Vous êtes sur la page 1sur 29

Case 1:08-cv-01971-WSD

Document 12

Filed 07/25/2008

Page 1 of 29

CJ

FILED Iii c~ERlt'S OFFICE


tJ S.Q. C. - A~lan la

IN THE UNITED STATES DISTRICT COURT


FOR THE NORTHERN DISTRICT OF GEORGIA,

JUL 2 5 2008

Atlanta Division

1AI~S t~li'fEP1, Clerk

JAMES B. STEGEMAN,
JANET D. MCDONALD,
Plaintiffs

CIVIL ACTION v

FILE NO : 1 : 08-CV-0197 1-WSD

vs.

SUPERIOR COURT, et., al.,


Defendants

PLAINTIFFS' INITIAL DISCLOSURES


(1) State precisely the classification of the cause of action being filed, a
brief factual outline of the case including plaintiffs' contentions as to what
defendant did or failed to do, and a succinct statement of the legal issues in the
case.
This case s_ br~ before the Court for Civil and .Constitutional Rights violations .
The defendants conspired to violate and violated Plaintiffs Fourth, Fifth, and
Fourteenth Amendment Rights, Rights to Equal Protection, Due Process of Law
and _ ille ga l acts to have a case in Superior Court dismissed. Defendants, most of
which are officers of the Court obstructed process and 'ustice through cons irac
malicious fraud, malicious and willful misrepresentation, use of for ged/fraudulent
documents and e ' Documents to be filed were held before film or not
filed at all . Plaintiffs have been denied unfettered access to the Courts and Plaintiff
Stegeman as a disabled adulthas been denied mean ingful access to the
Courts.

Case 1:08-cv-01971-WSD

Document 12

Filed 07/25/2008

Page 2 of 29

(2) Describe in detail all statutes, codes, regulations, legal principles,


standards and customs or usages, and illustrative case law which plaintiff contends
are applicable to this action .
Violations of 42

1982, 1983, 1985 . Illegal acts by the Defendants including

Conspiracy to violate and violation of Plaintiffs' Fourth, F ifth and Fourteenth


Amendment Rights ; retal iation against Plaintiffs_ for naming as a defendant Judge
Becker; violati ons o f Rights and retaliation aga inst a member of a protected class
of persons for seeking protection of l i fe liberty

d roe and seeking redress

for Rights violations. Through conspiracy, fraud, pej_ury, _illegal_ acts, and falsified
evidence Plaintiffs were denied due process of law . All defendants have moved to
dismiss . Claims of Rocker-Feldman Younger Abstention were made Plaintiffs
addressed the i ssues in their Response to Motion To Dismi ss .,

The "Georgia

Power" defendants moved to d ismiss, submitting several documents and stated that
Plaintiffs ask for rel ief which cannot be ted under most circumstances the
motion to dismiss is transformed into a Summary Judgment Motion. The
"Superior Court" or "State Defendants" have moved to dismiss claiming Judicial
Immunity, ante-item notice as well as other issues . Plaintiffs can show that
Superior Court Stone Mountain Judicial Circuit has a "policy" to treat Plaintiff
Stegeman, a disabled adult, thereby a protected class differently, and that the
Supreme Court does recognize a class of one. Plai ntiffs can further show why all
issues raised b Defendants are meritless.
(3) Provide the name and, if known, the address and telephone number of
each individual likely to have discoverable informat ion that you may use to
support your claims or defenses, unless solely for impeachment, identifying the
subjects of the information . (Attach witness list to Init ial Disclosures as
Attachment A .)

-2-

Case 1:08-cv-01971-WSD

Document 12

Filed 07/25/2008

Page 3 of 29

(4) Provide the name of any person who may be used at trial to present
evidence under Rules 702, 703, or 705 of the Federal Rules of Evidence . For all
experts described in Fed . R Civ. P . 26(a)(2)(B), provide a separate written report
satisfying the provisions of that rule . (Attach expert witness list and written
reports to Responses to Initial Disclosures as Attachment B)
(5) Provide a copy of, or a description by category and location of, all
documents, data, compilations, and tangible things in your possession, custody, or
control that you may use to support your claims or defenses unless solely for
impeachment, identifying the subjects of the information . (Attach document list
and descriptions to Initial Disclosures as Attachment C .)
(6) In the space provided below, provide a computation of any category of
damages claimed by you. In addition, include a copy of, or describe by category
and location of, the documents or other evidentiary material, not privileged or
protected from disclosure, on which such computation is based, including materials
bearing on the nature and extent of injuries suffered, making such documents or
evidentiary material available for inspection and copying as under Fed .R.Civ.P. 34.
(Attach any copies and descriptions to Initial Disclosures Attachment D.)

(7) Attach for inspection and copying as under Fed .RCiv.P. 34 any
insurance agreement under which any person carrying on an insurance business
may be liable to satisfy part or all of a judgment which may be entered in this
action or to indemnify or reimburse for payments made to satisfy the judgment .
(Attach copy of insurance agreement to Initial Disclosures as Attachment E.) N/A
(8) Disclose the full name, address, and telephone number of all persons or
legal entities who have a subrogation interest in the cause of action set forth in
plaintiffs cause of action and state the basis and extent of such interest .
Plaintiffs are unaware a any such entities at this time, and reserve the Wight to add

such names should Plaintiffs discover my.

[Signatures on following Page]

-3-

Case 1:08-cv-01971-WSD

Document 12

Filed 07/25/2008

Page 4 of 29

CJ

Respectfully Submitted, this 23 d day of July, 2008,

B. STEGEMA? , o Se
821 S d .
S ne Mountain, GA 30083
(770} -873

By :
T D . MCDON D, Pro Se
821 Sheppard Rd .
Stone Mountain, GA 30083
(770) 879-8737

Case 1:08-cv-01971-WSD

Document 12

Filed 07/25/2008

r]

Page 5 of 29

Attphm end "A"

WITNESS LIST
Name, if known, address and telephone number of each individual likely to
have discoverable information to support claims or defenses, unless solely for
impeachment, and the subjects of the information :

Georgia Power Company : 241 Ralph McGill Blvd., Atlanta, GA 30308


Superior Court Stone Mountain Judicial Circuit : 556 North McDonough St .,
Decatur, GA 30030
Judge Cynthia J . Becker : Superior Court, Stone Mountain Judicial Circuit 556
North McDonough St., Decatur, GA 30030
Brian P. Watt, Troutman Sanders, L.L. P. : 5200 Bank of America Plaza, 600
Peachtree St., N.E ., Suite 5200 , Atlanta, Georgia 30308
Scott A. Farrow, Troutman Sanders, L .L.P: 5200 Bank of America Plaza, 600
Peachtree St., N.E ., Suite 5200, Atlanta, Georgia 30308

Plaintiffs understand the necessity to update this information upon discovery


of information and reserve the right to add the information when it becomes
available.

