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FILED IN SCLERKS
~ OFFICE
vs.
file Plaintiffs' Brief In Response To Defendants Georgia Power, Brian P . Watt and
FACTS
Plaintiffs filed this action, not as an appeal as the Defendants attempt to have
this Court believe, but as a separate action resulting from "extrinsic fraud", and
other "illegal acts" Plaintiffs are not claiming a legal error by the state court, they
These defendants claim that Plaintiffs have failed to state a valid cause of
action. Although Plaintiffs believe they have properly plead, should this Court
decide that defendants are correct, Plaintiffs MOVE this Honorable Court for a
chance to amend their pleading in order to plead the causes of action correctly
they attempt to cloud the issues with matters wholly irrelevant to this case . They
prejudice against the Plaintiffs and thereby manipulate the Court and it's processes .
These defendants begin their "Memorandum of Law . . ." with "No possible
construction of the rambl ing allegation s. . ."; "With this action , . . . perpetuate a
disturbing trend . . . pro se lit igants, . . individual unfortunate enough . . ."; "Indeed
Plaintiffs themselves are no strangers to this very tactic" ; " . . .should not allow
Plaintiffs' misuse of the judicial system . . ." (MTD pg .2) These Defendants make
several unsubstantiated, false statements with the intent to mislead this Court . (See
These defendants would have Courts of Georgia and the United States
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violate the Rights of the disabled, the Rights of pro se litigants, as well as all the
Rights of any other citizen with whom they disagree . Denying disabled, pro sea
guaranteed Rights see Tennessee v. Lane 541 U.S . 513 (2004); U.S. v. Georgia,
" . . .interference with access to the judicial process, and procedural due process
violations. . ."
meant to prejudice this Court and has no relevance to this case . These defendants
should take note that the 11 '' Circuit Appeal has not been dismissed or denied, but
is c urrently pending,.
Plaintiffs were forced to file the Superior Court action because of Matt
Goff's allegations to the State Patrol Troopers . Plaintiffs discussed the matter with
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law enforcement personnel, who assured them that should anything happen to Matt
Goff,S Plaintiffs would be the major suspect. Plaintiffs have also discussed Matt
Goffls allegation with Duluth Deputy Chief of Police - Colonel Brian Carney6 who
agreed that Plaintiffs would be the major suspects, and that should there be no
Wells; the 1941 document has the name as R . F. Wells; There was neither a Dr. R -
F. Wells (GA Power's Verified Answers pg. 31, ¶6 "Dr. R. F. Wells"), nor R. F.
Wells (GA Power's Verified Answers pg. 33 ¶15 "Mr . R F. Wells") in Stone
Mountain at any time and neither document has proper information on it. (Comp.
Pg. 8). George Ril ey Wells was the one who had owned land in Stone Mountain,
but not as far down as Sheppard Road . (Response to Superior Court and Judge
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Carney had advised on the proper procedure of photographing the signature in case
there was no way to get a copy of it . Plaintiffs had already filled out the agreement
"Exhibit 1 " hereto emails, agreement, and credentials concerning Colonel Carney.
and correct copy of the Motion as "Exhibit 2". Defendants, to date have refused
to address the document . Five months after being served with Summons and
property . The Verified Answers and counterclaims were never and amended to the
Verified Answers .
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O.G.C.A. §9-11-15:
(a) Amendments . A party may amend his pleading . . .before the
entry of a pretrial order . . .A party may plead or move in response
to an amended pleading. . . (b) Amendments to conform to the
evidence. When issues not raised by the pleadings are tried by
express or implied co nsent of the parties, . . .Such amendment
. . .may be necessary to cause them to conform to the ev idence . . .
These defendants make false representation to this Court MTD pg .4: "As
Power would be unnecessary . (Id. at x¶33,34,65). The statements are lies . These
Defendants further state : " . . .noticed depositions, but Plaintiffs refused to appear .
