IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF GEORGIA
VALDOSTA DIVISION

___________________________________

)

WILLIE FLOYD WILLIAMS, JR.,

)

MICKLE JERMAINE JACKSON,

)

)

Plaintiffs,

)

)

v.

)

)

CLINCH COUNTY, Georgia,

)

)

WINSTON PETERSON,

)

Sheriff of Clinch County, in his

)

official and individual capacities,

)

)

SISSY SUGGS,

)

Deputy Sheriff of Clinch County,

)

in her official and individual

)

capacities,

)

)

)

Defendants.

)

___________________________________ )

CIVIL ACTION No. ________________
CLASS ACTION JURY TRIAL DEMANDED

COMPLAINT

COME NOW plaintiffs WILLIE FLOYD WILLIAMS, JR. and MICKLE

JERMAINE JACKSON (collectively, “Plaintiffs”), on behalf of themselves and

the class alleged herein, by and through their attorneys, and file this Complaint

against defendants CLINCH COUNTY, WINSTON PETERSON, and SISSY

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SUGGS (collectively, “Defendants”). In support thereof, Plaintiffs respectfully state as follows:
PRELIMINARY STATEMENT 1.
This is an action to stop Defendants from an abuse of their authority, through which they have been charging inmates at the Clinch County Jail in Homerville, Georgia (the “Jail”) fees for “room and board.” Clinch County, its Sheriff, and his Deputies have been forcing inmates -- even those inmates who have not been convicted of a crime -- to pay charges set by Defendants. Defendants threaten to incarcerate those who have been released but refuse to pay these fees. Without any statutory authority or oversight by a court, Defendants charge often poor inmates exorbitant fees -- in some cases over $4,000 -- for room and board. This is far more than many defendants can pay. Even when an inmate at the Jail is released by the court on bond, Defendants often will not allow the individual to leave unless he signs a promissory note that states he must make weekly payments or face re-incarceration.
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2. This practice is illegal. Defendants have no authority to impose charges on inmates. Defendants have no authority to coerce inmates to sign promissory notes. Through this pervasive practice, Defendants have taken substantial sums of money from Plaintiffs and other inmates.
3. Defendants’ policy and practice of requiring pre-trial detainees to pay room and board fees violates numerous provisions of the U.S. Constitution and the Georgia Constitution. Further, this policy and practice violates Georgia law -- and quite simply constitutes conversion of Plaintiffs’ money. Plaintiffs assert claims for violation of their civil rights under 42 U.S.C. § 1983, conversion, false imprisonment, and violation of the Georgia Constitution. In addition, they seek a declaratory judgment ruling that the promissory notes are not enforceable.
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4. Plaintiffs bring this putative class action on behalf of themselves and all past, current, and future pre-trial detainees at the Clinch County Jail who have been or will be charged for costs of their incarceration in violation of law. Plaintiffs respectfully ask this Court to preliminarily and thereafter permanently enjoin Defendants from charging inmates fees for room and board or other fees that are not permitted by law. Plaintiffs also ask this Court to order Defendants to return money that Defendants have wrongfully collected from Plaintiffs and other class members.
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PARTIES Plaintiffs
5. Plaintiff Willie Floyd Williams, Jr. is resident of Homerville, Georgia. Mr. Williams was arrested on or around October 3, 2003 and spent approximately nine months in the Clinch County Jail before being released on bond on June 15, 2004. Before Mr. Williams was permitted to leave the Jail, despite having posted bond and being free to leave under the law, Deputy Sheriff Sissy Suggs advised him that he must first sign a promissory note agreeing to pay room and board costs of $4,608. The promissory note included a statement advising Mr. Williams that he would be re-incarcerated if he failed to make his payments. To date, Mr. Williams has paid approximately $140 towards the cost of the $4,608 the Defendants claim he owes the County.
6. Mickle Jermaine Jackson is a resident of Homerville, Georgia. Mr. Jackson was arrested on February 6, 2004 and spent approximately three months incarcerated at the Jail before he was released on bond on April 26, 2004. Mr. Jackson was charged approximately $12,415000 for Jail costs for these three months. Defendants have ordered Mr. Jackson to pay the County $100 per month towards his “jail bill.”
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Defendants 7.
Defendant Clinch County is responsible for setting the customs, policies, and practices at the Clinch County Jail, and has received “room and board fees” that were unlawfully collected from Plaintiffs by the Clinch County Sheriff and his Deputies. Upon information and belief, Clinch County Jail officials have deposited the room and board fees collected from Plaintiffs into an account earmarked “Jail Board Reimbursements” in the County treasury. (See Plaintiffs’ Exhibit 1). Upon information and belief, Clinch County has caused, created, authorized, condoned, ratified, approved, and/or knowing acquiesced in the policy of charging Jail inmates for the cost of incarceration, as described in this Complaint.
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8. Defendant Winston Peterson is the Sheriff of Clinch County and, upon information and belief, is a resident of Clinch County, Georgia. As Sheriff, Defendant Peterson is directly responsible for the daily management, administration, and operation of the Clinch County Jail. In Defendant Peterson’s capacity as Sheriff, he has caused, created, participated in, authorized, condoned, ratified, approved, and/or knowingly acquiesced in the policy of charging Jail inmates for the cost of incarceration, as described in this Complaint. Sheriff Peterson is sued in his official and individual capacities.
9. Defendant Sissy Suggs is the Deputy Sheriff of Clinch County and, upon information and belief, is a resident of Clinch County, Georgia. In Defendant Suggs’ capacity as Deputy Sheriff, she has caused, created, participated in, authorized, condoned, ratified, approved, and/or knowingly acquiesced in the policy of charging Jail inmates for the cost of incarceration, as described in this Complaint. Deputy Sheriff Suggs is sued in her official and individual capacities.
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JURISDICTION AND VENUE 10.
This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. §§ 1331 and 1343 because the action arises under and is brought under the Civil Rights Act of 1871, 42 U.S.C. § 1983 and the Fourteenth Amendment to the United States Constitution. The Court has supplemental jurisdiction over Plaintiffs’ state law claims under 28 U.S.C. § 1367 because they are so related to the federal claims that they form part of the same case or controversy under Article III of the United States Constitution.
11. Venue is proper in this District under 28 U.S.C. § 1391(b)(1) because at least one Defendant resides in this judicial district. This District also is an appropriate venue for this action under 28 U.S.C. § 1391(b)(2) because all or at least a substantial part of the events or omissions giving rise to the claims asserted herein occurred in this judicial district.
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FACTUAL BACKGROUND 12.
Willie Floyd Williams, Jr. Plaintiff Willie Floyd Williams, Jr. was arrested on or about October 3, 2003
and spent approximately nine months in the Clinch County Jail. Through his court-appointed attorney, Mr. Williams applied for bond on or about May 10, 2004, and on June 15, 2004, was permitted to bond out of the Jail. Before Mr. Williams was released, however, Sheriff Peterson advised him that he owed the Jail money and directed him to see Deputy Sheriff Sissy Suggs. Deputy Sheriff Suggs told Mr. Williams he owed the Jail $4,608 to cover his Jail costs. Deputy Sheriff Suggs presented Mr. Williams with a promissory note, which he was directed to sign as a condition of being released from Jail. (See Exhibit 2). The promissory note described the amount Mr. Williams purportedly owed the Jail and stated that if he failed to pay such Jail costs, he would be incarcerated. The note states, in relevant part:
I Willie Williams am agreeing to pay the Clinch County Jail $20.00 per week on jail cost that I owe in the amount of $4608.00, to which I have paid $100.00[.] The new balance will be $4508.00. I will start paying this amount on 6/25/04. I am aware that if I fail to keep this agreement I will be incarcerated in the Clinch County Jail.
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13. After signing the promissory note and giving $100 to Defendant Suggs, Mr. Williams was released from the jail.
14. On July 6, 2004, Mr. Williams gave Defendant Suggs an additional $20 cash payment toward his debt. (See Exhibit 3). On or around August 3026, 2004, Mr. Williams received a post card from the Sheriff asking him to come to the Sheriff’s Department within three working days of receiving the notice. (See Exhibit 4). On September 3, 2004, Mr. Williams gave Ms. Suggs a third cash payment of $20. (See Exhibit 5).
15. Mr. Williams is still awaiting trial on the charges for which he was arrested in October 2003. He has not been convicted of any crime.
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16. Mr. Williams is indigent. The Superior Court of Clinch County determined he was too poor to afford a lawyer to represent him in his criminal case and appointed an attorney to represent him. Mr. Williams hopes to be re-hired as a forklift operator by his previous employer, where he worked for 10 years before being arrested on the charges that he is facing. At present, however, Mr. Williams has no income, has continuing child support obligations and is unable to pay the $4,608000 it is claimed he owes the Jail.
17. Mickle Jermaine Jackson
Mickle Jermaine Jackson was arrested on February 6, 2004 and was incarcerated for approximately three months at the Jail before being released on bond on April 26, 2004. Before being released, Deputy Warden Sissy Suggs advised Mr. Jackson he owed the Jail $1,415 for “room and board.” Jail officials would not allow Mr. Jackson to leave the Jjail until Mr. Jackson’s cousin, Lonnie Cooper, came to the Jail with a cash payment$113 in cash. Since being released on bond, Mr. Jackson has been ordered to pay the Jail $100 per month on the first of each month until he has repaid the Jail in full for his Jail costs. Attached to this Complaint as Exhibit 65 are two receipts showing that Mr. Jackson has paid $200 toward the cost of his jail stay.
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18. Mr. Jackson is currently awaiting trial. He has not been convicted of the crime with which he has been charged.
19. Mr. Jackson is indigent. The Superior Court of Clinch County determined that Mr. Jackson was too poor to afford a lawyer to represent him in his criminal case and appointed an attorney to represent him. Mr. Jackson currently lives off of a fixed income of $562 per month in Supplemental Security Income. Other Former Pre-Trial Detainees
20. The experiences of Mr. Williams and Mr. Jackson are not isolated instances. It is Defendants’ policy and practice to charge Jail inmates – including pre-trial detainees – for s -- for the cost of room and board. The following are just a few other examples of this policy and practice: (a) Darius Dorsey was arrested in May 2004 and spent the night in the
Jail. The following day, the charges against Mr. Dorsey were dismissed. Despite this, Mr. Dorsey was required to pay the Jail $36 for the cost of room and board. (b) James Smith spent approximately one week in the Jjail in 2003 for allegedly failing to pay child support. He was released from the Jail
25

on a Friday afternoon after a determination was made that he was too poor to pay child support. Later the same day, sheriff’s deputies arrived at Mr. Smith’s house, picked him up, and re-incarcerated him at the Jjail until he paid his $109 “food bill.” Mr. Smith’s mother came to the Jjail the next morning with the $109 and Mr. Smith was released. (c) Kenneth Brown was arrested in March 2004. Mr. Brown bonded out of the Jjail the day after his arrest. Before he was permitted to leave the Jail, however, he was required to pay $18 for the cost of room and board. Mr. Brown had yet to be convicted of the crime with which he was charged. Fredrick Caussey was arrested on August 4, 2004. He spent three days in the Clinch County Jail before being released on bond on August 8, 2004. Before being permitted to leave the Jjail, Mr. Caussey was required to pay $57 for the cost of room and board. Mr. Caussey has not been convicted of the offense for which he was charged. (d) Jeanne McGhee was arrested in March 2003. She was incarcerated in the Jail for approximately four days before pleading guilty and being releasedsentenced to a term of probation. When Ms. McGhee was
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released, she was charged $90 for room and board. Dominique Raysor was arrested on July 28, 2004. He spent approximately three months in the Jail before pleading guilty on October 15, 2004. Following his guilty plea, the Assistant District Attorney assigned to Mr. Raysor’s case told Mr. Raysor that he owed over $1,440 in “jail costs.” Mr. Raysor has paid $85 toward the Jail costs. Defendants’ Conduct Is Unauthorized And Illegal
5. There is no statutory or other legal authority for Defendants to charge Plaintiff’s for the cost of room and board. This policy and practice constitutes unlawful conduct deliberately undertaken by a County and its officials.
6. Defendants’ policy and practice of collecting room and board fees has not been authorized by the Georgia legislature.
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CLASS ACTION ALLEGATIONS 7.
Plaintiffs bring this class action pursuant to Rules 23(a) and (b)(2) of the Federal Rules of Civil Procedure on their behalf and on behalf of a class similarly situated and affected during the pendency of this lawsuit and in the future. The class is defined as all past, current, and future pre-trial detainees at the Clinch County Jail who have been or will be charged for the cost of incarceration in violation of law.
8. The members of this class are so numerous that their joinder is impractical. The class consists of an unknown number of past inmates, about 32 current inmates, and such future inmates who will be incarcerated at the Jail.
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9. The conditions and practices challenged in this action apply with equal force to the named Plaintiffs and all members of the class so that the claims of the named Plaintiffs are typical of those of the class. All class members are past, current, or future inmates at the Clinch County Jail. All class members have been or will be, absent this Court’s intervention, charged for the cost of incarceration, in violation of law and deprived of their liberty without due process of law upon any alleged failure to pay. All class members will continue to be subject to such conditions absent the requested relief.
10. The named Plaintiffs will fairly represent and adequately protect the interests of the class as a whole. They possess the requisite personal interest in the subject matter of the lawsuit and possess no interests adverse to other class members. Plaintiffs are representative of the class of all persons who have been or will be charged for the cost of incarceration at the Jail in violation of law.
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11. Plaintiffs are represented by counsel who are experienced in class action litigation involving the rights of prisoners. The named Plaintiffs and the class members are represented by attorneys at King & Spalding LLP, a law firm with extensive experience in complex class action litigation as well as attorneys at the Southern Center for Human Rights, a privately funded, nonprofit organization with extensive experience in complex class action litigation involving prisoners’ rights. Plaintiffs’ counsel have the resources, expertise, and experience to effectively prosecute this action.
12. The questions of fact and law common to the class as a whole concern the constitutionality and lawfulness of the policy and practice of charging Clinch County Jail pre-trial detainees for the cost of incarceration. For example, there are common questions of law and fact concerning the lawfulness of each of the following of Defendants’ policies and practices: (a) the policy and practice of requiring inmates to pay a per diem charge for the cost of incarceration regardless of their guilt or innocence or ability to pay; (b) the policy and practice of holding at the jail inmates who are entitled to release until they sign a promissory note stating that he or shethey will
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pay the amount owed; (c) the policy and practice of threatening to re-incarcerate without any due process protections former jail inmates who fail to make payments on their “jail bill;” (d) the policy and practice of collecting installment payments; (e) the policy and practice of holding of such illegally collected funds in the county treasury.
13. Defendants, in creating and enforcing the jail reimbursement policy, have acted in a way generally applicable to the class the Plaintiffs represent, thereby making preliminary and permanent injunctive relief and corresponding declaratory relief appropriate for the class as a whole pursuant to F.R.C.P. 23(b)(2).
CLAIMS FOR RELIEF COUNT ONE
INJUNCTIVE RELIEF 14.
Plaintiffs incorporate herein and re-allege, as if fully set forth herein, the allegations of the preceding paragraphs.
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15. Plaintiffs seek a preliminary and thereafter a permanent injunction to prevent Defendants from charging Jail inmates for the cost of incarceration in violation of federal law and Georgia law. See infra Counts Two through Six.
16. Defendants’ conduct is not authorized by any Georgia law. Defendants’ conduct violates 42 U.S.C. § 1983 and Georgia law.
17. Defendants’ conduct is likely to continue unless preliminarily and thereafter permanently enjoined. Defendants’ conduct is causing Plaintiffs immediate irreparable harm that cannot be remedied by the award of money damages. Plaintiffs have no plain, adequate, or complete remedy at law to redress the wrongs described herein. If Defendants’ are not enjoined, they are likely to continue irreparably harming Plaintiffs.
18. The balance of the hardships and public policy strongly favor the Court entering a preliminary injunction and thereafter permanently enjoining Defendants’ unlawful policy and practice of collecting fees for “room and board” from inmates at the Jail.
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19. Plaintiffs seek an Order from this Court preliminarily, and thereafter permanently, enjoining Defendants from collecting fees for room and board from pre-trial detainees at the Jail or collecting other fees not permitted by law.
20. Plaintiffs also seek an order from this Court requiring Defendants to reimburse the money wrongfully taken from Plaintiffs and other class members.
COUNT TWO VIOLATION OF PLAINTIFFS’ CIVIL RIGHTS
UNDER 42 U.S.C. § 1983 21.
Plaintiffs incorporates herein and re-alleges, as if fully set forth herein, the allegations of the preceding paragraphs.
22. Defendants have violated Plaintiffs’ right to due process of law under the Fourteenth Amendment to the Constitution of the United States, as applied to the states and enforced through 42 U.S.C. § 1983, by requiring Plaintiffs to pay the cost of room and board for a pre-trial and/or pre-conviction jail stay.
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23. By requiring Plaintiffs who have not been convicted of any crime to pay the cost of room and board for a pre-trial and/or pre-conviction jail stay, Defendants are violating the Fifth Amendment’s prohibition on takings without just compensation, as applied to the states and enforced through 42 U.S.C. § 1983.
24. By deliberately requiring Plaintiffs to pay the cost of room and board for a pre-trial and/or pre-conviction jail stay before release, Defendants have deprived Plaintiffs of their liberty without due process of law, falsely imprisoned Plaintiffs in violation of their constitutional rights, deprived Plaintiffs of equal protection of the law, and imposed an unconstitutional ex post facto law.
25. By requiring Plaintiffs who have not been convicted of any crime to pay the cost of room and board for a pre-trial and/or pre-conviction jail stay, Defendants have deprived Plaintiffs of their property without due process in violation of Plaintiffs’ constitutional rights.
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26. By requiring Plaintiffs who have not been convicted of any crime to pay the cost of room and board for a pre-trial and/or pre-conviction jail stay, Defendants have deprived Plaintiffs of their substantive due process rights under the Constitution.
27. In each and every instance set forth above, Defendants acted intentionally, or at least recklessly, in disregard of Plaintiffs’ constitutional rights. Defendants knew or should have known that confiscating funds without a conviction, without a court order, without notice or hearing, and without any statutory authority violated Plaintiffs’ constitutional rights.
28. The actions set forth above were taken by Defendants under color of state law.
29. As a direct and proximate result of Defendants’ illegal policy and practice, Plaintiffs were wrongfully deprived of money that belonged to them.
30. As a direct and proximate result of Defendants’ illegal policy and practice, Plaintiffs were wrongfully deprived of their liberty.
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31. Defendants are jointly and severally liable for the violations of Plaintiffs’ rights, and the harm they suffered as a result, because each Defendant either personally participated in the actions or failures to act, act; or implicitly authorized, approved, or knowingly acquiesced or failed to remedy the wrongs at issue.
32. Defendants’ above-described actions were willful, deliberate, and malicious, and should be punished and deterred by an award of punitive or enhanced damages as permitted by law and in an amount to be determined at trial.
COUNT THREE CONVERSION
33. Plaintiffs incorporates herein and re-alleges, as if fully set forth herein, the allegations of the preceding paragraphs.
34. Defendants took and converted to their own use the funds set forth above from Plaintiffs.
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35. Defendants’ above-described actions were willful, deliberate, and malicious, and should be punished and deterred by an award of punitive damages as permitted by law and in an amount to be determined at trial.
COUNT FOUR FALSE IMPRISONMENT
36. Plaintiffs incorporates herein and re-alleges, as if fully set forth herein, the allegations of the preceding paragraphs.
37. Defendants’ detention of Plaintiffs in order to coerce the execution of promissory notes or payment of fees for room and board constitutes detention or imprisonment without authorization and in violation of law.
38. Defendants’ actions constitute false imprisonment under Georgia law.
39. Defendants’ above-described actions were willful, deliberate, and malicious, and should be punished and deterred by an award of punitive damages as permitted by law and in an amount to be determined at trial.
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COUNT FIVE VIOLATION OF THE GEORGIA CONSTITUTION
40. Plaintiffs incorporate herein and re-allege, as if fully set forth herein, the allegations of the preceding paragraphs.
41. The Georgia Constitution states: “No person shall be compelled to pay costs in any criminal case except after conviction on final trial.” See Ga. Const. Art. I, § 1, ¶ XXIV. In contravention of the Georgia Constitution, Defendants are compelling Plaintiffs to pay for the cost of incarceration before they have been found guilty of any crime.
COUNT SIX DECLARATORY JUDGMENT
42. Plaintiffs incorporate herein and re-allege, as if fully set forth herein, the allegations of the preceding paragraphs.
43. Defendants have directly and/or indirectly forced Plaintiff Williams to sign a promissory note that purports to require him to make payments to one or more Defendants.
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44. Pursuant to 28 U.S.C. § 2201, Plaintiff Williams seeks a declaration by the Court that the promissory note is unenforceable. The promissory note is unenforceable because, among other things, Plaintiff Williams was coerced to enter it, it lacks consideration, and it is unconscionable.
45. Plaintiff Williams will be adversely affected if Defendants continue to enforce the promissory notes. The controversy between Plaintiff Williams and Defendants is definite and concrete. An actual controversy exists between the parties as to Defendants’ enforcement of the promissory note and whether Defendants will seek to incarcerate Plaintiff Williams for failing to pay the amounts allegedly due under the promissory notes.
PRAYER FOR RELIEF WHEREFORE, Plaintiffs respectfully prays that this Court: 1. Assume jurisdiction over this action; 2. Determine by Order pursuant to Rule 23 of the Federal Rules of Civil
Procedure that this action be maintained as a class action; 3. Order trial by jury on all claims so triable; 4. Enter judgment in favor of Plaintiffs;
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5. Enter a preliminary injunction and thereafter a permanent injunction enjoining Defendants from collecting fees for room and board from pre-trial detainees at the Jail or collecting other fees not permitted by law;
6. Order that Defendants return all money taken from Plaintiffs in violation of law;
7. Declare the promissory note that purports to bind Plaintiff Williams null and void;
8. Award Plaintiffs the costs of this lawsuit and reasonable attorneys’ fees pursuant to 42 U.S.C. § 1988;
9. Award enhanced or punitive damages as permitted by law and in an amount to be proven at trial;
10. Order such other and further relief as this Court may deem just and proper.
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Respectfully submitted this ___ day of November, 2004.
KING & SPALDING LLP
_____________________ Courtland Reichman
(Ga. Bar No. 599894) Stephen B. Devereaux (Ga. Bar No. 219791) 191 Peachtree Street Atlanta, Georgia 30303-1763 Tel: (404) 572-4600 Fax: (404) 572-5145
___________________________ Stephen B. Bright (Ga. Bar No. 082075) Sarah Geraghty
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(Ga. Bar No. 291393) Southern Center for Human Rights 83 Poplar Street, N.W. Atlanta, Georgia 30303-2122 Tel: (404) 688-1202 Fax: (404) 688-9440 Attorneys for Plaintiffs
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 IN THE UNITED STATES DISTRICT coufi1ecl ql. $0 f ~M