Case 1:08-cv-01971-WSD

Document 12

Filed 07/25/2008

Page 6 of 29

AtAhment "B"

EXPERT WITNESS LIST


Plaintiffs have inquired with Brain Carney about examining documents and
signatures . Plaintiffs have attached hereto Mr . Carney's credentials and the
communications concerning same . This information was also attached to
Plaintiffs' Response to "Georgia Power Defendant's" Motion to Dismiss . Due to
the fact that Dr . R. F. Wells, R . F. Wells, or Mr. R. F. Wells never existed,
Plaintiffs have been unable to proceedd as yet, but plan to have the easement
documents examined.

Case 1:08-cv-01971-WSD

Document 12

Filed 07/25/2008

Page 7 of 29

October 3
. Duluth M ercha nts Association
(6 :30pm)
-----

Events :
September 29October 01
Fall Festival
September 30
SummerStage
O'Kaysions

October 14
Community Events
Special Operations Force Charity Motorcycle Ride
October 28 Halloween on the Green

Deputy Chief of Police -Colonel . Brian Carnet'


Colonel Canvey has worked in law enforcement for over thirty years . He is a former Chief of Police and the current
President of the American Board of Forensic Document Examiners . His forensic experience brings a unique and valued
asset to the City of Duluth . He started his career in law enforcement in the military and was a CID Agent in the USMC
and later a Special Age* in the U . S . Army Crimina) Investigation Division .
Colonel Carnet' also completed the two year training program in Forensic Document Examination at the U . S . Army
Criminal Investigation Laboratory . He has worked as a line Officer in the DeKaIb County Police Department and as an
Investigator with the DeKalb County Sheriffs Office . Colonel Carnet' has an Associate in Science Degree and a
Bachelor of Arts Degree.
Professional Development
U . S . Marine Corps
Criminal Investigator / MP
DeKalb County, GA
Police Officer
U. S . Army, Criminal Investigation Division
Special Agent
U. S . Army Criminal Investigation Laboratories
Forensic Document Examiner
Institute of Forensic Sciences, Dallas, TX
Forensic Document Examiner
Bureau of Alcohol, Tobacco & Firearms (ATF)
Forensic Document Examiner

1966 - 1972
1972 - 1975
1978
1978-1982
1982 - 1986
1986-1987

DeKalb County, GA
Deputy Sheriff/Juvestigator/Document Examiner
(Fraud and Forgery Unit)
Duluth Police Department
Deputy Chief of Police
Norcrass Police Department
Chief of Police
Carnet' & Hammond (C & H Lab)

1987 -1988

1988-1991
1991-1992
1992-1996

Case 1:08-cv-01971-WSD

Document 12

Major - Uniform Division CommancTer


American Board of Forensic Document Examiners
President

Duluth Police Department


Deputy Chief of Police

Filed 07/25/2008
1996-110
Present
Present

Education & Special Training


University of the State of New York
Associate in Science

U. S . Secret Service
Questioned Documents Course
Institute of Paper Chemistry
US Army Criminal Investigation Command
Certified Documents Examiner
U. S . Army Criminal Investigation Laboratory
Questioned Documents . Course
Federal Bureau of Investigation (FBI)
Questioned Documents Course
Western Illinois University
Bachelor of Arts
Federal Bureau of Investigation (FBI)
Typewriter Examination Seminar
American Board of Forensic Document Examiners
Certified Documents Examiner

1978
1978
1978

1979
1983
1983
1990

Current Professional Affiliations


American Board of Forensic Document Exam iners - President
American Soc i ety of Questioned Document Exam iners - Member
American Academy of Forensic Sciences - Member
Southeastern Association of Forensic Document Examiners - President,
Charter Member
International Association far laentif-ICabort - Member
Georgia State Divi sion of the International Assoc iation for Identification .
Member
International Journal of Forensic Document Examiners - Former
Editorial
Board Member
Former Adjunct Faculty Member - DeKalb Techn i cal Institute , North
and
Central Campus' (Dunwoody and Ctarkston, GA)
Former Adjunct Faculty Member - Rollins College, Public Safety
I nstitute ,
Winter Park, FL

0 2008 Duluth Police Department


3 2 76 Buford Highway I Duluth , GA 30096
Phone : 770 . 476 . 4151

Page 8 of 29

Case 1:08-cv-01971-WSD

Document 12

Duluth Police Department


"Pride in the Old & New"

Menu:

Hom e

About Us
Weddings
Events
To ur
Bri cks
Contact . Us

_.

Public Safety Building :


3276 Bufor d Hwy .
Duluth GA 3 0096
770-4 76-4 151

Meetings:
September 25
City Council
September 27
Zoning Board of Appeals
(7:00pm)
October 2
Planning Commission

Filed 07/25/2008

Page 9 of 29

Case 1:08-cv-01971-WSD

Document 12

Filed 07/25/2008

Page 10 of 29

CARNEY & HAMMOND FORENSIC DOCUMENT LABORATORY, INC.


AGREEMENT FOR EXPERT SE RVICES
THIS AGREEMENT , by and between CARNEY & HAMIMOND FOREN SIC DOC UMENT
LABORATORY , with offices at 4078 Biltmore Woods Court, B uford, Georgia 30519 (hereinafter referred
to as C & H Lab), and

James B Stegeman , with offices located at 821 Sheppard Road, Stone

Mountain, GA 30083 . (hereinafter referred to as EMPLOYER), in the matter of. Stegeman/McDonald


v. .Superior C ourt, et , a1 . U.S. District Court Civil File Action No.

