in state law for appointing a special
independent prosecutor.
There are, however, code sections in state law that allow the
governor to appoint special prosecutors, as then-Gov. Sonny Perdue
did when he hired Wilson and former Attorney General Mike Bowers
to investigate the Atlanta Public Schools cheating scandal.
In this situation, however, would Deal who steadfastly claims he
and his office have done nothing wrong want an independent
investigation, and how could he ensure any investigator he named
would be independent?
Finally, state law allows the General Assembly to also conduct
investigations with the same power as the attorney general. The code
section, however, does not spell out how the Legislature would
decide to do that, and lawmakers dont return to session until
January.
Whether or not a new investigation is launched, investigations are
already being conducted by the State Auditors Office, the state
Inspector General and the FBI.
5. Who benefited from the memo staying hidden?
The memos concealment may have prevented Deal and/or his staff
members from having to testify in the whistleblower lawsuits,
including one that ultimately went to trial earlier this year.
The judge overseeing the case rejected a motion to have Deal or his
staff testify in the cases. A crucial factor in the judges ruling was that
the plaintiff had not demonstrated that the men engaged in any type
of coercion.
Both former employees prevailed in their cases; Kalberman was
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awarded $1.15 million after a jury sided with her, and Streicker settled
her case for $1 million. Two others former employees settled for
nearly $500,000 each. But attorneys for the four are now calling foul.
Had it remained hidden, Deals re-election would have been helped
by keeping a potentially embarrassing memo out of public view.
Legally, Olens and the state benefited from not having the issue
come up in the trial. LaBerge and her attorney have said the memo
would have helped the defense, not the plaintiffs.
Now that its become public, the memo could prove a springboard to
reopen the court settlements and lead to legal complaints against
Olens, his staff and/or Teague.
Deal and LaBerge also now say the argumentative nature of the
phone call with Teague, as well as LaBerges conclusion that Teague
threatened the agency, shows the governors office didnt control her.
Teague, LaBerge wrote, wanted her to agree to a $1,500 settlement
with no admission of violations. She said she had, the day before,
offered Deals private attorney a $5,400 settlement. It was then that
Teague allegedly said it was not in the agencys best interest for the
cases to go to a hearing.
Deal ultimately agreed to pay $3,350 in fees for technical defects in
his disclosures.
KEY PLAYERS
Nathan Deal
The governor faced complaints that he personally profited from his campaigns
aircraft rentals from a company he partly owned, that he illegally used state
campaign funds for legal bills related to a federal ethics investigation when he
was a member of Congress and that he accepted campaign contributions that
exceeded limits. The state ethics commission cleared Deal of major ethics
violations in July 2012 while finding he made technical defects in a series of
personal financial and campaign finance reports. Deal agreed to pay fees totaling
$3,350.
Holly LaBerge
Before her appointment as executive director of the state ethics commission in
August 2011, she was a lobbyist for the state Public Defenders Standards
Council. She reportedly said that the governor owed her after the commission
cleared him of major ethics violations in July 2012. Last week, it was revealed
that she wrote a memo and sent it to the state Attorney Generals Office that said
that in the week before he settlement she had felt pressured by top-level aides to
Deal to quickly and quietly bring an end to the case against the governor.
Chris Riley
LaBerge alleges in her memo that Riley, the chief of staff to Gov. Nathan Deal,

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sent a text to her personal phone while she was on vacation the week before the
Deal case was settled that stated: So since you are at the beach, with your feet
in the sand and probably something cold to drink. Does this mean we can resolve
all of DFG (Deal for Governor) issues by Monday?:) Riley also was a founding
member of HRPW Investments, a Gainesville partnership that owns the airplane
Deal used in his 2010 campaign. Deals private business, Gainesville Salvage &
Disposal, also was a co-owner of the plane through its subsidiary, North Georgia
Aviation. Riley later dropped out of the partnership but was the pilot of the plane
when it carried Deal throughout the state during the campaign.
Ryan Teague
LaBerge alleges in her memo that while on vacation she received a phone call
from Teague, the governors chief counsel. She claims Teague said, It was not
in the agencys best interest for these cases to go to a hearing nor was it in
their best political interest either. According to the memo, Teague said the ethics
commission might not recover the power to create its own regulations and
interpret the law a power taken away from the commission in 2012 if the
governors case was not settled without a public hearing. Teague also has been
identified by the governors office as the person who called LaBerge in 2011 to
see whether she would be interested in heading the commission before the
position came open.
Stacey Kalberman
The former executive director of the state ethics commission was forced out of
the position in June 2011 after then-Chairman Patrick Millsaps said a looming
budget crisis for the commission had required him to cut her salary by 30
percent. Prior to that, Kalberman said she twice asked Millsaps to sign
subpoenas involving the commissions investigation into the complaints against
Deal. Kalberman filed a whistleblower suit against the state in June 2012, and in
April a jury ruled she was forced from her job for aggressively investigating Deal.
Kalberman was awarded $1.15 million.
Sherilyn Streicker
Streicker was Kalbermans top assistant and the investigator in the complaints
against Deal. Her position was eliminated as a result of the commissions
financial difficulties, then ethics commission Chairman Patrick Millsaps said. Like
Kalberman, Streicker filed a whistleblower suit against the state in June 2012.
Two years later, the state settled the case, awarding her $1 million.
Elisabeth Murray-Obertein
Murray-Obertein was hired by LaBerge to serve as the ethics commissions staff
attorney. In sworn testimony leading up to Kalbermans case, Murray-Obertein
claimed that LaBerge intervened in Deals case and bragged that Deal owed her
after his case was settled. Murray-Obertein was dismissed from her position in
January after a Capitol police officer said he smelled alcohol on her on the
morning of a workday. During Kalbermans trial, she testified that LaBerge told
her that commissioners felt Kalberman and Streicker were delving into the
(Deal) investigation too deeply. Murray-Obertein threatened to sue the state. In
June, the state settled with her for $477,500.
John Hair

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Hair is a former information technology specialist with the ethics commission who
claims he was fired for frivolous reasons after he refused to remove documents
from Deals ethics case file. He said he blew the whistle to reclaim his
reputation. Hair filed a whistleblower suit against the state in March. In June, the
state agreed to pay him $410,000 to settle the suit.

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CERTIFICATE OF SERVICE
Undersigned counsel hereby certifies that this Motion has been served on
opposing counsel, this 24th day of July, 2014, as follows:
Samuel S. Olens
Annette Cowart
Dennis R. Dunn
Kathleen T. Godsden
Laura W. McDonald
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
Bogart, GA 30622
(706) 543-7777 p
(706) 543-1844 f
(706) 207-6982 m

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