FOR THE MIDDLE DISTRICT OF GEORGIA Y 19 ?I

VALDOSTA DIVISION

DD££~PUmTY~CLEteR~K~Ut"\..l;~&.~_ MIDDlE Dlm',ir O~EOR,ifURT

)

WILLIE FLOYD WILLIAMS, JR.,

)

MICKEL JERMAINE JACKSON,

)

)

Plaintiffs,

)

)

v.

)

)

CLINCH COUNTY, Georgia,

)

)

WINSTON PETERSON,

)

Sheriff of Clinch County, in his

)

official and individual capacities,

)

)

PATRICIA SUGGS,

)

Deputy Sheriff of Clinch County,

)

in her official and individual

)

capacities,

)

)

)

Defendants.

)

--------------------------)

CIVIL ACTION No.7:04-CV-124
CLASS ACTION
JURy TRIAL DEMANDED

AMENDED COMPLAINT

COME NOW plaintiffs WILLIE FLOYD WILLIAMS, JR. and MICKEL

JERMAINE JACKSON (collectively, "Plaintiffs"), on behalf of themselves and

the class alleged herein, by and through their attorneys, and file this Complaint

against defendants CLINCH COUNTY, WINSTON PETERSON, and PATRICIA

SUGGS (collectively, "Defendants"). In support thereof, Plaintiffs respectfully state as follows:
PRELIMINARY STATEMENT 1.
This is an action to stop Defendants from an abuse of their authority, through which they have been charging inmates at the Clinch County Jail in Homerville, Georgia (the "Jail") fees for "room and board." Clinch County, its Sheriff, and his Deputies have been forcing inmates -- even those inmates who have not been convicted of a crime -- to pay charges set by Defendants. Defendants threaten to incarcerate those who have been released but refuse to pay these fees. Without any statutory authority or oversight by a court, Defendants charge often poor inmates exorbitant fees -- in some cases over $4,000 -- for room and board. This is far more than many defendants can pay. Even when an inmate at the Jail is released by the court on bond, Defendants often will not allow the individual to leave unless he signs a promissory note that states he must make periodic payments or face re-incarceration.
2. This practice is illegal. Defendants have no authority to impose charges on inmates. Defendants have no authority to coerce inmates to sign promissory notes. Through this pervasive practice, Defendants have taken substantial sums of
2

money from Plaintiffs and other inmates. 3.
Defendants' policy and practice of requiring pre-trial detainees to pay room and board fees violates numerous provisions of the U.S. Constitution and the Georgia Constitution. Further, this policy and practice violates Georgia law -- and quite simply constitutes conversion of Plaintiffs' money. Plaintiffs assert claims for violation of their civil rights under 42 U .S.C. § 1983, conversion, violation of O.C.G.A. § 17-11-1, and violation of the Georgia Constitution. In addition, they seek equitable restitution of their money, a declaratory judgment ruling that the promissory notes are not enforceable, and a declaratory judgment ruling that Defendants' policy violates the law.
4. Plaintiffs bring this putative class action on behalf of themselves and all past, current, and future pre-trial detainees at the Clinch County Jail who have been or will be charged for costs of their incarceration in violation of law. Plaintiffs respectfully ask this Court to preliminarily and thereafter permanently enjoin Defendants from charging inmates fees for room and board or other fees that are not permitted by law. Plaintiffs also ask this Court to order Defendants to return money that Defendants have wrongfully collected from Plaintiffs and other class members.
3

PARTIES
Plaintiffs 5.
Plaintiff Willie Floyd Williams, Jr. is resident of Homerville, Georgia. Mr. Williams was arrested on or around October 3,2003 and spent approximately nine months in the Clinch County Jail before being released on bond on June 15,2004. Before Mr. Williams was permitted to leave the Jail, despite having posted bond and being free to leave under the law, Deputy Sheriff Patricia Suggs advised him that he must first sign a promissory note agreeing to pay room and board costs of
$4,608. The promissory note included a statement advising Mr. Williams that he
would be re-incarcerated if he failed to make his payments. To date, Mr. Williams has paid approximately $140 towards the cost of the $4,608 the Defendants claim he owes the County.
6. Mickel Jermaine Jackson is a resident of Homerville, Georgia. Mr. Jackson
was arrested on February 6, 2004 and spent approximately three months incarcerated at the Jail before he was released on bond on April 26, 2004. Mr. Jackson was charged approximately $1,415 for Jail costs for these three months. Defendants have ordered Mr. Jackson to pay the County $100 per month towards his "jail bill."
4

Defendants
7. Defendant Clinch County is responsible for designating the decision maker to set the customs, policies and practices at the Clinch County Jail and so designated Sheriff Winston Peterson. Clinch County received "room and board fees" that were unlawfully collected from Plaintiffs by the Clinch County Sheriff and his Deputies. Upon information and belief, Defendants have deposited the room and board fees collected from Plaintiffs into the County treasury. (See Plaintiffs' Exhibit 1). Upon information and belief, Clinch County has caused, created, authorized, condoned, ratified, approved. and/or knowingly acquiesced in the policy of charging Jail inmates for the cost of incarceration, as described in this Complaint.
8. Defendant Winston Peterson is the Sheriff of Clinch County and, upon information and belief, is a resident of Clinch County, Georgia. As Sheriff, Defendant Peterson is the County's authorized decision maker for the Jail. He is directly responsible for the daily management, administration, policies, and operation of the Clinch County Jail. In Defendant Peterson's capacity as Sheriff, he has caused, created, participated in, authorized, condoned, ratified, approved, and/or knowingly acquiesced in the policy of charging Jail inmates for the cost of
5

incarceration, as described in this Complaint. Sheriff Peterson is sued in his official and individual capacities.
9. Defendant Patricia Suggs is the Deputy Sheriff of Clinch County and, upon information and belief, is a resident of Clinch County. Georgia. In Defendant Suggs' capacity as Deputy Sheriff, she has caused, created, participated in, authorized, condoned, ratified, approved, and/or knowingly acquiesced in the policy of charging Jail inmates for the cost of incarceration, as described in this Complaint. Deputy Sheriff Suggs is sued in her official and individual capacities.
JURISDICTION AND VENUE 10.
This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. §§ 1331 and 1343 because the action arises under and is brought under the Civil Rights Act of 1871, 42 U.S.C. § 1983 and the Fourteenth Amendment to the United States Constitution. The Court has supplemental jurisdiction over Plaintiffs' state law claims under 28 U.S.C. § 1367 because they are so related to the federal claims that they form part of the same case or controversy under Article III of the United States Constitution.
6

11. Venue is proper in this District under 28 U.S.C. § 1391(b)(1) because at least one Defendant resides in this judicial district. This District also is an appropriate venue for this action under 28 U.S.C. § 139I(b)(2) because all or at least a substantial part of the events or omissions giving rise to the claims asserted herein occurred in this judicial district.
FACTUAL BACKGROUND
12. Willie Floyd Williams, Jr.
Plaintiff Willie Floyd Williams, Jr. was arrested on or about October 3, 2003 and spent approximately nine months in the Clinch County Jail. Through his
court-appointed attorney, Mr. Williams applied for bond on or about May 10, 2004, and on June 15,2004, was permitted to bond out of the Jail. Before Mr.
Williams was released, however, Sheriff Peterson advised him that he owed the Jail money and directed him to see Deputy Sheriff Patricia Suggs. Deputy Sheriff Suggs told Mr. Williams he owed the Jail $4,608 to cover his Jail costs. Deputy Sheriff Suggs presented Mr. Williams with a promissory note, which he was directed to sign as a condition a/being released from Jail. (See Exhibit 2). The
promissory note described the amount Mr. Williams purportedly owed the Jail and
stated that if he failed to pay such Jail costs, he would be incarcerated. The note
7

states, in relevant part:
I Willie Williams am agreeing to pay the Clinch County Jail $20.00 per week on jail cost that lowe in the amount of $4608.00, to which I have paid $100.00[.] The new balance will be $4508.00. I will start paying this amount on 6/25104. I am aware that if I fail to keep this agreement I will be incarcerated in the Clinch County Jail.
13.
After signing the promissory note and giving $100 to Defendant Suggs, Mr.
Williams was released from the jail. 14.
On July 6, 2004, Mr. Williams paid Defendants an additional $20 cash payment toward his debt. (See Exhibit 3). On or around August 30, 2004, Mr. Williams received a post card from the Sheriff asking him to come to the Sheriffs Department within three working days of receiving the notice. (See Exhibit 4). On September 3, 2004, Mr. Williams made a third cash payment of $20 to Defendants. (See Exhibit 5).
15. Mr. Williams is still awaiting trial on the charges for which he was arrested in October 2003. He has not been convicted of any crime.
16. Mr. Williams is indigent. The Superior Court of Clinch County determined he was too poor to afford a lawyer to represent him in his criminal case and
8

appointed an attorney to represent him. Mr. Williams hopes to be re-hired as a forklift operator by his previous employer, where he worked for 10 years before being arrested on the charges that he is facing. At present, however, Mr. Williams has a limited income, has continuing child support obligations and is unable to pay the $4,608 it is claimed he owes the Jail. Mickel Jermaine Jackson
17. Mickel Jermaine Jackson was arrested on February 6, 2004 and was incarcerated for approximately three months at the Jail before being released on bond on April 26, 2004. Before being released, Deputy Warden Patricia Suggs advised Mr. Jackson he owed the Jail $1,415 for "room and board." Jail officials would not allow Mr. Jackson to leave the Jail until Mr. Jackson's cousin, Lottie Cooper Posley, came to the Jail with $113 in cash. Defendant Suggs told Mr. Jackson that he had to pay the Jail $100 per month on the first of each month until he repaid the Jail in full for his Jail costs. Defendant Suggs subsequently threatened to re-incarcerate Mr. Jackson if his payments were not made on time.
18. Mickel Jackson is indigent. He subsists on a monthly payment of Supplemental Security Income ("SSI") from the federal government.
9

19. Mr. Jackson has paid a total of $713 in Jail Costs as evidenced by the attached receipt. (See Exhibit 6).
20. On April 4, 2005, the District Attorney of Clinch County dismissed all criminal charges against Mr. Jackson.
Other Former Pre-Trial Detainees
21. The experiences of Mr. Williams and Mr. Jackson are not isolated instances. It is Defendants' policy and practice to charge Jail inmates - including pre-trial detainees - for the cost of room and board. The following are just a few other examples of this policy and practice: (a) Darius Dorsey was arrested in May 2004 and spent the night in the
Jail. The following day, the charges against Mr. Dorsey were
dismissed. Despite this, Mr. Dorsey was required to pay the Jail $36
for the cost of room and board. (b) Kenneth Brown was arrested in March 2004. Mr. Brown bonded out
of the Jail the day after his arrest. Before he was permitted to leave
10

the Jail, however, he was required to pay $18 for the cost of room and board. Mr. Brown had yet to be convicted of the crime with which he was charged. (c) Fredrick Caussey was arrested on August 4,2004. He spent three days in the Clinch County Jail before being released on bond on August 8, 2004. Before being permitted to leave the Jail, Mr. Caussey was required to pay $57 for the cost of room and board. Mr. Caussey has not been convicted of the offense for which he was charged. (d) Jeanne McGhee was arrested in March 2003. She was incarcerated in the Jail for approximately four days before pleading guilty and being sentenced to a term of probation. When Ms. McGhee was released, she was charged $90 for room and board. (e) Dominique Raysor was arrested on July 28, 2004. He spent approximately three months in the Jail before pleading guilty on October 15,2004. Following his gUilty plea, the Assistant District Attorney assigned to Mr. Raysor's case told Mr. Raysor that he owed $1,440 in "jail costs."
11

Defendants' Conduct Is Unauthorized And illegal 22.
There is no statutory or other legal authority for Defendants to charge Plaintiffs for the cost of room and board. This policy and practice constitutes unlawful conduct deliberately undertaken by a County and its officials.
23. Defendants' policy and practice of collecting room and board fees has not been authorized by the Georgia legislature.
CLASS ACTION ALLEGATIONS 24.
Plaintiffs bring this class action pursuant to Rules 23(a) and (b)(2) of the Federal Rules of Civil Procedure on their behalf and on behalf of a class similarly situated and affected during the pendency of this lawsuit and in the future. The class is defined as all past, current, and future pre-trial detainees at the Clinch County Jail who have been or will be charged for the cost of incarceration in violation of law.
25. The members of this class are so numerous that their joinder is impractical. The class consists of an unknown number of past inmates, about 32 current inmates, and such future inmates who will be incarcerated at the Jail.
12

26. The conditions and practices challenged in this action apply with equal force to the named Plaintiffs and all members of the class so that the claims of the named Plaintiffs are typical of those of the class. All class members are past, current, or future inmates at the Clinch County Jail. All class members have been or will be, absent this Court's intervention, charged for the cost of incarceration, in violation of law and deprived of their liberty without due process of law upon any alleged failure to pay. All class members will continue to be subject to such conditions absent the requested relief.
27.
The named Plaintiffs will fairly represent and adequately protect the interests of the class as a whole. They possess the requisite personal interest in the subject matter of the lawsuit and possess no interests adverse to other class members. Plaintiffs are representative of the class of all persons who have been or will be charged for the cost of incarceration at the Jail in violation of law.
28. Plaintiffs are represented by counsel who are experienced in class action litigation involving the rights of prisoners. The named Plaintiffs and the class members are represented by attorneys at King & Spalding LLP, a law fmn with extensive experience in complex class action litigation as well as attorneys at the
13