(Id. at ¶¶5$-60,76 )"; " . . .merits of the case decided before any significant discovery
had occurred .10 (See generally, id. at Exhibit 12 ; ¶¶31, 43, 44) .51-
". . .inundated . . .with motions . . ." Obviously, as was done in Superior Court,
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defendants take things out of context as to what is said to manipulate the Court,
and looking at the Docket Report clearly shows that Georgia Power over-burdened
photographs, video, etc . Rather than contact Plaintiffs, defendants sent a discovery
dispute letter dated February 19'h attached hereto is the original letter "Exhibit
3';" on the l~` page, there are four items, Plaintiffs called Watt, and complied
with the demands of the Feb. 19th letter. Defendants then claimed that the letter
made requests for copy of video tape, which was not in the Feb . 19`h letter. 12
The original letter from Defendant Watt dated February 27 attached hereto
as "Exhibit 4" pg.2 shows that there had been agreement that there would be no
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Plaintiffs filed Motion to Strike (3/12/2008)3 and filed for a protective order
1) There was no Discovery Dispute, the items in the letter had been
complied with ;
2) Discovery requests were in violation of O .C.G.A. §§9-11-26
through 9-11-37, and U.S.C.R. . Rules 5 .3, and 6 .4;
3) that the same 6.4 letter was used for both Motions to Compel ;
4) and that the Watt had perjured himself in both Certifications
Plaintiffs have attached as "Exhibit 5" true and correct copies of Plaintiffs'
13 plaintiffs mailed the Motion U .S .P.S. Priority, Certified Mail, the Court received
the Motion on March 8, 2008 but held without filing until March 12th and didn't
mail back Plaintiffs' copy although there was postage pre-paid, self-addressed
envelope to do so ; no explanation was given .
14 Plaintiffs Objected to Continuance ; Motion to Strike, Motion to Stay were not
ruled on until the Order dismissing Plaintiffs' complaint, Motion for Continuance
has never been ruled on.
's Plaintiffs responded to Motion for Continuance citing bad-faith attempt to delay
and that depositions will not legitimize a falsified fraudulent document .
16 Without ruling on any other Motions Judge Becker jumped to Defendant's
Motion to Compel filed 03/31/2008 and their second Motion to Compel filed
04/15/2008, without a hearing scheduled and denying Plaintiffs their Rights of due
process, ruled on both Motions in the same Order, in favor of Defendants on May
05/28/2008, then didn't notify Plaintiffs of the decision .
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. . . AND
,, . . .Certification of Compliance . . . . Defendants d iscovery requests were in
violation of Georgia statutes which require a definite date and time for response .
Plaintiffs further showed that defendants and their attorneys had perjured
themselves in every Verification, Affidavit, and Certification filed with the court
and were doing so to manipulate the court and the Court's process which in turn
violated Plaintiffs' due process rights and asked to have the offensive documents
stricken."
"It is the responsibility of the trial court to ensure that the system is
not manipulated by any party. . ." Carson v. State, Ga. App . (SE2d)
(Case No. A0314Q3, 2003) ;
"A trial court also is authorized "[t]o preserve and enforce
order . . .to prevent . . . and hindrance to its proceedings ." Robinson v.
Becker, Ga. App. (SE2d) (Case No . A03A2524, 2004).
See also judicial gEkMeh
"is directed against those who would attempt to manipulate the
court system through the calculated assertion of divergent sworn
positions . . ." Johnson Service Co. v. Transamerica Insurance
Co., 485 F.2d 164, 174 (5' Cir . 1973); Chrysler Credit Corp. v.
Rebhan, 842 F.2d 1257, 1261 (11d' Cir. 1988);
"The doctrine is designed to prevent parties from making a
mockery of justice by inconsistent pleadings ." American Nat'I
Bank of Jacksonville v. FDIC, 710 F.2d 1528, 1536 (10' Cir .