1 : 118-c v_19,78-WSD_

WITNESSETH:
That, in consideration of the premises and covenants, terms and conditions set forth, it is mutually agreed by
the Parties as follows :
1 . EMPLOYER hereby employs C & H Lab, and C & H Lab hereby accepts such employment .
2 . EMPLOYER shall be solely responsible for alll movies due to C & H Lab in accordance with this
Agreement regardless of any agreement EMPLOYER may have with a third party or client concerning
ultimate payment of expert fees and expenses .

EMPLOYER shall pay C & H Lab anon-refundable retainer fee of $1000.0(} upon execution of this
Agreement. This amount represents the minimum fee charged by C & H Lab for its services . This
retainer reserves C & H's offices and services and is not refwidable in the event C & H's services are not
needed or not used in their entirety. However, when C & H Lab renders services, the retainer shall be
applied to time and efforts expended as set out in Paragraph 4 .
4 . The retainer set forth above shall be applied to the total cost of examination which EMPLOYER shall
pay to C & H Lab at the rate of $200 .00 per hour for examination of documents and evidence submitted
to C & H Lab, consultations, research, preparation of exhibits and testimony_
S . EMPLOYER understands that, for work performed outside the offices of C & H Lab, the hourly rate of
$200 .00 will be charged from the time C & H Lab agents or employees leave their offices and until such
time as said agents or employees return . to their offices . EMPLOYER agrees that there will be a
minimum charge of $600 .00, in advance, for each appearance for tri al/deM sition testimony. A 6!/0 late
fee will be added monthly to all balances not paid in full within forty-five (45) days of the bill ing date
and shall not exceed the max imum interest rate allowed by the Laws of the State of Georgia .
6 . At the option of EMPLOYER, C & H Lab agrees to charge a fixed "day rate" of $1600 .00 per day for
testimony, in advance, and/or overnight travel outside the Atlanta metropolitan area . It is agreed by
EMPLOYER and C & H Lab that a "day rate" is defined as any part of a day and not to exceed eight (8)
hours in length. If EMPLOYER chooses the day rate, this selection should be annotated in paragraph
15 upon execution of this Agreement.

Your i ni tials

Page 2

C & H L ab in iti a ls

Case 1:08-cv-01971-WSD

Document 12

Filed 07/25/2008

Page 11 of 29

is

7 . In addition to all payments set forth above, EMPLOYER agrees to reimburse C & H Lab for all
expenses incurred by C & H Lab on behalf of EMPLOYER including, but not limited to, parking
fees, taxi service, courier services, mail expenses, photographic expenses, and laboratory supplies .
EMPLOYER agrees to prepay all airfares, lodging expenses, meals ($65 .00 daily) and rental car if
required and other case related travel expenses as incurred .
C & H Lab shall provide the following services to EMPLOY ER, including but not limited to :
examination and comparison of questioned documents ; a written report enumerating results of such
examinations, if requ ired; sworn testimony relative to said examinations, results and opinions , if
required; preparation of a ny photographic exhibits required to demonstrate the examination results
during testimony .
9 . EMPLOYER shall have the right, at any time, with or without cause, to terminate this Agreement .
In the event of such termination, EMPLOYER shall immediately pay to C & H Lab all sums of
money due C & H Lab per this agreement up to the date of termination .
10-

C & H Lab shall have the right to terminate it's services to EMPLOYER, at any time, with or
without cause . EMPLOYER will hold harmless C & H Lab, it's executives, employees, and agents
in the event of such termination and will protect and indemnify C & H Lab, it's executives,
employees, and agents from any claim or lawsuit by agents, employees, or representatives of
EMPLOYER in connection with their employment . In the event of such termination, EMPLOYER
shall pay C & H Lab all sums of money due C & H Lab per this agreement up to the time of
termination . In the event of such termination, C & H Lab shall protect the confidentiality of
documents or evidence submitted to C & H Lab and C & H Lab shall return all such documents and
evidence to EMPLOYER in accordance with EMPLOYER'S instructions .

11 . EMPLOYER shall indemnify and hold harmless C & H Lab, it's executives, employees or agents
for any acts, decisions, or opinions made by it or them in good faith while performing services for
the Employer in this matter. Employer will pay all expenses, including attorney's fees, actually and
necessarily incurred by C & H Lab in connection with the defense of such act, suit or proceeding .
12 . Upon completion of each service rendered by C & H Lab to EMPLOYER, EMPLOYER shall
immediately pay to C & H Lab all compensation set forth in the foregoing paragraphs that are due
and owing. In the event any sums of money remain unpaid to C & H Lab by EMPLOYER for a
period of forty-five (45) days after termination of services, C & H Lab shall have the right to
protect it's interests in any manner it shall deem appropriate and to collect court costs and attorney's
fees resulting from such necessary actions from EMPLOYER.
1 3 . All notices required to be given herein shall be given by Certified Mail, return receipt requested,
addressed to the persons and parties as stated in this Agreement.
14 . In the event EMPLOYER is a resident of other than the State of Georgia, EMPLOYER agrees that
the venue, in the event of litigation between parties, will be the Courts of the State of Georgia and
EMPLOYER will accept service of process of such Courts .

Yo ur i nitials

Page 3

C & H Lab initials

Case 1:08-cv-01971-WSD

15.

Document 12

Filed 07/25/2008

Page 12 of 29

AMENDMENT :

Dated this day of

2008 .

CARNEY & HAMMOND FORENSIC DOCUMENT LABORATORY, INC .

BY :

OR BY:
President C & H Lab Vice-President /Secretary

BY:
Employer (Client) Date

BY :
Co-Employer (Client) Date

Case 1:08-cv-01971-WSD

Document 12

Filed 07/25/2008

Page 13 of 29

Janet ~D . .cm on alb


j atrteo J6 . 6 tegem a:n
821 Sheppa rd Rd
Stone Mountain, GA 30083
(770) 879-8734
nootkabear@bell south.net

Ju ne 30, 2008
Mr. Brian Carnet'
4078 SiI#more Woods Court
Buford, Georgia 30519

RE : CARNEY & HAMMOND FORENSIC


DOCUMENT LABORATORY, INC .
Dear Mr . Carnet',
James Stegeman and I talked with you last week concerning examination of an

document supplied to us by Georgia Power Company . If you remember, last


Thursday, we were to meet with the curator of Stone Mountain Historic Society

hoping to obtain either pictures or copies of Dr . R. F. Wells signature .