Southern Center for Human Rights, a privately funded, nonprofit organization with extensive experience in complex class action litigation involving prisoners' rights. Plaintiffs' counsel have the resources, expertise. and experience to effectively prosecute this action.
29. The questions of fact and law common to the class as a whole concern the constitutionality and lawfulness of the policy and practice of charging Clinch County Jail pre-trial detainees for the cost of incarceration. For example, there are common questions of law and fact concerning the lawfulness of each of the following of Defendants' policies and practices: (a) the policy and practice of requiring inmates to pay a per diem charge for the cost of incarceration regardless of their guilt or innocence or ability to pay; (b) the policy and practice of holding at the jail inmates who are entitled to be released until they sign a promissory note stating that they will pay the amount owed; (c) the policy and practice of threatening to re-incarcerate without any due process protections former jail inmates who fail to make payments on their "jail bill;" (d) the policy and practice of collecting installment payments; (e) the policy and practice of the holding and converting of such illegally
14

collected funds in the county treasury. 30.
Defendants, in creating and enforcing the jail reimbursement policy, have acted in a way generally applicable to the class the Plaintiffs represent, thereby making preliminary and permanent injunctive relief and corresponding declaratory relief appropriate for the class as a whole pursuant to F.R.C.P. 23(b)(2).
CLAIMS FOR RELIEF COUNT ONE
INJUNCTIVE RELIEF
31. Plaintiffs incorporate herein and re-allege, as if fully set forth herein, the allegations of the preceding paragraphs.
32. Plaintiffs seek a preliminary and thereafter a pennanent injunction to prevent Defendants from charging Jail inmates for the cost of incarceration in violation of federal law and Georgia law. See infra Counts Two through Six.
33. Defendants' conduct is not authorized by any Georgia law. Defendants' conduct violates 42 U.S.C. § 1983 and Georgia law.
15

34. Defendants' conduct is likely to continue unless preliminarily and thereafter permanently enjoined. Defendants' conduct is causing Plaintiffs immediate irreparable harm that cannot be remedied by the award of money damages. Plaintiffs have no plain, adequate, or complete remedy at law to redress the wrongs described herein. If Defendants are not enjoined, they are likely to continue irreparably harming Plaintiffs.
35. The balance of the hardships and public policy strongly favor the Court entering a preliminary injunction and thereafter permanently enjoining Defendants' unlawful policy and practice of collecting fees for "room and board" from inmates at the Jail.
36.
Plaintiffs seek an Order from this Court preliminarily. and thereafter permanently, enjoining Defendants from collecting fees for room and board from pre-trial detainees at the Jail or collecting other fees not permitted by law.
37. Plaintiffs also seek an order from this Court requiring Defendants to reimburse the money wrongfully taken from Plaintiffs and other class members.
16

COUNT TWO VIOLATION OF PLAINTIFFS' CIVIL RIGHTS
UNDER 42 U.S.C. § 1983 38.
Plaintiffs incorporate herein and re-allege, as if fully set forth herein, the allegations of the preceding paragraphs.
39. Defendants have violated Plaintiffs' right to due process of law under the Fourteenth Amendment to the Constitution of the United States, as applied to the states and enforced through 42 U.S.C. § 1983, by requiring Plaintiffs to pay the cost of room and board for a pre-trial and/or pre-conviction jail stay.
40. By requiring Plaintiffs who have not been convicted of any crime to pay the cost of room and board for a pre-trial and/or pre-conviction jail stay, Defendants are violating the Fifth Amendment's prohibition on takings without just compensation, as applied to the states and enforced through 42 U.S.C. § 1983.
41. By deliberately requiring Plaintiffs to pay the cost of room and board for a pre-trial and/or pre-conviction jail stay before release, Defendants have deprived Plaintiffs of their liberty without due process of law, deprived Plaintiffs of equal protection of the law, and imposed an unconstitutional ex post facto law.
17

42. By requiring Plaintiffs who have not been convicted of any crime to pay the cost of room and board for a pre-trial and/or pre-conviction jail stay, Defendants have deprived Plaintiffs of their property without due process in violation of Plaintiffs' constitutional rights.
43. By requiring Plaintiffs who have not been convicted of any crime to pay the cost of room and board for a pre-trial and/or pre-conviction jail stay, Defendants have deprived Plaintiffs of their substantive due process rights under the Constitution.
44. In each and every instance set forth above, Defendants acted intentionally, or at least recklessly, in disregard of Plaintiffs' constitutional rights. Defendants knew or should have known that confiscating funds without a conviction, without a court order, without notice or hearing, and without any statutory authority violated Plaintiffs' constitutional rights.
45. The actions set forth above were taken by Defendants under color of state law.
18

46. As a direct and proximate result of Defendants' illegal policy and practice, Plaintiffs were wrongfully deprived of money that belonged to them.
47. As a direct and proximate result of Defendants' illegal policy and practice, Plaintiffs were wrongfully deprived of their liberty.
48. Defendants are jointly and severally liable for the violations of Plaintiffs' rights, and the harm they suffered as a result, because each Defendant either personally participated in the actions or failures to act, or implicitly authorized, approved, or knowingly acquiesced or failed to remedy the wrongs at issue.
49. Defendants' above-described actions were willful, deliberate, malicious, and involved reckless or callous indifference to Plaintiffs' rights and should be punished and deterred by an award of punitive or enhanced damages as permitted by law and in an amount to be determined at trial.
19

COUNT THREE
CONVERSION 50.
Plaintiffs incorporate herein and re-allege, as if fully set forth herein, the allegations of the preceding paragraphs.
51. Officers and/or employees of Clinch County took and converted to the County's own use the funds set forth above from Plaintiffs.
52. Defendants' above-described actions were willful, deliberate, and malicious, and involved reckless or callous indifference to Plaintiffs' rights and should be punished and deterred by an award of punitive or enhanced damages as permitted by law and in an amount to be determined at trial.
COUNT FOUR
VIOLATION OF THE GEORGIA CONSTITUTION 53.
Plaintiffs incorporate herein and re-allege, as if fully set forth herein, the allegations of the preceding paragraphs.
20

54. The Georgia Constitution states: "No person shall be compelled to pay costs in any criminal case except after conviction on final trial." See Ga. Const. Art. I, § 1,4)[ XXIV. In contravention of the Georgia Constitution, Defendants are compelling Plaintiffs to pay for the cost of incarceration before they have been found gUilty of any crime.
55. The Georgia Constitution states: "No person shall be deprived of life, liberty, or property except by due process of law." See Ga. Const. Art. I, § I, I)[ I. Defendants have violated Plaintiffs' right to due process of law under Ga. Const. Art. I, § I, I)[ I, by requiring Plaintiffs to pay the cost of room and board for a pre-trial and/or pre-conviction stay.
56. The Georgia Constitution states: "Protection to person and property is the paramount duty of government and shall be impartial and complete." See Ga. Const. Art. I, § I, I)[ II. Defendants have violated Plaintiffs' rights under Ga. Const. Art. I, § I, I)[ II, by requiring Plaintiffs to pay the cost of room and board for a pretrial and/or pre-conviction stay.
21

57. The Georgia Constitution states: "[P]rivate property shall not be taken or damaged for public purposes without just and adequate compensation fIrst being paid." See Ga. Const. Art. I, § III, <)[ I. Defendants have violated Plaintiffs' rights under Ga. Const. Art. I, § III, <][ I, by requiring Plaintiffs to pay the cost of room and board for a pre-trial and/or pre-conviction stay.
58. In each and every instance set forth above, Defendants acted intentionally, and recklessly, in disregard of Plaintiff s constitutional rights. Defendants knew or should have known that confiscating funds without a conviction, without a court order, without notice or hearing. and without any statutory authority violated Plaintiffs' constitutional rights.
COUNT FIVE VIOLATION OF O.C.G.A. § 17·11·1
59. Plaintiffs incorporate herein and re-allege, as if fully set forth herein, the allegations of the preceding paragraphs.
22

60. a.C.O.A. § 17-11-1 states: "The costs of a prosecution ... shall not be demanded of a defendant until after trial and conviction." In contravention of O.C.O.A. § 17-11-1, Defendants are compelling Plaintiffs to pay for the cost of incarceration before they have been found guilty of any crime. Defendants require Plaintiffs to pay Jail costs even if all criminal charges against Plaintiffs have been dismissed. Defendants do not reimburse inmates or fonner inmates who have paid Jail costs, but were never convicted of any crime.
COUNT SIX EQUITABLE RELIEF
61. Plaintiffs incorporate herein and re-allege, as if fully set forth herein, the allegations of the preceding paragraphs.
62.
Defendants took and converted to their own use the funds set forth above from Plaintiffs. Defendants had no legal right to Plaintiffs' funds and took these funds in violation of law. The retention of Plaintiffs' money by Defendants would result in unjust enrichment.
23

COUNT SEVEN
DECLARATORY JUDGMENT
63. Plaintiffs incorporate herein and re-allege, as if fully set forth herein, the allegations of the preceding paragraphs.
64.
Defendants have directly and/or indirectly forced Plaintiff Williams to sign a promissory note that purports to require him to make payments to one or more Defendants.
65. Pursuant to 28 U.S.C. § 2201, Plaintiff Williams seeks a declaration by the Court that the promissory note is unenforceable. The promissory note is unenforceable because, among other things, Plaintiff Williams was coerced to enter it, it lacks consideration, and it is unconscionable.
66. Plaintiff Williams will be adversely affected if Defendants continue to enforce the promissory notes. The controversy between Plaintiff Williams and Defendants is definite and concrete. An actual controversy exists between the parties as to Defendants' enforcement of the promissory note and whether
24

Defendants will seek to incarcerate Plaintiff Williams for failing to pay the amounts allegedly due under the promissory note.
PRAYER FOR RELIEF WHEREFORE, Plaintiffs respectfully pray that this Court: 1. Assume jurisdiction over this action; 2. Determine by Order pursuant to Rule 23 of the Federal Rules of Civil
Procedure that this action be maintained as a class action; 3. Order trial by jury on all claims so triable; 4. Enter judgment in favor of Plaintiffs; 5. Enter a preliminary injunction and thereafter a permanent injunction
enjoining Defendants from collecting fees for room and board from pre-trial detainees at the Jailor collecting other fees not permitted by law; 6. Impose a constructive trust on all money taken from Plaintiffs in violation of law; 7. Order that Defendants return all money taken from Plaintiffs in violation of law; 8. Declare the promissory note that purports to bind Plaintiff Williams null and void;
25

9. Declare Defendants' policy of requiring Plaintiffs to pay the cost of
room and board for a pre-trial and/or pre-conviction stay to be in
violation of law;
10. Award Plaintiffs the costs of this lawsuit and reasonable attorneys'
fees pursuant to 42 U.S.c. § 1988;
11. Award enhanced or punitive damages as permitted by law and in an
amount to be proven at trial:
12. Order such other and further relief as this Court may deemjust and
proper. Respectfully submitted this 2nd day of May, 2005.
KING & SPALDING LLP
Courtland Reichman (Ga. Bar No. 599894) Stephen B. Devereaux (Ga. Bar No. 219791) Amy L. Madigan (Ga. Bar No. 465501) 191 Peachtree Street Atlanta, Georgia 30303-1763 Tel: (404) 572-4600 Fax: (404) 572-5136
SOUTHERN CENTER FOR HUMAN RIGHTS
Stephen B. Bright (Ga. Bar No. 082075)
26

Sarah Geraghty (Ga. Bar No. 291393) 83 Poplar Street, N.W. Atlanta, Georgia 30303-2122 Tel: (404) 688-1202 Fax: (404) 688-9440
27

EXHIBIT·l

Clinch Co., Board of C~lss1oners Revenue Appropriations

Fund 100 GENERAL FUND Dept 34 CHARGES FOR SERVICES

Appropriation for the Fiscal Year 2004-200S

APPROPRIATION CLASSIFICATION

34.1100 34.1101 34.1600 34.1930
34.1940 34.1941 34.2000 34.2500 34.2900

FEES PROBATE JUDGE FEES MAGISTRATE COURT TAG , TITLE FEES CHARGES CURRENT SERVICES
TAX COLLECTED COMH
TAX RECEIVER COMH
FEES SHERI FF 911 SUBSCRIBER FEES JAIL BOARD ftEIMBUftSEKENTS

DEPARTMEtll' TOTAL

Date Page

10/15/04 9

1,SOO.00 11,600.00
1,800.00 9,500.00 111,900.00 20,000.00 19,500.00
0.00 46,000.00
239,800.00

EXHIBIT·2

06/15/04 I Wl~Ll£ WILLIAMS AM Ar~EE1NG TO PAY THE CLINCH COUNTY JAIL S2O.00 PER WEEK 'ON JAIL COST THAT" t OWE It: THE AMOUNT OF S4608.00. TO WHICH t HAVE PAID Sl00.00
THE NEW BALANC£ WILL BE $4508.00. I WILL START PAVING THIS AMOUNT ON 6/25/04. I AM . AWARE THAT IF I FAll TO KEEP THIS AGREEMENT I WILL 8E INCARCERATED 1M THE CLINCH eoUlTY
JAIL.
."

EXHIBIT 3

-

<"~" .

CLINCH COUNTY

WINSTON PETERSON. SHERIFF

100 COURT SQ.• HOMERVILLE. GA 31634

,

(912) 487-531

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EXHIBIT 4

NO,.,. C E

(9 l:2/1£1:;'« MRS., MISS

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, PLEASE CONTACTTHIS OFRCE IN PERSON WITHIN THREE WORKING DAYS
OF RECEMNG THIS NOTICE. OFRCE HOURS ARE 8:.30 A.M. TO 5110 P.M.

MONDAY - FRIDAY.

I

THANK YOU.

WINSTON C. PETERSON. SHERIFF

.

CUNCH COUNTY SHERIFF'S DEPARTMENT

HOMERVILLE. GA 31634 •

JjL 2 b. DATE:

PHONE: 912-487-5315

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WINSTON C. PETERSON
;lINCH CO. SHERIFF DEPT.
100 COURT SQUARE I-iOMERVILLE. GA 31834

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HOMER~

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EXHIBITS

CLINCH COUNTY
WINSTON PETERSON, SHERIFF 100 COURT SQ., HOMERVIllE. GA 31634
(912) 487· 15

9 - 3 DATE

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EXHIBIT.6

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 L! {: ';';

FILED
lr};IS'!I'f"'"~lr.."..r'

li.'.''u''tJRT

IN THE UNITED STATES DISTRICT COUilPDLE Gi::Of(G1A

FOR THE MIDDLE DISTRICT OF GEO~PR 14 PH 2: 4,

VALDOSTA DIVISION

~
<~

DEPUTY CLERK

~

)

WILLIE FLOYD WILLIAMS, JR.,

)

MICKEL JERMAINE JACKSON,

)

)

Plaintiffs,

)

) CIVIL ACTION

v.

)

) No.: 7:04-CV-124-HL

CLINCH COUNTY, Georgia,

)

)

WINSTON PETERSON,

)

Sheriff of Clinch County, in his

)

official and individual capacities,

)

)

PATRICIA SUGGS,

)

Deputy Sheriff of Clinch County,

)

in her official and individual

)

capacities,

)

)

)

Defendants.

)

-------------------------- )

CONSENT ORDER

The Plaintiffs brought the instant action challenging the imposition ofjail

reimbursement fees upon pre-trial detainees incarcerated at the Clinch County Jail

in Homerville, Georgia. The policy of collecting jail reimbursement fees has been

in existence at the Clinch County Jail for approximately thirty years, long before

the administration of Sheriff Winston Peterson. Upon his election, Sheriff

Peterson continued the policy of seeking jail reimbursement fees from inmates, other counties, and the State of Georgia.
The parties, through counsel, have thoroughly briefed the legal issues presented by this case. After reviewing the parties' submissions and scheduling a hearing, the Court encouraged the parties to pursue mediation of this matter before United States Magistrate Judge Mallon Faircloth. The parties participated in mediation and mutually agreed to a settlement.
This Consent Order is submitted and entered into as a settlement of all claims set forth in Plaintiffs' Amended Complaint, as well as a settlement of all attorneys' fees and costs. This Consent Order represents the mutual agreement of the parties and shall not be deemed to be an admission by either Plaintiffs or Defendants concerning the merits of the case. In consideration of and in reliance on the parties' mutual agreement to the terms of settlement set forth herein, the Plaintiffs, Willie Williams, Jr. and Mickel Jackson, and the Defendants, Clinch County, Winston Peterson, and Patricia Suggs, hereby agree to a voluntary dismissal of this action pursuant to Fed. R. Civ. P. 41. All parties hereby agree to the following terms:
2