1983)
The case was stayed, there could be no ruling on Motion to Compel without
1 ' The Motions to Strike the offensive, perjured filings was ignored by the Court .
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hearing that was neither on the Motion Calendar , nor shown in "Scheduled Events"
on the Docket. Plaintiffs Petitioned the Court For a Docket Correction a true and
correct copy is attached as "exhibit 6" on pg.3 Plaintiffs complain that neither the
Docket Report nor the Scheduled Events showed the hearing . 19 After filing the
Petition, several entries were corrected, there still was no scheduled events and the
18 To Plaintiffs' knowledge, to date there still has been no ruling on the Motion for
Continuance . Of course, there is no guarantee that Plaintiffs would have been
informed as shown by the Superior Court's actions in that case .
19 U.S.C.R. Rule 2. 4 " . . .the person who is charged with the responsibility of
setting and scheduling all hearings and trials . . .a particular judge. Each calendar
clerk carries out those duties under the supervision of the assigned judge, . . ." See
also Internal Operating Procedures Degalb County Superior Court Stone
Mountain J udicial Circuit 8 .C . Duties of Court Clerk and Calendar Clerk
" . . .The scheduling of any hearing . . .shall be the responsibility of the assigned
judge's calendar clerk, acting under the direction of the assigned judge ."
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The case of Brown v. C & S Nab Bank, 245 Ga. 515 (265 S .E.2d
791) (1980), provides " . . .this Court held that publishing a trial
calendar with the case name on it but without the attorney's name
on it did not meet the trial court's duty . . . Id. at 518 ."
"This Court has held that notice by publication in the Fulton
County Daily Report is . . . Spyropoulos v. John Linard Estate, 243
Ga. 518 (255 S .E.2d 40) (1979).. ."
Plaintiffs cannot be at fault for missing a hearing that was neither on the Motion
"Pro se pleadings are held to a less stringent standard than pleadings drafted
States , 148 F .3d 1262, 1 263 (11 'h Cir. 1998) (per curiam). See also the following :
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(1972)." Hugh es v. Roth, 371 F. Supp . 740, 741 (D .C. Pa. 1974).
support of their MTD and state "While the Court construes . . ., the Court is
issued in other legal proceedings . . ." (MTD pg. 3 fn2) Just as these defendants did
in Superior Court, by their actions they ask for Summary Judgment, but by their
words attempt to prevent Summary Judgment : "In examining the merits of the
claims, the court must . . . `look only to the facts alleged in the complaint and not
Of course, proceeding as pro se, Plaintiffs are unsure whether or not this
case will be converted and requests this Court to make the determination whether
or not such conversion will take place and inform the parties if conversion is taking
place so that these Plaintiffs can take the appropriate steps for Summary Judgment .
Plaintiffs have shown that GA Power has never had an easement concerning
Plaintiffs' property, yet continue to claim they do . (MTD pg. 3 : " . . .Georgia
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It has been held that where as here, the allegations are that these defendants
conspired with Judge Becker, her law clerk and calendar clerk . Judge Becker and
her clerks performed official acts, the acts were the product of a corrupt conspiracy
with these defendants, the acts were performed without consequence were illegal
acts designed to have Plaintiffs' case dismissed for a fictional discovery dispute .;
link the illegal acts that plagued the Superior Court proceedings, Plaintiffs believe
they showed the link . (Compl. pgs. 8-16) Plaintiffs have attached a true and
correct copy Plaintiffs' Statements For The Record . . . as "Exhibit 7"20. Judge
the Court and it's process without interference, which resulted in Plaintiffs'
intentional gross violations of Plaintiffs' right to due process of law and ultimately
Private parties who corruptly conspire with a judge in connection with such
conduct are thus acting under color of state law within the meaning of § 1983 .
20 Plaintiffs attempted to have Judge Becker address the illegal acts numerous
times .
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" . . . `under color of state law for §1983 purposes does not requite
that the defendant be an officer of the state . It is enough that he is a
willful participant in joint action with the State or its agents .