The problem we ran into was :
1) the meeting with the curator was postponed a day ;
2) there was no Dr . R. F. Wells (ever) I managed to get a copy of the Wells' family tree
dating back to the 1500s;
3) the man that owned property in Stone Mountain was George Riley Wells, he is
buried in the Confederate Cemetery, he died in 1906 ;
4) there had been a Dr . James Wells, which was the son of George Riley Wells . but he
died in 1933, and according to Mrs . Wright (curator) he did not own any land ;
5) The Wells family never owned land in Stone Mountain as far down as the road we
are on which is Sheppard Rd .

Case 1:08-cv-01971-WSD

Document 12

Filed 07/25/2008

Page 14 of 29

I am waiting to see what kind of unimaginable story GA Power will come up

with to confront all of these findings .

I feel we will be having the document

examined, due to the other "issues" we expressed to you about the document .
I have filled out the "Agreement" you sent to us and will keep it ready . We so
much appreciate your help in this matter .

Sincerely,
Janet D. McDonald

James B. Stegeman

Case 1:08-cv-01971-WSD

Document 12

Filed 07/25/2008

Page 15 of 29

Ancestors of James Frederick Wells

Generation No. I
1 . James Frederick Wel1sl2, born February 08, 1906 ; died December 1986 in DeKalb County, GA . He
was the son of 2. William Atticus Wells and 3 . Hattie Ladonia Minton . He married (1) Martha Stovall
Clarkez June 21, 1935 in Atlanta, GA . She was born March 23, 1912 in Hazlehurst, GA, and died April 12,
1995 in DeKalb County, GA3 . She was the daughter of Robert Melville Clarks and Ella Beatrice Stovall .

Generation No. 2
2 . Will iam Atticus Welled, born July 19, 18715; died May 05, 1 949 in Fulton Co unty, GA6 . He was the so n
.
of 4. Jam es Alv i n Wells and 5 . Mar y Jane Thompson . He married 3. Rattle Ladonia M inton May 03,18997
y
01,
196
6
in
Fulton
County,
GA9.
She
was
3 . Hattie Ladon ia Mi nton, b orn Septemb er 1 7, 18758 ; di ed Jul
the daughter of 6 . Zachary Taylor Minton and 7. Catherine Lncinda Everette .
Children of William Wells and Hattie Minton are :
i . Jessie Mae WellsfO, born Abt . 190111 .12; died March (?4, 196613
ii . Mary Kate Wells j4, born Abt. September 1908 ; died January 12, 1925 in Atlanta, GA's
iii . William Carl Wellsfe, born March 1 1, 1903; died July 1986 in Fulton County, GA; married Lucy
Rebman; bom 1908; died 1968.
L iv . James Frederick Wells, born February 08, 1906; died December 1986 in DeKalb County, GA ; married
Martha Stovall Clarke June 21, 1935 in Atlanta, GA .

Generation No. 3
4. Jam es Alvin Wells16, born May 11, 1847 in DeKalb, GA ; died May 27, 1933 in DeKaib, GA . He was
the son of 8 . Willie Lea Well s and 9. Drusilla D. Sex ton . He married 5 . Mary Jan e Thom ps on 1866 in DeKalb
County, GA .
5. Mary Jan e Th o m pson 1 ; born April 21, 1843 in DeKaib, GA ; died July 20, 1922 in DeKalb, GA . She
was the daughter of 10 . James Thoma s Thompson and 11 . Luci nda Hardman .
Children of James Wells and Mary Thompson are :
i. George Raymond Wellsi a, born September 19, 1868 .
2 ii . William Atticus Wells, born July 19, 1871 ; died May 05, 1949 in Fulton County , GA; married Rattl e
Ladonia Minton May 03 , 1899 .
iii. James Simpson Wells, born December 09, 1873 .
iv. Coca Estella Wells, born November 11, 1875,
v . Flonni e Leaola Wells, born March 23 , 1876 .

vi . Virgil Mary Wells'6, born November 13, 1881 ; married Herbert O . Aust i n September 02 , 19 2 ,
vii. Charlie Glen Wells, born July 04 , 1884 .

6. Zachary Taylor Mi nton, born Abr . 1849 ; died August 06, 19 35 in Fulton County, GAj7 1 8 . He was th e
son of 12. John Minion and 13. Elizabeth Mart in . He married 7 . Catherine Lucinda Everette .
7. Catherine Lucinda Ev erette, born May 13, 1845 ; died D ecember 03, 1 91 8 .
Ch ildren of Zachary Minton and Catherine Everette are :
i. Mi nnie Minton79, born 1888; marrie d Ja cks on.
ii . Ella Mintan?B, born 18 70 .
iii. Pearl Minion, born 1883 .

iv. Hattie Ladonia M intvn, born September 17, 1 875 ; died July 01, 1966 in Fulton County, GA ; married
Willia m Atticus Wells May 03, 1894.
v. I. ula Mintonal, born 1868 .
vi. Walter Minton, born 1$73 .

Case 1:08-cv-01971-WSD

Document 12

Filed 07/25/2008

Page 16 of 29

Generation No. 4
8. Wilds Lea Wetl s2z, born October 17, 18 05 in Caswell County, NC?23; died May 1 1, 1 88 7 in Stone
M ountain, GA24 . He was the son of 16. Elisha Wells and 1 7 . Elizabeth Mars h . He married 9 . Dra s illa D.
Sex ton January 08 , 1829 in Gw innett County, GA25 .
9. Drus illa D . Seaton,2a, born May 10, 1 813 in Spartanburg County, SC ; died February 28, 1 8 88 in Stone
Mountai n, GA-27 . She was the daughter of I$. William S. Sexton and 19. Mary Woffard .
Children of Will is Wells and Drusilla Sexton are ;
i . E lizabeth Aurelia Well s, born January 03 , 1830.
ii . Mi les Marion Well s, born April 01 , 1833 .
ii i.
iv .
v.
v i.

vi i.

W illard Simpson We lls, born January 15, 1834 .


Willi am Henry Wells, born December 02, 1835 .
George Riley Well s, born September 01, 1838 .
Willis Virgil Wells, born F ebruary 03 , 1841 .