1. Reimbursement of Named Plaintiffs: Defendants will reimburse Plaintiffs Willie Williams, Jr. and Mickel Jackson any money they paid as jail reimbursement fees. Within seven (7) days of the date of this Order, Defendants will tender a check to Plaintiffs' counsel made out to Plaintiff Willie Williams, Jr. in the amount of$100. Within seven (7) days of the date of this Consent Order, Defendants will tender a check to Plaintiffs' counsel made out to Plaintiff Mickel Jackson in the amount of$718.
2. Reimbursement of Former Inmates Who Paid Jail Reimbursement Fees: Defendants will reimburse all persons who paid jail reimbursement fees in the four (4) year period prior to November 21, 2004, unless such persons paid the jail reimbursement fees pursuant to a court order. The reimbursement procedure will take place as set forth below, and will be subject to the oversight of the Honorable Mallon Faircloth, Magistrate Judge, United States District Court for the Middle District of Georgia.
(a) Identification ofpersons entitled to reimbursement: A list of people who paid jail reimbursement fees between November 21,2000 and November 21, 2004 is attached as Exhibit A to this Order. The Defendants hereby agree to reimburse every person listed in Exhibit A, in the amount indicated on the list, unless there is a court order in the person's Superior Court file showing that the jail fee in question was imposed pursuant to court order before the
3

date of this Consent Order. Within ten (10) days of the date of this Order, Defendants' counsel will mail to Plaintiffs' counsel and to Judge Faircloth: (1) a list of each person in Exhibit A that Defendants contend is not due reimbursement under this Order; and (2) for each such person, the applicable court order showing that the person's jail fee was imposed by the Superior Court. (b) Disagreement about who should be reimbursed: Should any disagreement arise between Plaintiffs' counsel and Defendants' counsel about whether a particular person shall be reimbursed under this Order, or how that reimbursement shall be effected, the parties will first make a good faith effort to resolve the disagreement. Any disagreement that cannot be resolved informally shall be presented to Judge Faircloth. The parties may make written submissions to Judge Faircloth, and he may decide the issue without conducting a hearing. Judge Faircloth's decision about whether the person is entitled to reimbursement pursuant to the terms of this Order, will be binding on all parties. (c) Reimbursement period: The reimbursement period refers to the period of time during which Defendants will make reimbursement checks available to former inmates. The reimbursement period will last for one year,
4

commencing forty-five (45) days from the date of this Order and ending one year from the date of this Order. (d) Reimbursement procedure: Within forty-five (45) days of the date of this Order, Defendants will make reimbursement checks available to each person entitled to reimbursement under this Order. Defendants will deliver all such checks to the Clinch County Board of Commissioners, 100 Court Square, Homerville, Georgia, within forty-five (45) days from the date of this Order. Thereafter, for a period of one year, Defendants will make the checks available to be picked up Monday through Friday, between the hours of 9 a.m. and 5 p.m. Those entitled to payment may collect their checks upon presentation of proper identification and upon signing an acknowledgement of receipt and a release of claims, as set forth below. If any person entitled to reimbursement under this Order is unable to pick up his or her check by reason of disability, illness, or incarceration, and such person (or, if such person lacks legal capacity, hislher legal guardian) puts Defendants on notice of the disability, illness or incarceration, Defendants shall mail the release form to an address designated by the person entitled to reimbursement. Upon receipt of the fully executed release form from that person, Defendants shall mail such person's check to the designated address.
5

(e) Proper identification: Proper identification means the following:
(1) A valid Georgia driver's license; (2) A valid identification card issued by a branch, department, agency, or entity of the State of Georgia, any other state, or the United States authorized by law to issue personal identification; (3) A valid United States passport; (4) A valid employee identification card containing a photograph of the person and issued by any branch, department, agency, or entity of the United States government, this state, or any county, municipality, board, authority, or other entity of this state; (5) A valid employee identification card containing a photograph of the person and issued by any employer of the person in the ordinary course of such person's business; (6) A valid student identification card containing a photograph of the person from any public or private college, university, or postgraduate technical or professional school located within the State of Georgia; (7) A valid United States military identification card; (8) A certified copy of the person's birth certificate; (9) A valid social security card; (10) Certified naturalization documentation. (1) Release o/Claims: Any person receiving monies from the Defendants
pursuant to this Consent Order must execute a release of claims form before
receiving his or her reimbursement check. The release of claims form that
shall be used by Defendants is attached as Exhibit B.
6

(g) Documents to be provided to Plaintiffs' counsel: Defendants shall mail the following documents to Plaintiffs' counsel, once every sixty (60) days, starting on the 60th day of the reimbursement period and ending on the last day of the reimbursement period:
1. copies of all release of claims forms obtained during the preceding 60-day period; complete log of all people who received reimbursement during the preceding 60-day period (Defendants shall use the log form attached as Exhibit C);
3. list of all people who sought to receive reimbursement during the preceding 60-day period, but did not receive reimbursement for any reason (Defendants shall use the log form attached as Exhibit C).
3. Notice: Plaintiffs' counsel shall provide Defendants with the last known address for each individual entitled to reimbursement under this Order. Within thirty (30) days after the date of this Order, Defendants shaH mail a written statement of notice to those persons entitled to reimbursement at their last known address. The notice letter that Defendants shall use is attached as Exhibit D.
4. Advertisements: Defendants will place and pay for advertisements in the Clinch County News in order to notify persons who are eligible for reimbursement
7

of the process necessary to collect the reimbursement. The advertisements will take up approximately one-quarter of one newspaper page and will run, weekly, for a period of four weeks, starting thirty (30) days from the date of this Order. The advertisement will state as follows: "Pursuant to a settlement agreement in the case of Williams v. Clinch County, No.: 7:04-CV-124-HL (M.D. Georgia), the Clinch County Sheriffs Department will reimburse certain persons who paid jail reimbursement fees. Those entitled to reimbursement under this agreement are former inmates who paid jail reimbursement fees in the four (4) year period between November 21, 2000 and November 21, 2004, unless such inmates paid the jail reimbursement fees pursuant to a written court order. Those entitled to reimbursement may claim their reimbursement check between [date: forty-five days after the date of the Order] and [date: one year plus forty-five (45) days after the date of the Order] at the Clinch Office of the County Board of Commissioners." The advertisement shall also state that persons seeking to claim reimbursement checks must bring identification, and shall list the forms of identification set forth in ~ 2(e) (above).
5. Agreement Regarding Future Conduct: Sheriff Peterson agrees that neither he nor any of his employees or agents will seek jail reimbursement fees from any person incarcerated or formerly incarcerated at the Clinch County Jail in the future, unless such fees are specifically ordered by a court of competent
8

jurisdiction. In the event that the State of Georgia enacts legislation specifically authorizing the recovery ofjail reimbursement fees by the duly elected Sheriffs within the state of Georgia, Sheriff Peterson would be permitted to follow Georgia law.
6. Litigation Costs and Attorneys' Fees: On behalf of Defendants, the Association of County Commissioners of Georgia's Interlocal Risk Management Agency (ACCG-IRMA) will pay a lump sum amount of $30,000 to Plaintiffs' counseL That amount shall represent the entire sum to be paid as litigation costs and attorneys' fees to plaintiffs and/or their counsel in connection with this civil action. Neither Plaintiffs nor their counsel will file any other application for attorneys' fees or costs pursuant to any federal or state law in connection with this civil action. Defendants' counsel will tender a check in the amount of$30,000 to Plaintiffs' counsel within fourteen (14) days of the date of this Order.
7. Release of Claims: In consideration of this agreement, Plaintiffs Willie Williams and Mickel Jackson release Defendants Clinch County, Winston Peterson, and Patricia Suggs in full, with regard to all claims made in the Complaint, the Amended Complaint, and in the course of this lawsuit. Plaintiffs agree that they will not file any civil action in state or federal court dealing with the issue ofjail reimbursement fees arising from any period of incarceration prior to the date of this Order. This agreement does not prevent Mr. Williams or Mr.
9

Jackson from making any claim regarding jail fees or other costs in the context of

any criminal case in which they are named as defendants.

8. Unclaimed Monies: If a person entitled to reimbursement under this Order

does not come forward to collect the money by the later of: (a) four (4) years from

the date on which he/she last paid fees; or (b) one (1) year after the date of this

Order, such monies shall be donated to Family Connections Collaborative in

Homerville, Georgia.

9. Enforcement: If Plaintiffs or Defendants fail to comply with the terms and

conditions of this Order, the opposing party may apply to the Court for a finding of

contempt or appropriate relief. Prior to approaching the Court for such relief, the

party seeking such relief will bring, in writing, any alleged deficiencies to the

attention of counsel for the opposing party and will make reasonable attempts to

resolve the issues informally. The parties agree that the Court shall retain

jurisdiction of this action for purposes of enforcing this Consent Order.

WHEREFORE, the Court, with the consent of the parties, hereby dismisses

this case pursuant to Fed. R. Civ. P. 41. The Court retains jurisdiction of the case

to enforce the terms of this Order.

4 IT IS SO ORDERED this

day of April, 2006.
~~e~<-~
The Hono able Hugh Lawson United States District Court Judge

10

A;:=C:;::ENTEDTOBY/v/ ~

Sarah Geraghty Ga. Bar 291393 Stephen B. Bright Ga. Bar No. 082075 SOUTHERN CENTER FOR HUMAN RIGHTS 83 Poplar Street, N.W. Atlanta, GA 30303 (404) 688-1202 (T) (404) 688-1202(F)

Richard K. Strickland Ga. Bar No. 687830 BROWN, READDICK, BUMGARTNER, CARTER, STRICKLAND & WATKINS, LLP 5 Glynn Avenue P.O. Box 220 Brunswick, GA 31521 (912) 264-9667 (T) (912) 264-9687 (F)

Courtland Reichman Ga. Bar No. 599894 Stephen Devereaux Ga. Bar No. 219791 Amy L. Madigan Ga. Bar No. 465501 KING & SPALDING, LLP 1180 Peachtree Street, N.E. Atlanta, GA 30309 (404) 572-4600 (T) (404)572-5100 (F)
Attorneys for Plaintiffs

Attorneyfor Defendants
L::L~-9i1!u6r\
Winston Peterson Sheriff of Clinch County
~~u~ Patricia Suggs d Deputy Sheriff, Clinch County Sheriff's
F=tw~l)
I linch County Commissioner (on behalfofClinch County)

~I'~~bJr;o~
Mickel Jackson Plaintiff

11

Exhibit A

Summary of Jail Room and Board Costs Collected by Defendants from 11/3/2000-11/21/2004

HECEIPT It
z.&"17S ---
24164 r-------2-·11-·-19
2-1131 2-1118 2-1119 2-1095 24088 2-1089 24078 2·lOn 2·107-1 2-1075 20·162 20·158 20-&59 2·1053 24021 2-1034 2..':)976 23977 2..1943 239·11
---~--
23929 2391·1 23916 23906 23905 23BB7 23889
---

DATE PAID

JAIL COST PAID ($)

11/21/2004

36

11/14/2004

36

11/8/2004

36

1"1/1/200-1-

100

10/31/200.'

36

10/31/2004

36

---

10/2·lj2004

36

10/18/2004

36

10/18/2004

54

10/17j20!}4

36

10/16/2004

18

'10/15/2004

72

10/15/200·'

40

10/12/200-1

36

10/11/200·1

90

10/11/2004

90

10/8/200",

100

10/4/200-1

90

"10/ -1/200-1

50

9/22/200·1

18

9/22/200·1

72

9/14/200,*

54

9/13/200-1

18

9/10/200:1

18

9/7/200..j

36

9/7/200-1

36

9/3/200-1

20

9/2/200-1

100

8/28/2004

18

8/28/200·!

18

NAME or INMATE
Thornton, 13rilndol1 Thornton, 13rm,,!on Thornton, Brandon
Jacksnl1, Mickel Coopcr, Ricky
Thornton, Brandon
Thornton, Brandon CI;nk, Ned
Lashley, Christopher Thornton, Brandon Royals, Willie James
---
Cuter, Rome Willis, ClilytOll Douglas, Child Delk Jr., Roy
Hillhouse, Raymond
Jtlckson, Mickel Willis, Clnytoll Tolbert, John Graddy, M,\rvjn Eichellllall, David
Hi)yes, Mcrt Lnnticrs, Jilmcs Bun:h, l3yroll Brantley, Rita Sherrod, Vernon Williams, Willie Jncksoll, Mickel
JelVel, Jack Jewd, l~obert

DATE IN)AIL DATE OUT OF JAIL OWES

N/A 11/12/2004 1115/200.' 2/6/200·1
N/A
'[0/29/200·1
'IO/22/200·~
N/A ')0/15/200·' 10/'15/200·1 10/'15/200-1 10/12/200..j
N/A
'10/9/2004 10/7/2003 ]0/7/200-1 2/6/200-1 9/2.l/200-l
N/A 9/20/200,* 9/"18/200-1 9/11/200'* 9/12/200·t 9/9/2004 9/5/200·1 9/5/2004 10/3/2003 2/6/2004 8/28/200-1 8/28/200.\

N/A

11/'14/200-1

11/7/200.1

-1/26/200·1
N/A

10/31/200,!

10/24/2004

N/A

1°tlS/200.'

10/17/200·1

10/16/200-1

10/15/200-1
N/A

10/11/200-1

10/'12/2004

10/11/200-1

4/26!20M

10/24/200-1
N/A

9/21/200-1

9/22/200-1

!

9/B/200-1

---

9/13/200·1

9/10/200.'

9/7/200-1
9/7/200·~

6/15/200·1

-1/26/200·'

8/28/2004

8/28/200·\

$758
$40
. I
$-l,468

Summary of Jail Room and Bonrd Costs Collected by Defendnnts from 11/3/2000~11/21/20011

23SIH

8/27/200-1:

18

23879

8/25/200·'

18

23853

8/12/200-1

54

238-1·1

8/9/200-1

72

238-12

1:1/6/200--1

36

23815

7/30/200.1

18

23816

7/30/200.\

36

2·1183

7/30/200·'

100

23796

7/26/200-1:

54

2·I1H~

7/23/20U-1

18

2-1'185

7 j23/200-l

18

2·\'186

7/23/200.\

86

23786

7/,19/200.\

54

23785

7/18/200-1

20

237(,1

7/,12/2011-1

180

23769

7/,12/200-1

18

23757

7/10/200,1

18

23752

7/8/2004

100

- -237·rJ

7/6/200.1

20

23739

7/2/200--1

72

237·10

7/2/200·'

180

23730

6/29/200-1

54

23720

6/25/200-1:

18

23722

6/25/200-1

18

23696

6/15/200.'

36

f----- 23697

6/15/200·'

100

23679

6/10/200-1

72

23677

6/9j200-1

144

23656

6/7/200.t

108

23667

6/7/200-1

108

2.%35

6/3/200·!

100

2..1620

5/30/200·~

18

Kin!t. Ivl ichael Thornton, JcrclII}' Brand Jr., Tommy SwinsoJl, R,'YllIoml Cmssey, Freddrkk Edmond, Jeffery
:-vkGhcc, je,1I1 ],Kkso[l, t\·tickel
Delk Jr., Roy Lashley, BeLty Moylan, D,ll'ny Rowe, Cmdm:c tvloylan, Ikgillil Adkins, WiIIiiltll Weaver, ~.. !ichilcl & Tyson, Antonio W<I[crs, John Ellison, Ervin K. Jackson, Mickel WillilllllS, Willie Adallls, Mkhdlc L:1WSOll, Austill Powell Jr., Jolm D, 1-1<)11110$, Eldon I-lollowilY, Lester DOll!:1,1S Jr., James It Williams, Willie Geddie, Kennelh
Slil!vey, J,'y
Thornton, Chi\r!es BerllMd Thompson, Williill1l JilcksOll, tvlickd
Hodriqucz. Ronnie ji\cob

8/26/200.1

8/27/2(}0~

8/2·1/200-1

8/25/200.1

8/1/200·1

8/2/200·1

8/6/200.'

8/9/200.'

8/-1/200,1

8/6/200.1

N/A

N//\

7/29/2UO.1

7/30/200·1

2/6/2OtM

-1/26/200-1

7/23/200·,

7/26/200-1

N/A

N/A

N/i\

N/A

N/A

N/A

7/16/200-1

7/19/200·)

7/17/2004

7/18/200·1

7/8/200.1

7/12/200·'

7/ 1l/200·'

7/12/200-1

7/9/200.!

7/10/200-1

2/6/200·'

-1/26/200-1

10/3/2003

6/15/200.'

6/29/2UO-1

7/2/200.(

6/22/200.1

7/2/200.'

6/26/200.'

6/29/200-1

6/2-1/200·'

6/25/200-1

6/25/200-1

!

6/25/2(]0.1

6/1·1/200-1 Hl/3/2003

6rI5/200·' 6/15/200·1

6/7/200-1

6rIO/200·l

6/3/200-1:

6/10/200·!

6/2/200.1

6/7/2004

Srl/200-1

5/11/200-1

2/6/200..J.

-1/26/20D--I

N/A

NJA

---
=-:.J
I
SO
I

23622 23617
1---.
23613 236H 2..1616 23597 23601 23559 2..156! 23557 23551 23501 23491 2.1493
2.:~-l9-1
23·195 23·189
23490
23-182 23·171 23·158 23·\·19 23-148 23-139 23-118 23396 23383 23367 23360 23355 23350 23351

Summary of Jail Room and Board Costs Collected by Defendants from 11/3/2000-11/21/2004

5/30/200.1 5/29/20{}.1 5/28/200·! 5/28/200·1 5/28/2004 5/25/2004 5/25/200-1 5/11/200-1 5/1 1/2004 5/'10/200.1 5/7/200.1 4/27/200·1 4/26/200·\ .1/26/2004 .1/26/200·' ·1/26/200.\ ·1/23/200·' -1/23/200-\ 4/22/200-1 -I/2U/200.• .l/'16/200.j .1/'15/200.1 4/1.I/200-1 4/9/200-1 4/5/2004 .1/2/200.l 3/29/ ZOU-l 3/25/2004 3{23/200·\ 3/22/200·1 3/20/200-1 3/20/2ll0.1

18 36 36 36 18 18 90 80
---------
18 54 54 18
100 72 36 40 18
54
50
36 18 36 18
30 54 50 18 252
18
100 37 37

Holland, i\-I j) rUm Dorsey, DllriliS Barnes, Jimmy Smith, Anthony WiIli,llllS, CedI Douglils Jr" jilmes Rkh,m! Willson, Helen Thompson, William I'Inrris Jr., Truby S. SteedIe)" Paul Burlon, Larry Collins, James Jackson, Mickel Bun:h, Bvrol\ 'vViIliillllS III, Charlie.' Sparks, David
Raysor, Dominique J.
Johnson, ivlllrio Sparks, f),wid J-Iulcltinsnn, Ji\llH.~$ R. \VilJiallls Ill, Charlie Clmllncey, Lynn
'few, SIeve Willis, C{nylol1 Delmar, l'iHil Wiflis, Clayton Gonzalez, Toni I'vlcDimiel, '1'110111,)5
Booth, John Richardson, Kerry I-Innis, Jallles Michncl Scott, Andre Duvnlf

5/30/200-1 5/28/200-1 5/26/200-1 5/26/200-1 5/28/200-1 5/2·1/200·1 5/2'1/2004 5/12/200,1 5/'1/200,1 5/7/200·1 5/5/200·! -1/26/200.1 2/6/200·!
N/t\ N/ ,\
N/i\ -J/23/200-1 4/21/200-1 -1/18/200·1 ·1/19/200·1 -1/15/200-1
N/J\ -1/B/200.j
N/A
-I/2/200.! 3/5/200·1 3/28/200-1 3/12/200-1 3/23/200·1
N/A
3/18/2004
3/'l~1200.1

5/30/200-1

5/29/200-1

5/28/200-1

5/28/200.1

5/28/200·t

5/27/200-1

5/25/2004

N/i\

5/2/200-1

5/10/200-1

5/7/2UO·1

-1/27/20U-I

.1/26/200-1

N/I\
N/i\

N/t\

·t/23/200·\

4/23/2004

4/22/200-1

·1/20/200-1

4/16/200·1
N/A

-1/14/2004

!