Private persons, jointly engaged with State officials in the
challenged action, are acting "under color" of law for purposes of
§1983 actions." Adickes v. S. H. Kress & Co., 398 U/S/ 144, 152
(1 970); United States v. Price, 383 U .S. 787, 794 (1966)
See also
Sparks v . Sparks, el., al., 101 S . Ct. 183, 449 U.S. 24 (U .S . 1980)
*fn5 :
"Title U.S .C. §242, the criminal analog of §1983, also contains a
color-of-state-law requirement and we have interpreted the color-
of-state-law requirement in these sections coextensively . Adickes
v. S. H. Kress & Co., supra, at 152, n . 7. A state judge can be
found criminally liable under §242 . . . See Imbler v. Pachtman, 242
U.S. 409, 429 (1976); O'Shea v. Littleton, 414 U.S. 488, 503
(1974) . In either case, the judge has acted under color of law ."
These defendants' MTD pgs. 11-12 show seven of the instances referenced
by Plaintiffs complaint starting with "Superior Court failed . . ." see the following:
O.C.G.A. § 44-2-77
While the cause is pending before the examiner of titles or at any
time before final decree, the judge, or the examiner with the approval
of the judge, may require the land to be surveyed by some competent
surveyor and may order durable bounds to be set and a plat thereof to
be filed among the papers of the suit . Before such survey is made, all
adjoining landowners shall be given at least five days' notice . The
petitioner or any adjoining owner dissatisfied with the survey may file
a protest with the court within ten days from the time the plat is filed ;
and thereupon an issue shall be made up and tried as in case of protest
to the return of land processioners .
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Pavesich v. New England Life Ins Co., 122 Ga. 190, 197 (50 S .E.
68) (1905) held :
". . . that Georgia citizens have a "liberty of privacy" guaranteed by
the Georgia constitutional provision which declares that no person
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These defendants also reference Plaintiffs' claims about the Fourth and Fifth
Amendments (MTD pg. 13). The Supreme Court has explained, "[c]ertain wrongs
effect more than a single right and accordingly, can implicate more than one of the
The Supreme Court has held that a seizure of property occurs whenever
that property" United States v. Jacobsen, 466 U.S. 109, 113 (1984).
In James Daniel Good Real Property and Soldal, "the seizure of property
Amendment and the Fifth ." James Daniel Good Real Prop., 510 U.S. at 50
U.C.G.A. §44-2-64
The petition and amendments thereto shall be signed and sworn to
by each petitioner, or, in the case of a corporation, by some officer
thereof, . . . . It shall contain a full description of the land, its
valuation, and its last assessment for county taxation ; shall show
when, how, and from whom it was acquired, a description of the
title by which he claims the land, . . .all known liens, interests, and
claims, adverse or otherwise, vested or contingent. Full names and
addresses, if known, of all persons . . .including adjoining owners
and occupants, . . . The description of the land given in the petition
shall be in terms which will identify the same fully and . . . describe
the same as permanently . . .If the land is in a portion of the state in
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which land is divided into land districts and lot numbers by state
survey, the petition shall state the number of the land district and
the lot number or numbers in which the tract is located . Before
passing a decree upon any petition for registration, the judge, on his
own motion or upon the recommendation of the examiner, may
require a fuller and more adequate description or one tending more
permanently to identify the tract in question to be included in the
petition by amendment ; and if, in the discretion of the court, it shall
be necessary, the judge may for that purpose require a survey of the
premises to be made and the boundaries marked by permanent
monuments . The acreage . . . shall be stated with approximate
accuracy; and where reasonably practicable the court may require
the metes and bounds to be stated .
O.C.G.A. §44-2-67
(a)(1) Upon the petition being filed in the office of the clerk of the
superior court in the county where the land is located, the clerk
shall issue a process directed to the sheriffs . . . requiring all of the
defendants named . . . and all other persons "whom it may concern"
to show cause before the court on a named day not less than 40 nor
more than 50 days from the date thereof why the prayers of the
petition should not be granted and why the court should not proceed
to judgment in such cause. The clerk shall make the necessary
copies of the petition and process for service . . . .