James Alvin Wells, born May 11 , 1847 in DeKalb , GA; died May 27, 1933 in DeKa lb , GA ; married
Mary Jane Thompson 1866 in DeKalb County , GA.

10. James Thoma s Thompson , b orn November 28,1815 ; died December 23, 1904. He was the son of 20.
John E a s ley and 21 . Esther Thomps on. He married 11. Lucinda Hardman November 21, I839 .
11 . Lucinda Hsrdman , born June 09,1818 ; died January 02, 1901 . She w as the daughter 01 722 . John
Hardman and 2 3. Mary Cochran .
Children of James Thompson and Lucinda Hardman are :
5

i. James Thomas Thompson Jr, born November 27, 1840 ; died November O1, 1862 in Virginia .
ii. Mary Jane Thompson, born April 21,1943 in DeKalb, GA ; died July 20, 1922 in DeKalb, GA; married
James Alvin Wells 1966 in DeKalb County, GA .

iii.
iv.
v.
vi.
vii .
viii.

Cynthia Harriet Thompson, born July 25, 1845 .


Elizabeth M. Thompson, born February 11, 1846,
John R . Thompson, born November 06, 1550 .
William Hugh Thompson, born May O5, 1853 .
George Wyatt T'hocnpson, born November 21, 1855 .
Henry Jackson Thompson, born July 07, 1858 .

ix. Alford Riley Thompson, born March 10, 1861 .

12. John Minton, born 179928,29 . He married 13. E lizabeth Martin .


1 3. Eliza be th Martin
Child of John Minton and Elizabeth Martin is :
6
i. Zachary Taylor Minton, born Alst. 1849; died August 06, 1935 in Fulton County, GA ; married Catherine
Lucinda Everette.

Generation No. 5
16. Elisha Welts3a, born Abt . 1771 in Granville County, NC?3 1 ; died April 15, 1860 in DeKaib County,
Georgia32 . He was the son of 32. Miles Wells and 33. Frusanna . He married 17. Elizabeth Marsh October 19,
1792 in Person Co, NC .

17. Elizabeth Marsh, died January 13, 1849 in DeKalb County, Georgia.
Children of Elisha'Wells and Elizabeth Marsh are :
i. Abner Wells, born 1795 .
ii.
iii.
iv.
v.

Eunice Wells, born 1799 .


1ifeiah Wells, born 1801 .
Sarah Wells, born 1803 .
Henry Miles Wells, born 1807 .

Case 1:08-cv-01971-WSD

Document 12

Filed 07/25/2008

Page 17 of 29

1 8. Wi lliam S. Sexton , boii at. 1775 - 1780 in South Carolina ; died Deceo 18, 1840 in Spartanburg
County, SC33 . He was the son of 36 . Thomas Sexton and 37 . E l izabeth . He married 19. Mary Wofford .
19. Ma ry Wofford, born Abb . 1785 in South Carolina33 .
Children of William Sexton and Mary Wofford are :
9
i. Drusilla D . Sexton , born May 10, 1813 in Spartanburg County , SC ; died February 28, 1888 in Stone
Mountain, GA; married Willis Lea Wells January O8 , I829 in Gwinnett C ounty, GA ,
ii. Wes ley S Sexton, born Abt . 1803 .
iii. P _ Morgan Sexton, born November 04, 1807.
iv. Elizabeth Sexton, born Bef. 1820.

v . Polly S exton, born Bef. 1820 .


vi. Louisa Sexton, born Abt. 1824 .
vii. Samuel L . Sexton, born Aht . 1825 .
viii.
ix .

x.

B enjamin Wofford Sexton, born May 20, 1829.


S arah Ann Sexton, born Abt . 1830 .

Efisha 'I 'hornas Sexton, born Abp 1828 .

20 . John Ea s ley, born November 09, 1784 . He wa s the s on of 40. Thomas Easley and 41 . Ecleo Wade.
He married 21 . Esther Thompson December 24, 1814.
21 . Es th er Thomps on, born Novem ber 13, 1782 ; d ied April 15, 1 8 60 in DeKalb County, Georgia34. She
was the daughter of 42. Alexander Thompson and 43. Elizabeth Hodge.
Children of John Easley and Esther Thompson are:
lfl i . James Thomas Thompson, born November 28, 1815 ; died December 23, 1904 ; married Lucinda
Hardman November 21, 1839 .
ii . Marx Thompson, born November 10, 1818.
iii . Elizabeth Thompson, born November 21, 1822 .
iv . Jane Thompson, born November 21, 1 822 .

22 . John Hardman, born Febru ary 15, 1793 . He marri ed 23 . Mary Cochran .
23 . Mary Cochran She was the daughter of 46. Samuel Cochran .
Children of John Hardman and Mary Cochran are :
i . Ewell Hardman, born September 15, 1816.

11

ii .

Lucinda Hard man, born dune 09 , 1818 ; d ied January 02 , 1901 ; married James Thomas Thompson
November 21, 1839.
iii . Nancy Hardman, born August 18, 1820.
iv . Ii ody Harr i ett Hardmnn, born July 09, 1823 .
v.
vi .
vii .
viii .

William Franklin Hardman, born April 12 , 1826 .


Frances Eli zabeth Hardman, born April 28, 1829.
Mary John Hardman, born December 23, 183 1 .
27,i935
Martha Hardman, born January.

ix El iza Jane Hard tan , born February Ol, 1840 .

Generation No. 6
32 . Mi le s Wells3,35,36 . born Abt . 1 740 in Bertie County, NC ; died Abt . 1 826 in Person Co, NC . He was the
son of 64. John Wills . He married 33. F rusann a 1767 .

33. Frusanna
Children of Miles Wells and Frusasnna are :
i . Sarah Wells
ii. Priscilla Wells
iii. Elizabeth Wells
iv. Benjamin Wells, born Abt 1767.
v . Samuel Wells, born Abt 1768 .
16

vi. Elisha Wells, born AM . 1771 in Granville County, NC? ; died April 15, 1860 in DeKalb County,
Georgia; married Elisabeth Marsh October 19, 1792 in Person Co, NC .
vii . Stephen Wells, born Abt . 1777.
viii . Willis Lea Wells, born Abt. 1785 .

Case 1:08-cv-01971-WSD

Document 12

Filed 07/25/2008

Page 18 of 29

ix . Thomas Well s Abt. 1787 .


x Azariah Wells, born Atrt . 181 1 .