N/J\

·t/5/200.1

3jl9/200-1

N/J\

3/25/200.1

3/23/200-1
N/A

3/20/2004

3/20/200-1

--
$0 $0
$3,096
.--
!

Summary of Jail Room and Board Costs Collected by Defendants from 11/3/2000-11/21/2004

2..13·16 1,13·12
t-~-
23335
-~~~--
23222 ')3323
1,132·'
c-~-
23330 23331 2.1314 2.1306 23301 23302 23275 2.1286 23287 23288 23293
-~
23294 23281 23282 2..1283 2..1284 2..1285
r-----~
2..1274 23243
232~8
232·\9 23253 23260 23270 23235 23207

3/19/2004 3/18/200·' 3/16/200-1 3/15/20().t 3/'15/200.' 3/"lS/200-l 3/15/200.\ 3/15/2004
3/12/200~ 3/10/200~
3/8/200-1 3/8/200-l 3/5/200.\ 3/5/200-l 3/5/200.\ 3/5/200-1 3/5/2004 3/5/20IH 3/-1/200.\ 3 / -l/200-l 3/4/200-l 3/-1/2004 3/-1/2004 3/3/200·1 3/1/2004 3/1/200-1 3/1/200-l 3/'1/2004 3/1/200-l 3/1/200·\ 2/29/200·' 2/24/200·1

54
36 90 18 18 18 78 36
144
54 18 90 72
~-~
3G 18 36 36 36 36 18 36 18 18
36 18 36
18
36 18 90
18
54

Lacey, Gregory Wiltiams Jr./ Hosie Lee
Cook, Christopher Swinsoll, Rllymond lvl;nconc, Derek G.
Yearby, Tmvis J.
Hughes, T. Scott ~'[nj!1e, f.:d\\'urd Buddv
Cline, Ron Chauncey, Carl Thornton, Brandon Lolley, Glenda
Selph, Elaine Brown, Kenny Heliford. J,llH? Reliford, Bobb)' Hodges, Ishmacl Sl'nlvey, Vi1!erie Gordoll, Junn Gordon, Domn Hutchinson, J,lllICS Hil:lltml McGhee, MilC Swinson, Rilymond [ngTilllI, Hrend" Sims. Curtis Wright, QUintin Campbell, Taddl.!rick
----
HcideH.lurg, No"h McGill, E1dren
Armstrong, Kevin Ham, Glorii1 Tallwka
t,·lanac, Donnie

3/17/200~
-----
3/17/200~

3/12/200-1

~--~

~~

3/12/2004

~-

3/12/200.\

3/12/2004

3/12/200·1

3/14/200·j

3/-l/2004

3/7/200~

3/7/200·\

3/·1/2004

N/A

3/-1/2004

3/-'/200·1

3n/200-t

3/-I/200,f

3/3/2004

3/3/2004

3/·1/200·}

3/3/200·1

3/4/200-1

3/.1/200·'

3/1/2004

2/27/200-l

2/27/200·1

2/27/2004

2/27/2004

2/27/2004

2/26/200-1

2/27/2004

2/22/20()~

3/19/200.'

3/18/200.\

3/16/200·\

3/13/200.\

3/]3/200-1

3/13/200·'
3/]3/200~

3/15/20lJ-l

3/12/200-l

3/10/200.\

3/8/200·1

3/8/200·1

N/A

3/5/200-1

3/4/2004

3/5/200~

3/4/2004

N/A

3/-1/200·1

3/-l/200~

3/ -l/2lJ04

3/·l/200~

3/·lj200.!

:

3/3/200.1

2/28/200.\

2/29/200..

2/27/2004

2/29/200·'

2/28/200·1

3/1/200.'

2/29/2004

2/2·tj2004

! I
~~~~-

Summary of Jail Room ilnd Board Costs Collected by Defendilnts from 11/3/2000~11/21/2004

23'180

2/'17/2004

150

23182

2/17/200.1

50

23177

2/16/2004

72

23175

2/15/2004

18

23171

2/13/200-1

270

23151

2/9/2004

18

23152

2/9/2004

90

23'1l)6

1/30/2004

18

23107

1/30/200.~

18

23111

1/30/200-1

150

23077

1/23/200-l

72

2.107-l

1/22/200.J

18

2.1069

1/21/200-l

108

c--.. 2.1061

1/16/200.J

72

230-17

1/12/200.J

18

230-l9

1/12/200.t

18

2.102·1

'1/6/200.J

260

23006

'1/5/200-l

100

23033

1/5/200,!

100

22992 12/31/2003

250

22980 '12/30/2003

18

22963

'12/2.,/2003

18

22950 'l2/19/2003

100

22951

'12/19/2003

50

229-l8 12/18/2003

18

229·f2 12/15/2003

120

22928 12/10/2003

54

22919

12/8/2003

54

22925

12/8/2003

50

22912

12/5/2003

100

2290-l

12/3/2003

54

'--- 22886

12/2/2003

100

Glil:r.e, Jim Wilyne Richardson, Kerry IvlcGee II, ;.,·tic hacl E. Freeman, Cnlvin Pinknl'Y, Antonio
Knox, Sheila Nelson, Christopher
Smith, Wayne Hill, Slcp[mnic Gfil:r.C, Jim Wayne Dunn, Tommv
Shaw, Eric
Mo()dy, Johnny Timbcrlnlw, Emery
Smith, DOll!~lns
Mowery, tvlicIMel J{n,' Ddl, I\'lort
Glaze, Jim \-Vayne Ddl, ivlort King, Allen
1'1011, l~idlilrcl Corbitt, lvlich;lei Cla:r.e, Jim WilYJle
King, Allen \,VilIiams, Curtis Tysoll, Jimmy \Vnlkills, Lyle H.
Infinger, J.B. Glaze, Jim Wayne GlazL', Jim Wayne Sherrod, Vernon
Kin!~, Allen

N/A
N/t\
2/13/200·~
2/13/200.J 1/30/2004
N/J\ 2/2/200-l
N/A
1/29/200·~
N/A
'1/20/200-l 1/21/200-l
N/A
1/'11/200·1 1/11/200-l 1/,11/200·1
._---
N/A N/A
12tl7/2003 N/A
12/29/2003 12/22/2003
N/A
N/J\ '12/17/2003 '12/ .1/2003 'l2/8/2003 '12/6/2003
N/A N/A 11/28/2003 N/A

N/A

N/A
2/16/200,~

2/15/200"*

2/'I3/200.J

N/A

2/6/2004

N/i\

1/30/200·t
N/A
., /23/200-1

1/22/200-l
N/A

1/16/2004

1/12/200-l

1/12/200·\
N/A

N/A

1/S/20n·1
N/A

12/30/2003

12/23/2003

N/J\

~

N/J\

12/18/2003

'12/19/2003

12/10/2003

'12/8/2003

N/A N/A

12/1/2003
N/A
---.~

SO
SO SO 50 SO SO
SO S50 SO SO SO
$0
SO
$0
$0 -
$260

Summary of Jnil Room and Board Costs Collected by Defendants from 11/3/2000-11/21/2004

22859

12/1/2003

18

Drowll, Kimbcrly

11/26/2003

11/26/2003

22862

12/1/2003

72

Scruggs, Rich.ud

11/26/2003

11/29/2003

22868

12/1/2003

61

Anderson, SlIsan

11/29/2003

n/1/2003

22784 Tl/12/2003

5

Edith, Simeyon

N/i\

N/A

22779 11/10/2003

18

HcHin, Ezell

11/8/2003

11/9/2003

22773

11/5/2003

54

VI/hile, Bilford

12/7/2003

12/17/2003

2270'l

10/28/2!J03

18

Stalvey, Jay

10/28/2003

-10/28/2003

22679 10/26/2003

18

Spencer. James

-10/26/2003

10/26/2003

22680 10/26/2003

18

Grady, Anthony

N/A

N/A

22681 10/26/2003

36

Answorlh, Kellllelhi CII ristoplwr I-lowiud

N/A

N/i\

22678 10/25/2003

54

Guess, Trac\'

"11/16/2003

12/9/2003

22673

10/23/2003

18

Cmig, WrenL'il

-10/22/2003

10/23/2003

22660 10/20/2003

50

Mcrritt, Cecil

1-1/2"[j2003

1/6/200-l

22652 10/H>/2003

54

Hoopl.!r, Donald

-10/13/2003

10/16/2003

22653 10;-16/2003

18

Gray, James

-10/16/2003

10/16/2003

22651 10/15/2003

46

Lilnkford, Gilry

-10(13/2003

10/15/2003

22639 10/10/2003

250

Ivlcrritt, Cecil

9/18/2003

9/22/2003

226U

10/6/2003

18

Lace)" J\lexander

10/4/2003

10/6/2003

22571

9/27/2003

36

22569

9/26/2003

108

Kerry, Dawn G_ Guzman, tvlnrcus

9/26/2003 9/21/2003

9/27/2003
~-
9/26/2003

22526

9/12/20U3

54

l\'forris, Joseph

9/'10/2003

9/12/2003

22510

9/5/2003

54

Davis, Dcmelrou5

9/2/2003

9/5/2003

22511

9/5/2003

18

Richilrdson, Nathnnicl

9/5/2003

9/5/2003

22-l9-l

9/2/2003

126

Oeckcr, Ch,ulcs

8/26/2003

~

9/2/2003

22·~81

8/29/2003

40

/I.-liller, D.uryl Lee

N/A

N/A

22·l7S

8/28/2003

18

Muttis, Phillip

8/13/2005

8/"15/2005

22·m

8/25/2003

18

While Jr., Plltry Lee

8/2-l/2003

8/25/2003

22-lS0

8/16/2003

18

Wright Derick

8/15/2003

8/16/2U03

22-l·1O

8/15/2003

18

Kca ling, l".. lichal!l

8/11/2003

8/23/2003

22+tB

8/15/2003

18

McWhite., Engene

8/15/2003

8/t5/2003

22..32

8/13/2003

21

l\'liIler, Darrell

8/8/2003

8/"13/2003

22H3

8/13/2003

54

Reeves,lvlichnel

N/A

N/A

I
I
$3-18
$29
~-
----'

Summary of Jail Room and Board Costs Collected by Defendants from 11/3/2000-11/21/2004

22420

8/11/2003

72

22·\2'l

8/11/2003

36

22422

8/1'1/2003

36

224'l6

8/8/2003

20

22·1l7

8/8/2003

54

22·107

8/6/2003

]08

22..%8

8tl/2003

252

22372

8/1/2003

25

22362

7/31/2003

36

22339

7/28/2003

54

22347

7/28/2003

54

22335

7/25/2003

30

22338

7/25/2003

20

22328

7/24/2003

36

22317

7/22/2003

5'1

22313

7/2t/2003

18

22314

7/2'1/2003

18

~~~~

2230-1

7/18/2003

144

22301

7/16/2003

54

22295

7/15/2003

90

22291

7/14/2003

72

22293

7/1-J./2003

54

2228-1

7/12/2003

54

22274

7/'11/2003

18

22275

7/11/2003

18

22283

7/'11/2003

25

22267

7/8/2003

18

222'16

7/7/2003

18

22242

7/5/2003

S4

22240

7/.lj20D3

18

22227

7/3/2003

18

22231

7/3/2003

20

Paige> Alvin Ri\fficld, Arthur Powell, D.wid Hodges, Jerome Rowe, Candilcc
Hcwis, Jotiy Giddens, Rillldy Gainey, M,\fvin Williamson, Alllla Douglas, Child Rowe, Candace Gainey, 1\·larvin Hod!~cs, Jerome
l\·tiller, Cory l\·losely, Gussiu McCaskey, Linda
Bell, Timmy Cabral, ~vlichacl
Tille, Cedric Steedley, Scott Bradley, Tobe)' May, Frank C ilnrnes, Marvin names> James W. Wright, Calvin O. Gainey, l\'!afvil1 Miller, Cory
Clark, Perry nolmn non, James Jones, Mathew Nicol.,!; I~eed, John Wesley Hodges, Jerome'

8/8/2003 8/10/2003 8/10/2003
N/A 8/6/2003 8/1/2003 7/10/2003
N/A
7(15/2003 7/26/2003 7/26/2003
N/A
7/18/2003 7/23/2003 7/15/2003 7/20/2003 7/20/2003 7/11/2003 7/1.t/2003 7/'£1/2003 7/]0/2003 7/12/1003 7/l'l/2003 7/10/2003 7/10/2003
N/A
7/8/2003
N/A
7/3/2U03 7/3/2003
N/A
6/27/2003

8/'11/2003 8/,11/2003 8/"11/2003
N/A
8/8/2003 8/6/2003 7/'23/2003
NjA
8/5/2003 7/28/2003 7/28/2003
N/A
7/20/2003 7/2·l/2003 7/17/2003 7/21/2003 7/21/2003 7/'18/2003 7/'16/2003 7/15/2003 7/1.1/20lB 7jl.l/2003 7/11/2003 ! 7/,11/2003 7/'11/2003
N/A
7/8/2003
N/A
7/5/2003 7 ;'~/2003
N/ f\
6/29/2003

51,612
--
--
-------------
i , ,
I
I

Summary of Jail Room and Board Costs Collected by Defendants from 11/3/2000-11/21/2004

22209 222"15 2220"1 22208 22169 22171 22163 22120 22 III 22093 22091 22086 22088 22079 22116[ 220-15 220-16 22037 22008 22002 22003 219-13 21950 21951 2[95-1 21956 21958 21959 21960 21961 21%2 , 21963

7/1/2003 7/1/2003 6/30/2003 6/30/2003 6/2.1/2003 6/2..1/2003 6/2'1/2003 6/12/2003 6/'10/2003 6/5/2003 6/-1/2003 613/2003 6/3/2003 6/2/2003 5/30/2003 5/25/2003 5/25/2003 5/23/2003 5/"15/2003 5/,12/2003 5/12/20D3 5/2/2003 5/2/2003 5/2/2003 5/2/2003 5/2/2003 5/2/2003 5/2/2003 5/2/2003 5/2/2003 5/2/2003 5/2/2003

-----
90 25 54 18 72 36 18 468 36 36 536
30
54 30
72 18 18
18 18 18 18 50 18 18 18 18 18 36 18 18 18 18

Willis, Hilton

6/26/2003

7/21/2003

Hodgl'!:i, Jerome

6/20/2003

6/22/2003

Temple, Krvstill

6/27/2003

6/30/2003

Simpson, Arviml P.

6/29/2003

6/30/2003

Slone, Stephen

6/20/2003

6/23/2003

Bnrltcy, Wendy

6/22/2003

6/23/2003

Sl1lilhic, Charlie

6/20/2003

6/21/2003

Crumpton, Christophel' Gohh!n, Hnw(lrd

N//\

N/A

.-

6/9/2003

6/10/2003

I-lentil, Jimmy De;lll

6/.J./2003

6/5/2003

RoUe, Keo kn

N/I\.

N/A

Roberson, Deneisha

N/A

N/A

Ash, Harriet Hooper, Donald

N/A 5/31/2003

-----

N/A

6/2/2003

Smith, Anthon)'

5/22/2003

5/27/2003

McCutchin, rvliclmel

5/25/2003

5/25/2003

Ingrnlll, Brenda

5/25/2003

5/25/2003

SilIlChc~,. Jimmy

5/22/2003

5/23/2003

Brantley, Dobbie

N/A

N/I\

Wilson, ROIl"ld

N/A

N//\

J<1CkSOll, ){;ll1d y

5/'12/2003

5/12/2003

Robison, DenC'si.l

.1/22/2003

4/28/2003-

G.unble, L"keslm

5/1/2003-

5/2/2003

Smith, Ethel

5/2/2002

!