O.C.G.A. §44-2-77
While the cause is pending before the examiner of titles or at any
time before final decree, the judge, or the examiner with the
approval of the judge, may require the land to be surveyed by some
competent surveyor and may order durable bounds to be set and a
plat thereof to be filed among the papers of the suit. Before such
survey is made, all adjoining landowners shall be given at least five
days' notice . The petitioner or any adjoining owner dissatisfied with
the survey may file a protest with the court within ten days from the
time the plat is filed ; and thereupon an issue shall be made up and
tried as in case of protest to the return of land processioners .
C. Constitutionally-Inadequate Process
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impartial and disinterested tribunal" . Marshall v. Jerrico, Inc., 466 U.S. 238, 242
(1980); "an absence of actual bias" In Re Murchison, 349 U.S . 133, 136 (1955) .
"Redress for such a violation is available under 42 U .S.C. §1983 when the
constitutional right is violated under color of state law. A private attorney who
conspires with a state judge is within §1983's purview ." Casa Marie, Inc. v.
Ga. Statues are clear on property, the Court's responsibilities concerning real
property disputes . The facts are clear, Plaintiffs' property was prior to filing suit in
Superior Court, the Court and attorneys refused to abide by Ga . Statutes which
shows that there was a conspiracy, an agreement was made to have Plaintiffs'
complaint dismissed, the plan was carried out through a fictional discovery dispute,
Plaintiffs' case was dismissed without a hearing having been scheduled. Looking
at the Ga. Statutes concerning what would have had to take place before GA Power
could have attempted to claim part of Plaintiffs' property together with the fact that
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Fourth Amendment seizure they have stated a claim for a conspiracy to violate
their constitut ional rights" . See e g., Mendocino Envt'l Or. V. Mendocino
disabled recognized by the State of Georgia as well as The United States under
U.S .C . 42 §12IOL Clearly, Plaintiff Stegeman, a disabled adult and he has been
following:
21 Plaintiffs also point out that the Supreme Court has recognized the "class of one"
claim, first expressly recognized by the Supreme Court in Village of Willowbrook
v. Olech, 528 U .S . 562 (2000) (per curiam) .
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legal-aid program to protect their Rights and property, has gone before the
Superior Court as pro se Plaintiff attempting to protect their Rights and property,
and where the defendants and Judge conspired to violate those rights in order to
allow the already performed illegal acts of falsifying and taking or seizure of real
property .
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As was the case in Miofsky v. Superior Court of California, 703 F.2d 332,
(9th Cir . 1983), Plaintiffs seek the enforcement of that which The United States
Constitution guarantees them and that which GA Power, Superior Court Judge
Becker along with her Law Clerk and Calendar Clerk, acting under color of state
There are no grounds for exempting from the broad reach of §1983 actions
taken by persons acting under color of state law in judicial proceedings, whether
they are judges or others acting on behalf of the court, see the following :
" . . .we know of no ground for exempting from the broad reach of
Sec . 1983 actions taken by persons acting under color of state law
in judicial proceedings, whether those persons are judges or others
appointed by judges to act on behalf of the court ." Miofsky v.
Superior Court of California, 703 F.2d 332, (9h Cu . 1983) :
"However, civil rights actions under Sec . 1983 are among the
exceptions . . . that have been "expressly authorized by Act of
Congress," id . See Mitchum v Foster, 407 U.S . 225, 92 S .Ct.
21511 32 L.Ed.2d 705 (1972)."