36. Thoma s S exton , died Aft. October 17, 1787 in South Carolina. He married 37. El iza b eth .
37. Elizabeth
Child of Thomas Sexton and Elizabeth is :
18

i . William S . Sexton, born Bet 1775 - 1780 in South Carolina ; died December 18, 1840 in Spartanburg
County, SC; married Mary Wofford .

40. Thomas Easley37, born November 21, 1756 in Manakin Co . VA ; died November 21, 1842 in Hickman
County, TN . He was the son of SO. Stephen Easley and 8 1 . Mary Ann David . He married 41 . Ecleo Wade
1782 in Sullivan Co ., TN .

41. Ecleo Wade38, born January 27, 1766 in Manakintown, VA39,39 ; died Abt . 1842 in Gray's Bend, TN .
Ch i ldren of Thomas Easley and Ecleo Wade are:
20

i. John Easley , born November 09,1784; married Esther Thompson December 24, 1814 .
ii. Nancy Easley, born August 23 , 1805 .

42. Alexander Thompson40, born Abt . 1740 in Pennsylvania- He was the son of 84 . James Thompson and
85. Ruth Alexander . He married 43. Elizabeth Hodge.

43 . Elizabeth Hvdge
C hildren of Alexander Thompson and Elizabeth Hodge are:
i. William L. Thompson, born March 14, 1764 ,
ii . James Thompson, born Abt . 1767 .
i ii . Alexander `i'hampsatt Jr, horn 171 .
i v. Robert Thompson, born 1773.
v. John Thompson, born 1775 .
vi . S arah Thomp son, born 1777 .
vii . Ruth Thomp son , born 1780.
21
viii . Esther Thompson, born November 13 , 1782; d ied April 15, 1860 in DeKalb County, Georgia; married
(1) William Lankford January 14, 1$f)2 in Oglethorpe County , GA; married (2) John Easley December
24, 1814 .
ix .

Ma ry Thompso n, born 1786.

46. Samuel Cochran, died Abt . 1842 in Oglethorpe, Georgi a.


Child of Samuel Cochran is :
23 i . Mary Cochran, married John Hardman .

Generation No. 7
64 . John Wrlls4l, born 1705 in Warwick Co, VA ; died Abt. 1762 in Bertie County, NC . He was the son of
128. John Wills and 1 29. E lizabeth .

C hild of John Wills is:


32

i. Miles Wells, born Abt. 1740 in Sertie County, NC; di ed Ab#_ 1826 in Person Co, NC; married Frusanna
1767.

8(}. Stephen Easley42, born Abt. 1 7 18 in M an akintown, Henrico County, V irginia43,44,4s ; died Abt. 1803 in
Kingsport, Tennessee. He was the son of 160. John Easley and 161 . Mary l3en skin . He married 81 . Mary Ann
David .
81. Mary Ann David46, born Abt. 171 6 in Manakintown, He nrico County, VA ; died Abt . 1815 in Sullivan
County, TN. She was the daughter of 162 . Pierre David and 163. Anne .

Case 1:08-cv-01971-WSD

Document 12

Child of Stephen Easley and MARavid is :


40

Filed 07/25/2008

Page 19 of 29

i. Thomas Easley, born November 21, I756 in Manalcin Co . VA; died November 21,1842 in Hickman
County, TN; married Ecieo Wade 1782 in Sullivan Co ., TX

94. James Thompson, born in Ulster. He was the son of 168 . John Thompson and 169. Esther Hale . He
m arried 85. Ruth Alexander.
85. Ruth Alexander
Child of James Thompson and Ruth Al exander is :
42 i . A lexander Thompson, born Abt . 1 74 0 in Pennsy lvania; marr ied Elizabeth Hodge .

Generation No. 8
128 . John Wills, born Abt . 1675 in Warwick Cq VA ; died Abt . 1737 in Warwick Co, VA . He was the son
of 256. Emanuel Wills and 257 . Elizabeth Cary . He married 129 . Elizabeth .
129 . Elizabeth

Ch ild of John Wi lls and Elizabeth is:


64

i. John Wills, born 1705 in Warw ick Co, VA ; died Abt. 1762 in Bertie County, NC .

160. John Eas ley, died April 04, 17 42 in Henrico County, VA . He was the son of 320. Robert Easley and
321 . A n n. He marrie d 161 . Mary Benskin .
161 . Mary Benskin 7, born April 1 6 9(1 *7; die d Bef. 1742 .
Child of John Easley and Mary Benskin is :
SO

i . Stephen Easley, born Abt, 1718 in Manakintown, Henrico County, Virginia ; died Abt . 1803 in
Kingsport, Tennessee ; married Mary Ann David.

162 . Pierre David He marr i ed 163 . Anne .


163 . Anne
Ch i ld of Pierre David and Anne is :
81

i.

Mary A nn David, born Abp 1716 in Manakintown, Henrico County, VA; died Alt 181 5 in Sull ivan
Cou nty, TN ; married Stephen Easley.

16$ . John Thompson He married 169. Esther Hale.


1 69. Esther Hale, born in Ulster? .
C hi ld of John Thompson and Est her Hale is :
84

i. James Thomp son, born in Ulster; married Ruth Alexander.

Generation No. 9
256 . Emanuel Wills48, born Abt . ] 542 in Warwick Co., VA49; died 1697 in Warwick Co, VA . He was the
son of 5 12. John Wells and 513. Elizabeth Fletcher. He married 257 . E lizabeth Cary Abt. 1669 in Isle of
W ight, VA_
257 . Elizabeth Carys0, born 1 653 in Warwick Co., VA; died 1704 in Warwick Co ., VA . She w as the
daughter of 5 1 4. Miles Cary and 5 15. Anne Taylor .
Children of Emanuel Wills and Elizabeth Cary are:
128 i John Wills, bum AFst , 1675 in Warwick Go, VA; died Abt 1737 in Warwi ck Co, VA ; married Elizabeth.
ii. Miles Wills, born Abk 1670 31

iii.
iv.
V.

Emanuel Wills, barn Abt 1672 .


Elias Wi lls, born 1673 .
William Wills, born 1675.