5/2/2003

Coopt'r, AC.
Dnvis Jr., Albert

5/1/2003 5/2/2003

5/2/2003 5/2/2003

GrHfis, Kntie & Terrell

5/2/2003

5/2/2003

Delk, Henry & Carolyn

5/2/2003

5/2/2003

IHley, Linda

5/2/2003

5/2/2003

Sorrells, I\obert

N/A

N/A

Gri((js, Dorothy

5/2/2003

5/2/2003

Pl'ilcock, Lora

~---.-

5/2/2003

..... 5/2/2003

Summary of Jail Room and Board Costs Collected by Defendants from 1l/3/2000~11/21/2004

2196·1
2<1930
~~~~~~
21<)\8 2"1905 W363 21865 2185-1 21850 21851 21852 21842
2~\8-10
2183-1
'---~~~~<
21829 2Hl22 21812 2UH"! 2H:i09 21761 21763 21752 217·18 21749 21747 21739 21701 2171J.!
21683
2"1686 21677 21668 21652

5/2/2003 ·1/28/2003 .1/2·1/2003 .1/"15/2003 4/1/2003 .1/1/2003 3/27/2U03 3/25/2003 3/25/2003 3/25/2003 3/20/2003 3/19/2003 3/15/2003 3/13/2003 3/11/2003 3/9/2003 3/B/2003 3/6/2003 2/20/2003 2/20/2003 2/13/2003 2/ll/20t}3 2/11/2003 2/10/20l)3 2/6/2003 1/30/2003 1/30/2003 1/23/2003 1/23/2003 1117/2003 1/14/2003 1/6/2003

18

18

18

18

72

-----

918 36

18

90

108

18

36

18

30

72

18

18

25

54

25

30

18

162
-------
36

25

108

25

36

25

50

180

36

Ncwbern, Debra Tolbert, Ji\1\!l"C 1lodges, lshn,,'cl 1"lodges, Ish 1Il<1l.d Jilekson, Sophi,' Arthur, Iethm
Cunningham, ArchieTes!<Hl, Stac)'
McGhee, )I.Mn /"\'1cl\"li11"n, Joe Bennett, Liz I-lodge, Timothy Mct\-lulfel1, Roy
Gevcil, Jody
ThoI1MS, C.uolyn
Musgrove, Ry.m \Vhillen, \Villi,'lll
Gevcil, Jody
CUlIlmings, Shermilll Gevca, Judy GC'VL'il, Jody King, Pillrki,l
!\"larshall, JCllnirer Zajkowski, John
GL'vL'a, Jody Pope, Ien.!m}' GCI!L'.1, )ody Crosby, TOllY GevciI, Jody GL'vca, Jody Swinson, \Villie J. 1\ltman II, Jerry E.ul

N/t\

N/A

4c/27/2003

-1/27/2003

.~/23/2003

·1/2·1/2003

.1/"11/2003

4n5/2003

3/27/2003

4/1/2003

N/i\
------
N/A

N/J\
N/A

3/21/2003

3/2S/l003

3/21/2003

3/25/2003

3/20/2003

3/25/2003

N/A
---- -
3/"18/2003

N/A
3/19/2003

3/1-1/2003

3/15/2003

N/A

N/A

3/7/2003
N/i\

3/1"1/2003
N/A

3/5/2003
N/A

3/9/2003
N/A

2/17/2003

2/20/2003

N/A

N/A

-------

N/A
"---
N/i\

N/A N/A

2/3/2003

2/1'1/2003

2/8/2003

: 2/10/2003

N/t\

N/i\

"' /2.l/ 2003

1/30/2003

N//\

N/t\

2/7/2U03

3/4/2003

N//\

N/i\

1/2/2003

1/17/2003

1/4/2003

1/14/2003

1/4/2003

1/6/2003

-
. I ! I I
~~~-

Summary of Jail Room and Board Costs Collected by Defendants from 11/3/2000-11/21/2004

216·13 216'12 21597 21561 2'1563 21518 21·198 21-199 21500 21486 21-l55 21·m 21420 21410 21387 21351 21366 21299 21290 2125-1 2125'1 21220 21208
2n% 2120S
--
21I86
----------
21167 2n50 21'J42 2n13 21079 21074
'---

'1/3/2003 12/2·1/2002 12/12/2002 12/5/2002 12/5/2002 '11/24/2002 11/15/2002 '11/15/2002 '1'1/15/2002 11/12/2002 1"1/3/2002 10/29/2002 10/25/2002 10/20/2002 10/12/2U02 10/7/2002 10/7/2002 9/23/2002 9/20/2()02 9/9/2002 9/7/2002 9/3/2002 8/31/2002 8/30/2002 8/30/2002 8/28/2002 8/25/2002 8/17/2002 8/14/2002 8/6/2002 Sf 1/2002 7/31/2002_

18 18 50 18.17
252
18 36 36 103
108 18
---------
216 18 18 36 18 270 18 18
36 18
18 18 36 18 36
20
as
36 18 162 18

J0 hnson, Christopher
Price, vVarren Robersoll, Denesia
Ingram, April Hnrdy, Tyrone King, Glendn Grnddy, Shannon Graddy, Tina Sorrell, [lobby King, Allen Ward jenkins, Dnl1icI Byrd, Danny Wntsoll, DOI1<lld lvlurry, Larry Adnms, !-lilrvcy 13rcnmm, David Knight. noyd Gnmble, l3oblJ)' ThOlllllS, L(l\\,nndil
Lee, Gene Willinms, Darryl
/'·,1 iller, Darrell
I'!ill, Lindi1 Wright, MarIn
l3everly, Joe Johns. HMry Wilder, Chris!l")pher Carter. Dillil Hodges. Jerome Infinger, J. H. Hand, Hobert ~i1ylor, Eddie L.

'1/2/2003 12/23/2002 '12/2/2002 '12/2/2002 Tl/2'l/200Z
N/I\ r1/13/2002 11/'l3/2002
N/A 1"1/7/2002
N/l\
N/A
10/2-1/2002 '10/20/2002 lO/1i/2002
NjA 9/23/2002 9/23/2002 9/20/2002 9/8/2002
N//\
9/2/2002 8/3'1/2002 8/28/2002 8/29/2002 8/27/2002
N/A
N/i\ 8/11/2002 8/5/2002 7/24/2002 7/30/2002

1/2/2003

12/24/2002

'l2/3/2002

'12/5/2002

12/5/2002
N/A

11/15/2002

11/15/2002
N/A

11(12/2002

N/A N/A

10/25/2002

10/21/2002

9/12/2002

N/A

10/7/2002

9/2.1/2002

9/20/2002

9/9/2002

N/A

9/3/2002

8/3'1/2002

!

8/30/2002

8/30/2002

8/28/2002
~---
N/A
N/A

8/14/2002

9/6/2002

8/1/2002

7/31/2002

5209.79

Summary of Jail Room and Board Costs Collected by Defendants from 11/3/2000-11/21/2004

2"1058

7/29/2002

103

21038

7/25/2002

36

21020

7/19/2002

58

21008

7/16/2002

160

21005

7/1-4/2002

18

209B7

7/2/2002

270

20975

6/30/2002

234

209·(7

6/25/2002

6.21

209·16

6/2·lj2002

18

209-13

6/21/2002

26

20902

6/13/2002

18

20893

6/9/2U02

54

20892

6/8/2002

18

20867

5/30/2002

18

20S39

5/29/2002

126

20838

5/28/2002

18

20826

5/22/2002

18

2()77·t

5/2/2002

2S

20751

o1/22/2U02

25

2()750

4/19/2002

18

20732

4/15/2002

50

20279

4/11/2001

36

20728

-1/10/2002

54

20725

4/9/2002

54

20711

4/3/2002

18

20712

-1/3/2002

18

20690

3/29/2002

244

20691

3/29/2002

54

20692

3/29/2002

72

20671

3/26/2002

72

20656

3/18/2002

36

20652

3/15/2002

36

PHlmcr, Syh'in Stevens, LilTr)' Popc, Jeremy Pope, Jeremy
Shim', Eric Graddy, Brad Tysoll, Clifton Johnson, Christopher Lasitore, Corneliil Lankford, Gary Gilcrest, Bern.lf(1 Propes, Carina King, Preston Wright, Mariph Hilt Stephanie Boone Speigner, Eric King
Adams, Mklwlle N.
McCaskey, Linda lvkCilskcy, Limlil
Clark, Ned McCnskey, Lindn
Andrews, Eric Tolbert, Bessie Courson, April PiHl11illl, Bubby Pittmal1, Kelly Lil s lll()2"I~{!ttX Guess, Tracy Crosby, Thomas Vickers, Walter Gamblr.:>, Llewelyn McSwain, i'nt

7/26/2002

7/29/2002

7/2-1:/2002

7/25/2002

N/t\

N/A

7/2..1/2002

7/29/2002

7/14/2002

7/1-1:/2002

6/17/2002

7/2/2002

6/"17/2002

7/1/2002

6/14/2002

6/25/2002.

6/2..1/2002

6/2-1/2002

6/20/2002

6/20/2002

N/A

N/A

6/17/2002

7/1/2002

6/7/2002

6/8/2002

N/A

N/A

5/23/2002

5/29/2002

5/27/2002

5/28/2002

•

N/A

N/I\

N/A
2/25/2002

N/A 3/101/2002

N/A

N/A

2/25/2002

3/1-1/2000

-4/10/2002

4trtj2002

-1/9/2002

4/11/2002

-4/5/2002

!

N/A

4/2/2002

4/3/2002

4/2/2002

4/3/2002

N/A

N/A

3/23/2002

3/21:l/2002

3/26/2002

3/28/2002

3/23/2002

01/1/2002

3/17/2002

3/18/2002

3/14/2002

N/A

Summary of Jail Room and Board Costs Collected by Defendants from 11/3/2000-11/21/2004

206·17

3(12/2002

18

20GO·'

3/7/2002

18

20592

3/-1/2002

36

20589

3/2/2002

18

20590

3/2/2002

18

205G6

2/21/2002

128

20557

2(15/2002

18

205S0

2/13/2002

18

20551

2/13/20U2

36

20552

2/13/2002

36

205-10

2/8/2002

50

20533

2/5/2002

18

20521

2/.1/2002

108

20501

1/30/2002

18

20502

1/30/2002

71

20·128

1/5/2002

18

20-116

1/2/2002

15

20-120

1/2/2002

108

20·rt.t

n/31/2001

504

20·n2

12/28/2001

18

20-107

12/21/2001

15

203·15

12j.l/2001

36

20331

11/30/2001

54

20311

"11/22/2001

54

20300

'11/15/2001

194

2026·1

T1tl/2001

36

202-18

10/27/2001

18

20235

10/22/2001

54

20126

9/27/20()1

42

20105

9/25/2001

18

20099

9/21/200"1

45

~0092

9/20/2001

120

Donovan, LOflil~ L. J01111501\, Leroy
~l.'loorehci\d, Ken),un Mills, Andy
Gmddv, ShilllllOll Williallls, Toraine Sheffield,Sillllilntllil
tl.'lonrol.',Olis l\'lilrshnll, Sallluc! \Vi II i,m1:; Sr" C.B, Glaze, Jim Wayne Parler, Willie Jill1ll'S r)jnKney, ,\nlonio Rnymond, l!ilIy
Loern, Jose 13nll, Cindy Decs[', Homer nilymond, Charles McKelvin, Dexter Brown, Kenny Decsc, Homer
Cooper, Ricky J.
Powcrs, D,lImy Edmonds, Reggie CillllpbeIl, Lesler K.
!'!nrper, ScoLL Green, Dell Smith, Jall\es E. Horgcns, Crystal Lacey, Greg Holley, Olho Borgens, Crystal
-

3/1.1/2002

3/"1-1/2002

3/6/2002

3/7/2002

3/3/2002

N/A

3/2/2002

N/A

3/2/2002

N/A

2/15/2002

2/2"1/2002

N//\

N/A

2/12/2002

2/13/2002

2(12/2002
N/A N/A N//\

2/13/2002 N//\ N/J\ N//\

1/30/2002

2;'1/2002

1/30/2001
N/;\

1/30/2002
N/J\

1;'1/2002
N/t\ N/t\

1/5/2002
N/J\ N/A

12/3/2001

12/3'1/2001

12/27/20m
N/A

'12/28/200 I

I

N/J\

'12/3/2001

12/-1/2001

TI/27/2001

11/30/2001

Tlj20/2001

!

H/2.1/2001

11/7/2001

TI/1S/2001

10/31/2001
N/A

11/1/2001 Njt\

10/20/2001

10/22/2001

see'102

sec 102

9/25/2001

9/25/2001

see 101

see'IOI

9/12/2001

9/20/2001

Summary of Jnil Room and Board Costs Collected by Defendants from 11/3/2000-11/21/2004

20076 20069 20070 20071 20072 20073 2007·. 20068 20053 20037 200-10 200-n 200-12 200·1·1 200·18 2003-1 20035 20028 20029 20029 20030 200 .. 9 20025 20001 20002 19999 19997 19%5 'J9963 19960 199-10 199-11

9/14/200'1 9/12/2001 9/12/2001 9/12/2001 9/12/2001 9/12/2001 9/12/2001 9/1"1/200] 9/8/2001 9/6/2001
9/6/2001
9/6/2001 9/6/2001 9/6/2001
~/6/2001
9/5/2001 9/5/2001 9/-1/2001 9/4/2001 9/.. /itlO1 9/ ../2001 9/4/2001 9/2/2001 8/2..1/2001 8/23/2001 8/22/2001 8/21/200'1 8/16/2001 8/15/2001 8/14/2001 8/10/2001 8/'10/200]

25 18 18 18 18 18 18 13 20 54 18 18 18 18 18 18 36 18 18 18 18 80 18 18 18 18 234 36 126 36 18
5~_ ,

I'lollc)" 01110 Marlill, Mallison Donie! Johnson, Larry \Vnyne
Daniels, Nora Lee Portee "Bo" James Williams, Gerald
Mast, Sharon Thornton, Sammy
Vargos, Rogelio I-licks, Carmela Mavne, Robert Thompson, Sony" Waters, Howilrd D. Newsome, Charlcs W. Kinlaw, Andrea
Smith, Linda Anderson, S1l5nn
Ellis, Shciln Sikes, Trenton Hall, DaJliellc J-/emy, Lntall)'il IJames, Javenco Cuter, I{obcrt \viIlimns, Samuel fvlcCutcilin, MichiWI Johnsull, ChrislQphcr Schofield, Glunda Smith. Wnlter Newbern, John Foster, Eddie l... Hernandez, Hector NeWbern, Michelle

9/7/2001

9/10/2001

9/12/2001

9/12/2001

9/12/2001

9/12/2001

9/12/2001

9/12/2001

N/A

N/A

9/12/2001

9/"12/2001

9/12/2001

9/12/2001

9/7/2001

9/11/2001

9/7/2001

9/8/2001

9/3/200]

9/6/200'1

9/5/200'1

9/6/2001

9/5/2001

9/6/2001

9/5/2001

9/6/2001

9/5/200'1

9/6/2001

N/A

N/A

N/A

N/A

9/4/200'1

9/5/2001

9/3/2001

9/4/200'1

9/3/2001

9/-1/2001

9/3/2001

9/-l/2001

N/A

N/A

8/"2:1/2001

9/·1/2001

N/A

N/A

8/22/2001

;

8/23/2001

8/22/2001

8/23/2001

N/A

N/A

8/8/2001

8/21/2U01

8/15/2001

8/16/2001

8/8/2001

8(15/2001

8(12/2001

8/1-I/200t

8/10/2001

8rIO/2001

8/8/2001

8/"10/200'1

Summary of Jail Room and Board Costs Collected by Defendants from 11/3/2000-11/21/2004

199·13 199-14 19920 19913 '19903 19899 19896 1989-I 19895 198B3 '19869 '19822 19811 '19774 [9773 [975-1: 19703 19693 [9677 '1965-1 'l9656 19657 19652 '19636 '19633 19618 19571 '19574 19567 19526 195H '195'l'l

8/10/2001 8/10/20m 8/7/2U01 8/6/2UOI 7/31/2001 7/29/200] 7/27/2001 7/26/2001 7/26/2001 7/22/2001 7/16/2001 7/10/2001 7/7/2001 6/29/2001 6/2B/2001 6/22/2001 6/2'1/2001 6/1..J./2001 6/5/2001 5/29/2001 5/29/2001 5/29/2001 5/28/2UOl 5/22/2001 5/21/2001 5/17/2Otll 5/3/2001 5/3/2001 5/2/2001 -I/28/2001 ,1/25/2001 .1/20/2001

26 18 36 54 90 18
36
36 72 18
288 90 18 72 18 20 36 36 18 108
234 72
18 18 18 14,11 36
lOB
36 5'1 108 144

Richnrdsoll, Kerry Johnsol). \Vay'11C
Williams, Charles
Walts, Sleven
Roberts, Cluo
Wi Ilia \l1 S, Stn rzn Juniolls, Kiki
Hughes, Cha).;nj Lawsol1, lvlatt P«Hell, Ri'll1dy
WiIIi,llnSOn, J()seph Bacon, F<llmie Lue, John Meeks, I~illHly
Andrews, Trez
Bellnett, Rudy Jack
Guess, Trilcy
Williams, Josie
Riclmrdsoll, Kerry
Sheppard, Helen Corbin, Rose Selph, Joannu
Wilson, Dcwilync Hodge, Reno Dykes, Stephen
Glnzc, Jim Wayne Smith, Dennis Hnmld
DlImns, N,lthimieJ Borgens, Crystill GIi1zc, Jim Wayne Williams, Lois
Dodd, Jessie

8/7/2001

8/10/2001

N/A

N/A

N/A

N/t\

8/3/2001

8/6/2001

7/30/200'1

7/3'1/200'[

7/28/2001

7/29/2001

7/26/2001

7/27/2001

7/23/2001

7/26/2001

N/A

N/A

N/A

N/A

7(1/2001

7 j16/2oo1

N/A

NII\

N/A

N/A

6/29/2001

6/29/2001

6/27/200']

6/28/2001

6/20/2001

6/22/2001

(,/19/2001

6/21/2001

6/13/2001

6/14/2001

6/'~/2001

6/5/2001

5/2·1/2001

5/29/200'\

,

5/15/2001

5/29/2001

N/A

N/t\

5/27/2001

5/28/2001

5/21/200'1

:

5/22/2001

•

N/A

N/A

N/A

N/A

i

5/2/2001

5/3/200'1

4/29/2U01

5/3/2001

5/1/200']

5/2/2001

4/20/20U1

''128/2001

N/A

N/A

4/13/2001

-1/20/2001

Summary of Jail Room and Board Costs Collected by Defendants from 11/3/2000-11/21/200(1

19·197

4/17/2001

198

19-196

4/16/2001

72

]9-162

3/28/2001

36

'19,16'1

3/27/2001

18

19.J55

3/25/2001

18

'19·135

3/16/2001

68

'19·120

31'10/200]

36

19.J21

3/10/2001

49

'19-122

3/10/2001

18

19·123

3/10/2001

18

19397

3/5/2001

36

19377

3/2/2001

36

19380

3/2/2001

18

1936'1

2/25/2001

18

19344

2/20/2001

36

193-10

2/"19/200]

36

19288

2/6/2001

18

19259

1/31/200'1

54

19245

1/25/2001

72

'19246

1/25/2001

125

'192-l2

1/23/200<1

54

<192'12

1/19/2001

54

19210

'1/18/2001

108

19168

1/8/2001

72

19106 '12/17/2000

18

19'107 "12/17/2000

18

19075 12/13/2000

36

190G8

'12/9/2000

18

18992 '11/21/2000

36

18999 11/21/2000

36

18984 11/17/2000

54

18974 11/15/2000_

500

Thompson, Joseph Chmrncev, Terry Presler, Adrienne D.
Allcn, Ginger Bradford, Donnn Williams, Kennclh
Finch, Benny Willoughby, Ben
Bell, ]ny Steedley, Jessie
l.ofton Jr., Troy
Sclph, Trnvis Wjlliams, Gerald
Sm.)Il, Shnron Denton, Larry McKclvin, DexLer Wilson, Nit!han McCilskey, 1vlind.,
Cox, Joann Dunn, To 111 my Armslronn, Kevin Wiggs, f\,jnbel Burkes, Lorellzo Presler, Adrienne Allen, Williill11 Chambers, John Smith, AlexillldC'r Griffin, Willi,)1l1 Griffin, Nathi1niel Finch, Bunny FrCl.!tni111, Sonya Wiltl'i, Charlie