"Thus, as Mitchum makes clear, Congress has not rendered federal
courts impotent in the face of an infringement of constitutional
rights by the judicial arm of state government. As the Court said in
Mitchum, "[t]he very purpose of Sec . 1983 was to interpose the
federal courts between the States and the people, as guardians of
the people's federal rights--to protect the people from
unconstitutional action under color of state law, 'whether that action
be executive, legislative, or judicial .' " 407 U .S . at 242, 92 S .Ct. at
2162 (quoting Ex pane Virginia, 100 U.S. 339, 346, 25 L .Ed. 676
(1879) (emphasis added)) ."'
"In light of Mitchum, we conclude that district courts have subject
matter jurisdiction over suits brought under Sec . 1983 even when
the state action allegedly violating plaintiffs federally protected
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GA Power has the right to properly condemn real property . In this case the
private property belonging to Plaintiffs was seized and taken by fraudulent means,
without just compensation . Five months after being served with Summons and
easement document without having ever addressed the fact that the document was
V . ROOKER-FELDMAN
Plaintiffs in the case at bar are claiming "extrinsic fraud" and other "illegal
acts" which prevented them from presenting their claim in court, Rooker-Feldman
does not apply . Plaintiffs are not claiming a legal error by the court, they are
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Much like the claim made by Trust in Weis Builders, Inc. v. Kay S. Brown
Living Trust, 263 F. Supp. 2d 1197, 1202, 1204 (D. Colo . 2002) which appealed
that the Booker-Feldman doctrine did not apply so as to deprive the district court
of subject matter jurisdiction, and that dismissal should be denied, The appellate
The Plaintiffs in this case do not seek to set aside judgment of Superior
Court based on legal errors by the court; they seek to set aside the judgment based
on extrinsic fraud by the defendants that produced the judgment . Plaintiffs also do
not seek damages based on legal error by the court ; they seek damages based on
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Plaintiffs have shown that what the Defendants attempted to do and have
done concerning real property could not be done either through "Reformation" or
"Declaratory Judgment" ; but could only be done using proper process of O.C.G.A.
§§ 44-2-1 through 44-2-77 . In fact, without following the procedure, the Superior
Court lacked jurisdiction over Plaintiffs' private property . Defendants could not
use the proper procedure due to the "punishments" involved for falsifying real
B. Obstruction
is willful intent to obstruct justice of the illegal acts shows throughout the
Response .
Jowers v. State, 225 Ga. App. 809 (2) (484 SE2d 803) (1997), the
language therein unambiguously prohibits an individual from
making or using any false writing or document, without regard to
the identity of the individual who initially made or subsequently
used the false document . . Because there is no limitation placed on
the prohibited conduct of "making or using" false documents in
OCGA 16-10-20, the statutory language does not support the Court
of Appeals' holding that prosecution for use of a false document is
limited to those situations in which an accused uses false
documents prepared by another . State v. Johnson, supra at 837 .
22 All sworn
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CONCLUSION
These Pro Se Plaintiffs believe that they properly plead their complaint,
have properly addressed MTD and MOVE this Honorable Court to DENY
Defendants' MTD. Further, should this Court decide that Plaintiffs failed to
properly plead, Plaintiffs MOVE this Court to be lenient and allow them to Amend
their complaint .
By:
J
Mountain, GA 30083
(770) 879- 8737
By: I6 Ul
~ET D. MCDON4D, Pro Se
~ 82 1 Sheppard Rd
Stone Mountain, GA 30083
(770) 879-873 7
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Case 1:08-cv-01971-WSD Document 9 Filed 07/11/2008 Page 26 of 26
In compliance with LR 7 .ID, N.D. Ga., I certify that the foregoing Motion
has been prepared in conformity with LR 5 .1, N.D. GA. This Motion was prepared
with Times New Roman (14 point) type, with a top margin of one and one-half
(1 .5") inches and a left margin of one (I") inch, is proportionately spaced .
"II JAC
JAMES B. STE MAN, Pro Se
JANET D . MC NALD, Pro Se
821 Sheppard Rd
Stone Mountain, GA 30083
(770) 879-8737
Jam
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