Case 1:08-cv-01971-WSD

Document 12

Filed 07/25/2008

Page 20 of 29

320. Robert Eas ley, born Abt. 1658 ; died December 17, 171 1 in Henrico County, VA . He married 321.
Ann .
321 . Ann
Child of Robert Easley and Ann is :
160
s. John Easley , died April 04, 1742 in Henrico County, VA ; marri ed Mary Benskin.

Generation No. 10
5 12 .
Elizabeth
513.
VA. She

John Wells52, born Abt . 1 617 in England52 ; died 1664 in Warwick County, VA . He married 513.
Fletcher 1 6 4 1 in York Co, VA .
E lizabeth F letcher, born Abt . 1619 i n York County, VA ; died 1664 in Marston Parish , York County,
was the daughter of 1026. John F letc her .

Children of John Wells and Elizabeth Fletcher are :


256 i . Emanuel W2tK born Abt . 1642 in Warwick Co., VA ; died 1697 in Warwick Co, VA ; married Elizabeth
Cary Abt. 1669 in Isle of Wight, VA .
ii . John Wills, born Abt . 1644 .

514. Miles Cary53, born 1622 in Bristol, England ; died June 10, 1667 in Windmill Point, Warwick Co, VA .
He was the son of 1028 . John Cary and 1029. Alice Hobson. He married 515. Anne Taylor 1645 in Warwick
Co, VA .
515. Anne Taylor, born 1620 in England54 ; died Abt. 1657 in Windmill Point, Warwick Ca, VA . She was
the daughter of 1030 . Thomas Taylor .

Child of Miles Cary and Anne Taylor is:


257

i.

Elizabeth ('.ary, born 1653 in Warwick Co., VA ; died 1704 in Warw ick Co . , VA ; married Emanuel Wills
Abt. 1669 in Isle of Wight, VA.

Generation No. I1
1026. John Fletc her, born 1592.
Child of John Fletcher is :
513 i . Elizabeth Fletcher, born Abt . 1619 in York County, VA; died 1664 in Marston Parish, York County,
VA; married John Wells 1641 in York Co, VA .

1028. John Caryss, born Abp 1595 in Bristol, England ; died in Warwick Co, VA . He was the son of
William Cary . He married 1029. Alice Hobson 1619 .
1029. Alice Hobson55, born 1590 in Bristol, England ; died 1635 in Bristol, England. She was the daughter
of Henry Hobson and Alice Davis .
Children of John Cary and Alice Hobson are:
514

i.
ii .
iii .
iv .
v.
vi .
vii .

Miles Cary, born 1622 in Bristol, England; died June 10, 1667 in Wi ndm ill Point, Warw ick Co, VA;
married Anne Taylor 1645 in Warw ick Co, VA.
Henry Cary, born 1618 .
Matthew Gary , born 1620 .
Richard Cary, born 1621 .
Ali ce Gary, born 1625 .
Honor Cary, born 1627.
Mary Cary, born 1630 .

1030. Thoma s Taylor, born 1 595 in England; died Bef. M arch 1 3, 1656/57 in Warw ick Co., VA .

Child of Thomas Taylor is :


515

i . Anne Taylor, born 1620 in England ; died Abt . I657 in Windmill Point, Warwick Co, VA ; married Miles

Case 1:08-cv-01971-WSD

Document 12

Filed 07/25/2008

Page 21 of 29

Cary 1645 in Ock Co, VA

Endnotes
1 . Aurelia Austin (Mildred Austin Finch), "The Wells Family," Typewritten notes in a binder . .
2. Charles Wells (personal knowledge) .

3 . Broderbund Family Archive #110, Vol. 2, Ed. 6, Social Security .


4 . Aurelia Austin (Mildred Austin Finch), The Wells Family, (Private notes in a binder in my possession. This is also
available at the DcKalb County Historical Society, Decatur, GA .) .
5 . Aurelia Austin (Mildred Austin Finch), "The Wells Family," Typewritten notes in a binder .
6 . Georgia Death Certificate, Certificate number 10250, Fulton County .
7 . Aurelia Austin (Mildred Austin Finch), "The Wells Family," Typewritten notes in a binder . .
8 . Social Security Death Index .
9 . Georgia Death Certificate. Number 021485
10. Aurelia Austin (Mildred Austin Finch), "The Wells Family," Typewritten notes in a binder . .
11 . Broderbund Software, Inc ., World Family Tree Yod. 1, Ed, 1 .

12. Federal Census, 1920, ED 93, page 7 .


13 . Georgia Death Index.
14. Aurelia Austin (Mildred Austin Finch), "The Wells Family," Typewritten notes in a binder . .
15. Georgia Death Certificate, Cert . 1324-G, Fulton Co . .
16. Aurelia Austin (Mildred Austin Finch), "The Wells Family," Typewritten notes in a binder . .
17. Fulton County, GA, Death certificate, Certificate number 19911 .
18. Fulton County. GA, Death certificate, Certificate 19911 .

19. US Census, 192flRo11 : T625249 Page : 14A ED: 12 Image:

0111

20
. US Census, 1880 . Census Place : Oak Grove, Fulton, Georgia ; Roll : 19147; Family History Film : 1254147 ; Page: lA;
Enumeration District : 80, Image : 0462 .

21 . US Census, 1880 . Census Place: Oak Grove, Fulton, Georgia; Roll : T9_147 ; Family History Film : 1254147; Page : IA ;
Enumeration District : 80; Image : 0462 .
22. Aurelia Austin (Mildred Austin Finch), "The Wells Family," Typewritten notes in a binder . .
23 . Aurelia Austin (Mildred Austin Finch}, "The Wells Family," Typewritten notes in a binder ., The author cites an old
family bible for some of the info aboutWillis Lea Wells.
24. Brian P . Bivona, Brian P. Bivona website, (Website), "Electronic."
25 . International Genealogical Index, 1985551 .
26. Aurelia Austin (Mildred Austin Finch), "The Wells Family," Typewritten notes in a binder . .
27. Brian P . Bivona, Brian P. Bivona website, (Website), "Electronic."
28. Census, 1850, Margin County, GA census records.
29. Census, 1850.
30. Mildred Austin Finch (Aurelia Austin), A Georgia Boy with Stonewall Jackson, (Privately published) .
31 . Aurelia Austin (Mildred Austin Finch), "The Wells Family," Typewritten notes in a binder ., The Wells Family, by
Aurelia Austin .
32. Aurelia Austin (Mildred Austin Finch), "The Wells Family," Typewritten notes in a binder . .
33 . Brian P . Bivona, Brian P. Bivona website, (Website), "Electronic ."
34. Mildred Austin Finch (Aurelia Austin), A Georgia Boy with Stonewall Jackson, (Privately published) .
35. William S . Powell, A history ofCaswell County .