4/6/2001 N/A
3/28/2001 3/27/2001 3/2.1/2001
N/A
3/6/2001; 3/9/2001 N/A
3/10/2001 3/9/2001 3/3/2001 2/28/2001 3tI/200l 2/2-1/2001 2/18/2001 2/18/2001 2/6/2001 1/2S/2001 1/22/2001 1/18/2001 ]/20/2001
N/;\ 1/12/2001 '1/5/2001 12/17/2000 12/17/2000 12/12/2000 12/8/2000 11/19/2000 11/19/2000 11/17/2000
N/A

4/17/2001 N/t\
3/29/2001 3/27/2001 3/25/2001
N/A 3/7/2001; 3/Hlj2001
N/A 3/11/200-1 3/H/2001 3/5/200'] 3/2/2001 3/2/2001 2/25/2001 2/20/2001 2/19/2001 2/6/2001 1/31/2001 ]/25/2001 1/25/2001 1/2..1/2001
N/A 1/18/200'1 '1/8/2001 12/18/2000 12/18/2000 12/13/2000 '12/9/2000 11/21/2000 11/21/2000 11/19/2000
N/A

•
--
I
-
S436
--------------

Summary of Jail Room and Board Costs Collected by Defendants from 11/3/2000-11/21/2004

36

Tnshiki\

72

Crosby, Thomas

18

Lott fr.. Tohn It

54

I:rccnmn, Sonya

'IO/20/2000

Exhibit B

RELEASE OF CLAIMS In consideration for accepting the jail reimbursement fee issued to me on this day, I, _ _ _ _ _ _ _~_ _, hereby agree not to file any action in state or federal court against Clinch C()unty, Georgia, Sheriff Winston Peterson, or Patricia Suggs, for the purpose of seeking jail reimbursement fees paid or sought prior to November 21,2004. This waiver does not affect my right to file any civil action against Clinch County, Georgia, Sheriff Winston Peterson, or Patricia Suggs with respect to any other matter or issue. Nor does this waiver affect my right to challenge any aspect of any criminal case in which I am a defendant.
Printed
Signed
Date
Witness

Exhibit C

Date
-----

Name

JAIL REIMBURSEMENT FEE LOG

SSN

DOB Check issued

Check not issued

If check not issued, reason
therefor

--~------

-----

---------

---------
-------

I
-----

-----

-----

Exhibit D

DATE NAME ADDRESS CITY, STATE RE: NOTICE OF JAIL REIMBURSEMENT FEE Dear Mr.lMs. - - - - -
Pursuant to a settlement agreement in the case of Williams v. Clinch County, No.: 7:04-CV-124-HL (M.D. Georgia), the Clinch County Sheriffs Department has agreed to reimburse certain persons who paid jail reimbursement fees. Those entitled to reimbursement under this agreement are former inmates who paid jail reimbursement fees in the four (4) year period between November 21, 2000 and November 21, 2004, unless such inmates paid the jail reimbursement fees pursuant to a written court order.
You are entitled to a reimbursement fee under this settlement agreement for the amount of money you paid to the Sheriffs Department. In order to claim your reimbursement check, you must come to the office of the Clinch County Board of Commissioners between the hours of9 a.m. and 5 p.m., Monday through Friday. You must bring with you one of the following forms of identification:
(1) A valid Georgia driver's license; (2) A valid identification card issued by a branch, department, agency, or entity of the State of Georgia, any other state, or the United States authorized by law to issue personal identification;

(3) A valid United States passport; (4) A valid employee identification card containing a photograph of the person and issued by any branch, department, agency, or entity of the United States government, this state, or any county, municipality, board, authority, or other entity of this state; (5) A valid employee identification card containing a photograph of the person and issued by any employer of the person in the ordinary course of such person's business; (6) A valid student identification card containing a photograph of the person from any public or private college, university, or postgraduate technical or professional school located within the State of Georgia; (7) A valid United States military identification card; (8) A certified copy of the person's birth certificate; (9) A valid social security card; (10) Certified naturalization documentation. You must claim your reimbursement check in person by [date]. If you fail to
do so, this money will be donated to a charitable organization, pursuant to an order
entered by Honorable Hugh Lawson of the United States District Court for the
Middle District of Georgia.
Sincerely,
Winston Peterson Sheriff, Clinch County

 
 Williams v. Clinch County, Ga., 231 F.R.D. 700 (2005)
231 F.R.D. 700 United States District Court,
M.D. Georgia, Valdosta Division.
Willie Floyd WILLIAMS, Jr., and Mickle Jermaine Jackson, Plaintiffs, v.
CLINCH COUNTY, GEORGIA; Winston Peterson, Sheriff of Clinch County, in his official and
individual capacities; and Sissy Suggs, Deputy Sheriff of Clinch County, in her official and individual capacities, Defendants.
No. 7:04–CV–124. | May 19, 2005.
Attorneys and Law Firms
*701 Amy L. Madigan, Courtland Lewis Reichman, King & Spalding, Sarah Elisabeth Geraghty, Southern Center for Human Rights, Stephen Brooks Bright, Stephen B. Devereaux, Atlanta, GA, for Plaintiffs.
Richard K. Strickland, Brunswick, GA, for Defendants.
Opinion
ORDER
LAWSON, District Judge.
Before this Court is Plaintiffs’ motion to amend their complaint (Doc. 23) and Plaintiffs’ motion to extend discovery (Doc. 24). For the reasons set forth below, both motions are granted.
I. Motion to Amend In response to Plaintiffs’ motion to amend, Defendants indicate that they have no objection to the filing of the amended complaint. Therefore, under Federal Rule of Civil Procedure 15(a), Plaintiffs’ motion is granted. Exhibit 1, which was attached to Plaintiffs’ motion to amend, shall become the operative complaint in this case.
Additionally, Defendants want to know their deadline for answering the amended complaint. With no citation to authority or explanation, Defendants state that “their obligation to file a responsive pleading to the Amended Complaint will begin on the date of entry of an Order ... granting Plaintiffs’ Motion to Amend.” (Defs.’ Resp. Plfs.’ Mot. Am Compl. at 1, Doc. 25) (emphasis added.)

In the specific context of this case, they are correct.
Under Rule 15(a), “a party shall plead in response to an amended pleading within the time remaining for response to the original pleading or within 10 days after service of the amended pleading, whichever period may be the longer, unless the court otherwise orders.” Fed.R.Civ.P. 15(a) (emphasis added). Since the time remaining for response to the original pleading has passed, the 10–day period applies. By its terms, the 10–day period is triggered by “service” of the amended pleading, not just filing it with the Court. But, service and filing with the Court do not have to be mutually exclusive. Therefore, the Court must determine whether the filing of the proposed amended complaint effected service on Defendants.
Regarding who must be served, Rule 5(a) states, “every pleading subsequent to the original complaint unless the court otherwise orders because of numerous defendants ... shall be served upon each of the parties.” Fed.R.Civ.P. 5(a). “Service under Rule[ ] 5(a) ... on a party represented by an attorney is made on the attorney unless the court orders service on the party.” Fed.R.Civ.P. 5(b)(1). To that extent, it is no surprise that amended pleadings may be served on an attorney who represents a party to a lawsuit. Cohn v. Columbia Pictures Corp., 9 F.R.D. 204, 205 (S.D.N.Y.1949).
Regarding how service must be perfected, Rule 5(b)(2)(D) states service can be made electronically “through the court’s transmission facilities.” Fed.R.Civ.P. 5(b)(2)(D). In a standing order entered on November 29, 2004, the Court, speaking through Chief Judge Sands, stated that “[s]ervice will be perfected on registered attorneys in CM/ECF through the Clerk’s Office by electronic means. The registered attorney will receive a ‘Notice of Electronic Filing’ which will be the equivalent of service by mail under Federal Rule of Civil Procedure 5.” (Ord. at 3.) However, “Service by electronic means is not *702 effective if the party making service learns that the attempted service did not reach the person to be served.” (Ord. at 3.)
Here, attached to Plaintiffs’ motion to amend their complaint is a certificate of service stating that Amy Madigan, attorney for Plaintiffs, electronically served the motion to amend complaint upon counsel for Defendants. Also attached to the motion was the proposed amended complaint. Counsel for Defendants appears to be registered in the CM/ECF system. Thus, it seems that Plaintiffs have properly served Defendants with the proposed amended complaint. But, the proposed amended complaint had yet to be accepted by the Court when it was served; thus, the trigger starting Rule 15(a)’s 10–day period is date on which the Court accepts the amended complaint as the operative complaint. The trigger date in
1

Williams v. Clinch County, Ga., 231 F.R.D. 700 (2005)
this case is May 19, 2005, the date this Order was entered on the docket.
II. Motion to Extend Discovery Plaintiffs request the Court to extend discovery to June 22, 2005. Plaintiffs represented that Defendants do not object to the extension. Therefore, the extension is granted; discovery shall end on June 22, 2005.
III. Conclusion

A. Plaintiffs’ motion to amend complaint (Doc. 23) is granted. Exhibit 1, which was attached to Plaintiffs’ motion, shall become the operative complaint in this case. Defendants shall have no longer than 10 days after the entry of this Order to answer the amended complaint.
B. Plaintiffs’ motion to extend discovery (Doc. 24) is granted; discovery shall be extended to June 22, 2005. So ordered.
	  

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CLOSED, LLC1, STAYED
U.S. District Court [LIVE AREA] United States District Court for the Middle District of Georgia (Valdosta)
CIVIL DOCKET FOR CASE #: 7:04-cv-00124-HL

Williams et al v. Clinch County, Georgia et al Assigned to: Judge Hugh Lawson Cause: 42:1983 Civil Rights Act
Plaintiff Willie Floyd Williams, Jr.

Date Filed: 11/02/2004 Date Terminated: 04/17/2006 Jury Demand: Plaintiff Nature of Suit: 440 Civil Rights: Other Jurisdiction: Federal Question
represented by Amy L. Madigan King & Spalding 191 Peachtree Street 40th Floor Atlanta, GA 30303-1763 404-572-2747 Email: amadigan@kslaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Courtland Lewis Reichman King & Spalding LLP 1180 Peachtree Street Atlanta, GA 30309-3521 404-572-4600 Fax: 404-572-5100 Email: creichman@kslaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Sarah Elisabeth Geraghty Southern Center for Human Rights 83 Poplar Street, N.W Atlanta, GA 30303-2122 404-688-1202 Email: sgeraghty@schr.org LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen Brooks Bright 83 Poplar Street, N.W. Atlanta, GA 30303 404-688-1202 Email: sbright@schr.org LEAD ATTORNEY ATTORNEY TO BE NOTICED

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Plaintiff Mickle Jermaine Jackson
V. Defendant Clinch County, Georgia
Defendant Winston Peterson Sheriff of Clinch County, in his official and individual capacities

Stephen B. Devereaux 191 Peachtree Street Atlanta, GA 30303-1763 404-572-3441 Email: sdevereaux@kslaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
represented by Courtland Lewis Reichman (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Sarah Elisabeth Geraghty (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen Brooks Bright (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Stephen B. Devereaux (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Amy L. Madigan (See above for address) ATTORNEY TO BE NOTICED
represented by Richard K. Strickland P.O. Box 220 Brunswick, GA 31521-0220 912-264-8544 Email: rstrickland@wbrblaw.com ATTORNEY TO BE NOTICED
represented by Richard K. Strickland (See above for address) ATTORNEY TO BE NOTICED

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Defendant
Sissy Suggs Deputy Sheriff of Clinch County, in her official and individual capacities

represented by Richard K. Strickland (See above for address) ATTORNEY TO BE NOTICED

Date Filed 11/02/2004
11/02/2004 11/02/2004 11/02/2004 11/19/2004
11/22/2004 11/23/2004 11/23/2004
11/29/2004 11/29/2004 12/01/2004
12/01/2004 12/02/2004
01/05/2005
01/11/2005

#

Docket Text

1 COMPLAINT against Clinch County, Georgia, Winston Peterson, Sissy Suggs, Filing Fee $ 150, Receipt Number 701375, filed by Mickle Jermaine Jackson, Willie Floyd Williams Jr. Service of Complaint due by 3/2/2005. (Attachments: # 1 Exhibit)(rlw) (Entered: 11/02/2004)
2 Summons Issued as to Clinch County, Georgia. (rlw) (Entered: 11/02/2004)
3 Summons Issued as to Sissy Suggs. (rlw) (Entered: 11/02/2004)
4 Summons Issued as to Winston Peterson. (rlw) (Entered: 11/02/2004)
5 PRELIMINARY INJUNCTION entered with consent of parties. Signed by Judge Hugh Lawson on 11/18/2004. (Attachments: # 1 Certificate of Service)(rlw) (Entered: 11/22/2004)
6 ANSWER to Complaint by Clinch County, Georgia, Winston Peterson, Sissy Suggs.(Strickland, Richard) (Entered: 11/22/2004)
7 Election Form (28 USC 636(c)(1)) sent. (rlw) (Entered: 11/23/2004)
8 RULES 16/26 ORDER: Proposed Scheduling/Discovery order due by 1/7/2005.Signed by Judge Hugh Lawson on 11/23/2004. (Attachments: # 1 Certificate of Service)(rlw) (Entered: 11/23/2004)
9 Arbitration Referral Letter sent 11/29/2004 Arbitration Opt Out Letter due by 12/22/2004}.(trh, ) (Entered: 11/29/2004)
10 ***Arbitration Opt Out Letter by Defendants(Strickland, Richard) (Entered: 11/29/2004)
11 Declination to Proceed Before US Magistrate Judge by Clinch County, Georgia, Winston Peterson, Sissy Suggs. (Strickland, Richard) Modified on 12/2/2004 to correct event(rlw). (Entered: 12/01/2004)
12 DECLINATION to Proceed Before by US Magistrate Judge by Mickle Jermaine Jackson, Willie Floyd Williams Jr.. (Reichman, Courtland) (Entered: 12/01/2004)
13 Notice of Error in Filing (related document(s): 11 Consent (Declination) to Proceed Before by US Mag Judge filed by Winston Peterson, Clinch County, Georgia, Sissy Suggs). (rlw) (Entered: 12/02/2004)
14 MOTION to Certify Class by Willie Floyd Williams, Jr filed by Amy L. Madigan. Response to Motion due by 1/28/2005 Reply to Response to Motion due by 2/14/2005. (Madigan, Amy) (Entered: 01/05/2005)
15 SCHEDULING/DISCOVERY ORDER; Discovery to be complete by 5/22/2005. Signed by Judge Hugh Lawson on 1/11/2005. (rlw) (Entered: 01/12/2005)

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01/12/2005
01/28/2005 01/31/2005 01/31/2005 02/11/2005 03/29/2005 03/31/2005 05/02/2005 05/13/2005 05/16/2005 05/19/2005 05/19/2005 05/19/2005

16 ORDER re 15 Scheduling/Discovery Order. The Joint Proposed Scheduling/Discovery Order stated that the parties were unable to determine when motions would be filed in this case because there is a pending Motion for Class Certification. Therefore, no longer than 10 days after the Court enters an Order on the Motion for Class Certification, the parties SHALL contact the Court to establish deadlines for motions to be filed. Signed by Judge Hugh Lawson on January 12, 2004. (jmb,HL) (Entered: 01/12/2005)
17 RESPONSE filed by Clinch County, Georgia, Winston Peterson, Sissy Suggs re 14 MOTION to Certify Class (Strickland, Richard) (Entered: 01/28/2005)
18 Notice of Error in Filing (related document(s): 17 Response to Motion filed by Winston Peterson, Clinch County, Georgia, Sissy Suggs). (rlw) (Entered: 01/31/2005)
19 RESPONSE filed by Clinch County, Georgia, Winston Peterson, Sissy Suggs re 14 MOTION to Certify Class (Attachments: # 1 Exhibit Exhibit (Draft letter to plaintiff))(Strickland, Richard) (Entered: 01/31/2005)
20 REPLY to Response filed by Willie Floyd Williams, Jr re 14 MOTION to Certify Class (Madigan, Amy) (Entered: 02/11/2005)
21 MOTION for Extension of Time to File amend complaint and join parties. by Willie Floyd Williams, Jr, Mickle Jermaine Jackson filed by Sarah Elisabeth Geraghty. (Geraghty, Sarah) (Entered: 03/29/2005)
22 TEXT ONLY ORDER; no document issued. ORDER granting 21 Motion for Extension of Time. Deadline for amended complaint and to join parties is 05/02/05 . Signed by Judge Hugh Lawson on 03/31/05. (nbp,HL) (Entered: 03/31/2005)
23 MOTION to Amend/Correct 1 Complaint, by Willie Floyd Williams, Jr filed by Amy L. Madigan. Response to Motion due by 5/25/2005 Reply to Response to Motion due by 6/13/2005. (Attachments: # 1 Exhibit # 2 Exhibit)(Madigan, Amy) (Entered: 05/02/2005)
24 MOTION for Extension of Time to Complete Discovery by Willie Floyd Williams, Jr, Mickle Jermaine Jackson filed by Sarah Elisabeth Geraghty. (Attachments: # 1 proposed order)(Geraghty, Sarah) (Entered: 05/13/2005)
25 RESPONSE filed by Clinch County, Georgia, Winston Peterson, Sissy Suggs re 23 MOTION to Amend/Correct 1 Complaint, (Strickland, Richard) (Entered: 05/16/2005)
26 ORDER granting 23 Motion to Amend/Correct, granting 24 Motion for Extension of Time to Complete Discovery. Answer due by 6/3/2005. Discovery to be complete by 6/22/2005.Signed by Judge Hugh Lawson on 05/19/05. (jmb,HL) (Entered: 05/19/2005)
Text only order vacating Doc. 26 due to filing error. (jmb,HL) (Entered: 05/19/2005)
27 ORDER granting Plaintiffs' motion to amend and granting Plaintiffs' motion to extend discovery. (jmb,HL) Modified on 5/20/2005 (rlw, ). (Entered: 05/19/2005)

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05/19/2005 05/20/2005 05/31/2005 05/31/2005 06/16/2005 06/17/2005 06/17/2005 06/21/2005
06/22/2005 07/22/2005 07/25/2005 09/30/2005 09/30/2005

28 AMENDED COMPLAINT against Clinch County, Georgia, Winston Peterson, Patricia Suggs filed by Willie Floyd Williams, Jr, Mickel Jermaine Jackson (Amended Complaint was originally Exhibit 1 to Motion to Amend Complaint)(Attachments: # 1 Exhibit)(rlw) (Entered: 05/20/2005)
Set/Reset Scheduling Order Deadlines: Discovery to be complete by 6/22/2005. (rlw ) (Entered: 05/20/2005)
29 ANSWER to Amended Complaint by Clinch County, Georgia, Winston Peterson, Sissy Suggs.(Strickland, Richard) (Entered: 05/31/2005)
30 AMENDED ANSWER by Clinch County, Georgia, Winston Peterson, Sissy Suggs. (Strickland, Richard) (Entered: 05/31/2005)
31 MOTION for Extension of Time to Complete Discovery by Willie Floyd Williams, Jr filed by Amy L. Madigan. (Madigan, Amy) (Entered: 06/16/2005)
32 Notice of Error in Filing (related document(s): 31 Motion for Extension of Time to Complete Discovery filed by Willie Floyd Williams, Jr.). (sbd ) (Entered: 06/17/2005)
33 MOTION for Extension of Time to Complete Discovery by Willie Floyd Williams, Jr filed by Amy L. Madigan. (Attachments: # 1 Exhibit Excerpts from Deposition Testimony# 2 Exhibit Subpoena)(Madigan, Amy) (Entered: 06/17/2005)
34 TEXT ONLY ORDER; no document issued. For the reasons set forth in plaintiffs' Motion, both requests are granted. Discovery shall end on July 22, 2005. And while leave to depose Robert Ellis, Jr., who is a witness confined in prison, is granted, this Court cannot issue the subpoena to compel his attendance. Under Federal Rule of Civil Procedure 45(a)(2), "A subpoena for attendance at a deposition shall issue from the court for the district designated by the notice of deposition as the district in which the deposition is to be taken." Therefore, plaintiffs must petition the appropriate district court in New Jersey for the subpoena. Signed by Judge Hugh Lawson on 06/21/05. (nbp,HL) (Entered: 06/21/2005)
Set/Reset Scheduling Order Deadlines: Discovery to be complete by 7/22/2005. (rlw ) (Entered: 06/22/2005)
35 MOTION for Extension of Time to Complete Discovery by Clinch County, Georgia, Winston Peterson, Sissy Suggs filed by Richard K. Strickland. (Attachments: # 1 Text of Proposed Order Proposed order re discovery extension)(Strickland, Richard) (Entered: 07/22/2005)
36 ORDER granting 35 Motion for Extension of Time to Complete Discovery. Discovery to be complete by 8/21/2005. Signed by Judge Hugh Lawson on 7/25/05. (nbp,HL) (Entered: 07/25/2005)
37 ORDER denying 14 Motion to Certify Class. Status Conference set for 10/27/05 at 10:00 a.m. in Macon, Georgia.Signed by Judge Hugh Lawson on 9/30/05. (sbd ) (Entered: 09/30/2005)
Set Hearings: Status Conference set for 10/27/2005 10:00 AM in Macon before Judge Hugh Lawson. (sbd ) (Entered: 09/30/2005)

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10/04/2005 10/05/2005 10/05/2005 10/11/2005 10/11/2005 10/11/2005
10/11/2005

38 MOTION for Leave to File Excess Pages for motion for summary judgment by Willie Floyd Williams, Jr, Mickle Jermaine Jackson filed by Sarah Elisabeth Geraghty. (Geraghty, Sarah) (Entered: 10/04/2005)
39 MOTION for Extension of Time to File motion for summary judgment. by Willie Floyd Williams, Jr, Mickle Jermaine Jackson filed by Sarah Elisabeth Geraghty. (Geraghty, Sarah) (Entered: 10/05/2005)
This is a text only entry; no document issued. ORDER granting 38 Motion for Leave to File Excess Pages; limit brief to 30 pages; defendants allowed response brief of 30 pages; parties encouraged to be as succinct as possible. Granting 39 Motion for Extension of Time; Motion for Summary Judgment due by 10/11/2005. Signed by Judge Hugh Lawson on 10/05/2005. (nbp,HL) (Entered: 10/05/2005)
40 MOTION for Summary Judgment by Willie Floyd Williams, Jr, Mickle Jermaine Jackson filed by Sarah Elisabeth Geraghty. Response to Motion due by 11/3/2005 Reply to Response to Motion due by 11/21/2005. (Geraghty, Sarah) (Entered: 10/11/2005)
41 STATEMENT OF UNDISPUTED MATERIAL FACTS filed by Willie Floyd Williams, Jr, Mickle Jermaine Jackson re 40 MOTION for Summary Judgment (Geraghty, Sarah) (Entered: 10/11/2005)
42 MEMORANDUM in Support filed by Willie Floyd Williams, Jr, Mickle Jermaine Jackson re: 40 MOTION for Summary Judgment (Attachments: # 1 Exhibit Deposition of Winston Peterson# 2 Exhibit Defendants' Response to Plaintiffs' Interrogatories# 3 Exhibit Deposition of John Strickland# 4 Exhibit Deposition of Patricia Suggs# 5 Exhibit Summary of Jail Room and Board Charges Collected By Defendants# 6 Exhibit Defendants' Receipt Books# 7 Exhibit Defendants' Jail Log# 8 Exhibit Jail Inmate Handbook# 9 Exhibit Jail Employee Handbook# 10 Exhibit Sign Posted in Jail Notifying Inmates of Administrative Fee# 11 Exhibit Deposition of Ann Wells# 12 Exhibit Darius Dorsey Case File and Declaration# 13 Exhibit Jerome Hodges Case File# 14 Exhibit Shannon Grady Case File# 15 Exhibit Promissory Notes# 16 Exhibit Letter from Winston Peterson to B. Nobles# 17 Affidavit Sherrie Peterson# 18 Exhibit Receipt Register# 19 Exhibit Deposition of Charles Steedley# 20 Affidavit Berrien Sutton# 21 Affidavit Robert Ellis, Jr.# 22 Affidavit Lew Barrow# 23 Exhibit Deposition of Cathy Helms# 24 Exhibit Deposition of Willie Williams, Jr.# 25 Exhibit Promissory Note Signed By Willie Williams# 26 Exhibit Jail Cost Receipt for Willie Williams# 27 Exhibit Entry in Jail Log for Mickel Jackson# 28 Exhibit Deposition of Mickel Jackson# 29 Affidavit Affidavits of Others Who Paid Jail Costs# 30 Affidavit Annette Jackson# 31 Exhibit Jail Receipt for Mickel Jackson# 32 Exhibit Notice of Dismissal of Charges# 33 Exhibit Final Disposition Notice from Clinch Co. Superior Court# 34 Exhibit Souza v. Hodgson)(Geraghty, Sarah) (Entered: 10/11/2005)
43 MOTION for Summary Judgment by Clinch County, Georgia, Winston Peterson, Sissy Suggs filed by Richard K. Strickland. Response to Motion due by 11/3/2005 Reply to Response to Motion due by 11/21/2005. (Attachments: # 1 Appendix Rule 56 Statement of Facts# 2 Appendix Brief in Support of Motion for Summary Judgment)(Strickland, Richard) (Entered: 10/11/2005)

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10/11/2005 10/11/2005 10/11/2005
10/11/2005 10/11/2005 10/11/2005
10/11/2005 10/11/2005 10/11/2005 10/11/2005

44 NOTICE of Filing Depositions by Clinch County, Georgia, Winston Peterson, Sissy Suggs (Strickland, Richard) (Entered: 10/11/2005)
45 DEPOSITION of Ronda Cross-Scott taken on February 22, 2005. Court Reporter: Alexis Yalon filed by Clinch County, Georgia, Winston Peterson, Sissy Suggs.(Strickland, Richard) (Entered: 10/11/2005)
46 DEPOSITION of Suan Gordon taken on February 22, 2005. Court Reporter: Allison B. Murray filed by Clinch County, Georgia, Winston Peterson, Sissy Suggs. (Attachments: # 1 Exhibit Gordon Exhibit 1# 2 Exhibit Gordon Exhibit 2# 3)(Strickland, Richard) Modified text on 10/21/2005 (rlw ). TRANSCRIPT OF DEPOSITION ALSO AVAILABLE IN PAPER FORMAT IN CLERK'S OFFICE. (Entered: 10/11/2005)
47 DEPOSITION of Cathy Helms taken on June 14, 2005. Court Reporter: Allison B. Murray filed by Clinch County, Georgia, Winston Peterson, Sissy Suggs.(Strickland, Richard) Modified text on 10/21/2005 (rlw). TRANSCRIPT OF DEPOSITION ALSO AVAILABLE IN PAPER FORMAT IN CLERK'S OFFICE. (Entered: 10/11/2005)
48 DEPOSITION of Mickle Jackson taken on April 18, 2005. Court Reporter: Linda T. Moore filed by Clinch County, Georgia, Winston Peterson, Sissy Suggs.(Strickland, Richard) Modified text on 10/21/2005 (rlw). TRANSCRIPT OF DEPOSITION ALSO AVAILABLE IN PAPER FORMAT IN CLERK'S OFFICE. (Entered: 10/11/2005)
49 DEPOSITION of Winston Peterson taken on March 15, 2005. Court Reporter: Allison B. Murray filed by Clinch County, Georgia, Winston Peterson, Sissy Suggs. (Attachments: # 1 Exhibit Peterson Exhibit 1# 2 Exhibit Peterson Exhibit 2# 3 Exhibit Peterson Exhibit 3# 4 # 5 # 6 # 7 # 8 # 9 # 10 # 11 # 12 # 13)(Strickland, Richard) Modified text on 10/21/2005 (rlw). TRANSCRIPT OF DEPOSITION ALSO AVAILABLE IN PAPER FORMAT IN CLERK'S OFFICE. (Entered: 10/11/2005)
50 DEPOSITION of Charles Steedley taken on June 14, 2005. Court Reporter: Allison B. Murray filed by Clinch County, Georgia, Winston Peterson, Sissy Suggs. (Attachments: # 1 # 2)(Strickland, Richard) Modified text on 10/21/2005 (rlw). TRANSCRIPT OF DEPOSITION ALSO AVAILABLE IN PAPER FORMAT IN CLERK'S OFFICE. (Entered: 10/11/2005)
51 DEPOSITION of Wink Strickland taken on April 18, 2005. Court Reporter: Linda T. Moore filed by Clinch County, Georgia, Winston Peterson, Sissy Suggs. (Attachments: # 1 # 2 # 3)(Strickland, Richard) Modified text on 10/21/2005 (rlw). TRANSCRIPT OF DEPOSITION ALSO AVAILABLE IN PAPER FORMAT IN CLERK'S OFFICE. (Entered: 10/11/2005)
52 DEPOSITION of Willie Williams, Jr. taken on February 22, 2005. Court Reporter: Allison B. Murray filed by Clinch County, Georgia, Winston Peterson, Sissy Suggs. (Attachments: # 1 # 2)(Strickland, Richard) (Entered: 10/11/2005)
53 MOTION to Certify Class by Willie Floyd Williams, Jr, Mickle Jermaine Jackson filed by Sarah Elisabeth Geraghty. Response to Motion due by 11/3/2005 Reply to Response to Motion due by 11/21/2005. (Attachments: # 1 Exhibit Summary of Jail Room and Board Fees Collected By Defendants# 2

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10/11/2005
10/11/2005
10/12/2005
10/12/2005 10/12/2005 10/17/2005 10/17/2005 10/20/2005 10/21/2005 10/25/2005

Exhibit Deposition of Winston Peterson)(Geraghty, Sarah) (Entered: 10/11/2005)
54 DEPOSITION of Ann Wells taken on February 22, 2005. Court Reporter: Allison B. Murray filed by Clinch County, Georgia, Winston Peterson, Sissy Suggs. (Attachments: # 1 # 2 # 3 # 4 # 5 # 6 # 7 # 8 # 9 # 10)(Strickland, Richard) Modified text on 10/21/2005 (rlw). TRANSCRIPT OF DEPOSITION ALSO AVAILABLE IN PAPER FORMAT IN CLERK'S OFFICE. (Entered: 10/11/2005)
55 DEPOSITION of Sissy Suggs taken on March 15, 2005. Court Reporter: Allison B. Murray filed by Clinch County, Georgia, Winston Peterson, Sissy Suggs. (Attachments: # 1 # 2 # 3 # 4 # 5 # 6 # 7 # 8 # 9 # 10 # 11 # 12 # 13 # 14)(Strickland, Richard) Modified text on 10/21/2005 (rlw). TRANSCRIPT OF DEPOSITION ALSO AVAILABLE IN PAPER FORMAT IN CLERK'S OFFICE. (Entered: 10/11/2005)
56 Notice of Error in Filing (related document(s): 45 Deposition filed by Winston Peterson, Clinch County, Georgia, Sissy Suggs, 54 Deposition filed by Winston Peterson, Clinch County, Georgia, Sissy Suggs, 46 Deposition, filed by Winston Peterson, Clinch County, Georgia, Sissy Suggs, 55 Deposition filed by Winston Peterson, Clinch County, Georgia, Sissy Suggs,, 47 Deposition filed by Winston Peterson, Clinch County, Georgia, Sissy Suggs, 48 Deposition filed by Winston Peterson, Clinch County, Georgia, Sissy Suggs, 49 Deposition, filed by Winston Peterson, Clinch County, Georgia, Sissy Suggs, 42 Memorandum in Support filed by Willie Floyd Williams, Jr., Mickle Jermaine Jackson,50 Deposition filed by Winston Peterson,, Clinch County, Georgia,, Sissy Suggs, 51 Deposition filed by Winston Peterson,, Clinch County, Georgia, Sissy Suggs,, 52 Deposition filed by Winston Peterson, Clinch County, Georgia, Sissy Suggs ). (rlw, ) (Entered: 10/12/2005)
57 Certification of Need to File Discovery in Support of Plaintiffs' Motion for Summary Judgment by Willie Floyd Williams, Jr, Mickle Jermaine Jackson.(Geraghty, Sarah) (Entered: 10/12/2005)
58 Request to Willie Floyd Williams, Jr, Mickle Jermaine Jackson to file original discovery document(s) by Clinch County, Georgia, Winston Peterson, Sissy Suggs.(Strickland, Richard) (Entered: 10/12/2005)
59 DEPOSITION of Willie Floyd Williams taken on 2/22/2005. Court Reporter: Allison B. Murray filed by Winston Peterson, Sissy Suggs.(rlw ) (Entered: 10/17/2005)
60 DEPOSITION of Ronda Cross-Scott taken on 2/22/2005. Court Reporter: Allison B. Murray filed by Winston Peterson, Sissy Suggs.(rlw) (Entered: 10/17/2005)
61 NOTICE of Filing Exhibit Attachment by Willie Floyd Williams, Jr, Mickle Jermaine Jackson (Geraghty, Sarah) (Entered: 10/20/2005)
62 EXHIBITS 6 and 7 by Willie Floyd Williams, Jr, Mickle Jermaine Jackson re 40 MOTION for Summary Judgment. (rlw ) (Entered: 10/21/2005)
63 RESPONSE filed by Clinch County, Georgia, Winston Peterson, Sissy Suggs re 53 MOTION to Certify Class (Strickland, Richard) (Entered: 10/25/2005)

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10/31/2005
11/01/2005 11/14/2005
11/15/2005 01/17/2006
01/17/2006 01/18/2006 03/09/2006 03/14/2006
03/15/2006 03/24/2006 04/14/2006 06/26/2006

64 ORDER STAYING CASE for thirty days. All deadlines extended thirty days from this date. Signed by Judge Hugh Lawson on 10/31/2005. (nbp,HL) (Entered: 10/31/2005)
Set/Reset Deadlines: Notice of Compliance due by 12/1/2005 - case stayed for 30 days; re-set deadlines, if necessary. (rlw) (Entered: 11/01/2005)
65 ORDER referring case to Magistrate Judge G. Mallon Faircloth for mediation; case stayed until further order of Court. Signed by Judge Hugh Lawson on 11/14/2005. (nbp,HL) (Entered: 11/14/2005)
Set/Reset Deadlines: Parties to provide Status Report by 1/13/2006. (rlw ) (Entered: 11/15/2005)
66 ORDER EXTENDING STAY ordered 11/14/2005. Parties to report to Court not later than 3/13/2006. Signed by Judge Hugh Lawson on 1/17/2006. (nbp,HL) (Entered: 01/17/2006)
67 Letter from Sarah Geraghty regarding status of case. (rlw ) (Entered: 01/18/2006)
Set/Reset Deadlines: Status Report due by 3/13/2006. (rlw ) (Entered: 01/18/2006)
69 Letter from Richard Strickland re: continuance of stay. (rlw ) (Entered: 03/15/2006)
68 ORDER extending the stay previously entered by the Court and directing the parties provide a status report no later that 3/27/2006 . Signed by Judge Hugh Lawson on 3/14/2006. (nbp,HL) (Entered: 03/14/2006)
Set/Reset Deadlines: Status Report due by 3/27/2006. (rlw ) (Entered: 03/15/2006)
70 Letter from Sarah Geraghty regarding status report of case. (rlw) (Entered: 03/30/2006)
71 Consent ORDER. Signed by Judge Hugh Lawson on 4/14/06. (Attachments: # 1 Exhibit)(sbd ) (Entered: 04/17/2006)
NOTICE TO COUNSEL: This case has been closed, therefore deposition transcripts filed in paper form in this case, with the exception of those filed by court reporters or any other transcripts filed electronically, will be destroyed unless the filer(s) of those documents make arrangements with the Clerk's Office to retrieve them before the scheduled disposal date. Depositions to be destroyed on 7/11/2006. (rlw ) (Entered: 06/26/2006)

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