36. John Fox, Miles Wells, by John Fox, Winston Salem NC, (Draft of article for Caswell County Heritage Book, Vol I 1 ),
"Electronic ."
37. Mildred Austin Finch (Aurelia Austin), A Georgia Boy with Stone-wall Jackson, (Privately published).
38. Joe and Judy Conrad website: hup ://www.conraciraots .corn/
39. Will Johnson's website on rootsweb .
40. Mildred Austin Finch (Aurelia Austin), A Georgia Boy with Stone-wall Jackson, (Privately published).
41 . The Church of Jesus Christ of Latter-day Saints, International Genealogical I (R), (Copyright (c) 1980, 1997, data
as of February 1997) .
42. Mildred Austin Finch (Aurelia Austin), A Georgia Boy with Stonewall Jackson and their families, (Privately published) .
43 . George Mustain website.
44. Bill Veley website : http ://www .proaxis.coml biliveley/swnant_i .htrn
45 . George Mustain website. g_mustaizz@yahoo .eom
46, Bill Veley website .
47 . George Mustain website.
48 . Aurelia Austin (Mildred Austin Finch), "The Wells Family," Typewritten notes in a binder . .
49. familysearch.org, Family5earch .4ncestral File, (on Internet at www.familysearch,org), v4 .19 .
50 . AureGa Austin (Mildred Austin Finch, "The Wells Family," Typewritten notes in a binder . .
51 . familysearch.org, FamilySearch Ancestral File, (on Intemetat www.fwnilysearch-org), v4 .19.
52 . Aurelia Austin (Mildred Austin Finch), "The Wells Family," Typewritten notes in a binder . .
53 . Mary Folk Webb, The Cart' Family History, (Pub . 1939) .

Case 1:08-cv-01971-WSD

Document 12

54. International Genealogical 1A76111#} .

55 . Mary Folk Webb, The Gary Family History, (Pub. 1939).

Filed 07/25/2008

Page 22 of 29

Case 1:08-cv-01971-WSD

Document 12

Filed 07/25/2008

Page 23 of 29

From : Janet McDonald [ma ilto: nootkabear@belisouth .net]


Sent: Monday, June 23, 2008 5:17 PM

To: briancarney@bellsouth .net


Subject: Fw : document examination
From: Janet McDonald
Date: 06/23/08 01 :18:19
Subject: document
Hi, my name is Janet McDonald . I have a document that I need analyzed . I believe it is
manufactured . One problem is that it's a copy of an original, but I don't think the original
had the same information on it . I also believe that some on the info on the document came
from a b" point pen . We didn't have ball point in 1941 . It is supposed to be an easement
agreement .
What would something like that cost, how long would it take, and if it is manufactured can
you do an affidavit and perhaps appear a as an expert witness? What would all these things
cost? I know you probably cannot give me a set price on everything, ball park figure will
be Ok .
Janet McDonald
821 Sheppard Rd
Stone Mountain, GA 30083
(770) 879-8737
nootkabear@bellsouth .net
The information contained in this message and any attachments are confidential and
intended only for the named recipient(s) . If you have received this message in error, you
are prohibited from copying, distributing or using the information . Please contact the
sender immediately by return email and delete the original message.

From: Brian Carnet'


Date: 06/23/08 19:59:48
To: 'Janet McDonald'
Subject: RE: document examination

Actually Janet the ball point pen was manufactured i n 1939 in Brazil and didn't
become common in the US until after approx imately 1944 . If you have a copy of

-1-

Case 1:08-cv-01971-WSD

Document 12

Filed 07/25/2008

Page 24 of 29

the original document the examination you requested can be conducted . Of


course th is depends on the quality of the photocopy. One can not tell if the " ball
pen info" on the document was in fact made by a ball pen unless there are visible
striations in the writing l ine of the copy.
My fees are l i sted on the attached Letter of Agreement for Expert Services .
Basically, $200. 00 hourly is the rate .

Brian Carrtey
Forensic Document Examiner

From: Janet McDonald [ma ilto: nootkabear@ bellsouth.net]


Sent: Monday, June 23, 2008 9 :02 PM
To: BrianCarney @ belisouth. net
Subject: RE: document examination
Mr. Carnet',
That sounds wonderful . There wasn't an attachment with your reply . I have copied the
statement from your reply so as not to confuse you in case I didn't understand what you
said.

"My fees are listed on the attached Letter of Agreement for Expert Services .
Basically, $200.00 hourly is the rate ."
How long will it take to do something like this? Also, I don't know whether or not this
helps . ..
The document is an easement agreement provided to us by Georgia Power . They claim
that in 1941 R. F. Wells granted easement . Not only are several things wrong on the
document, they also provided us with a 1937 easement agreement and a 1937
Railway/Power Co . map showing pole placement .
The 1937 agreement and map show Dr. R. F. Wells and the signatures don't look
anywhere close to the same . Also, today I talked with Stone Mountain Historic Society
Manager. She said that there had been only a Dr. James Wells, after that the doctors
weren't named Wells and Dr. Wells had only one son, his name was George Riley
Wells.
-2-

Case 1:08-cv-01971-WSD

Document 12

Filed 07/25/2008

Page 25 of 29

Thanks,
Janet
The information contained in this message and any attachments are confidential and
intended only for the named recipient(s) . If you have received this message in error, you
are prohibited from copying, distributing or using the information. Please contact the
sender immediately by return email and delete the original message.

From: Brian Carnet


Date: 06/25/08 19 :55:03
To: 'Janet McDonald'
Subject: RE: document examination

Here i s the letter of agreement .


Brian Carney

From : Janet McDonald [ mailto:nootkabear@ beilsou# h.net]


Sent: Tuesday, July 01, 2008 2:04 PM
To : B rianCarney@ bellsouth. net
Subject : RE: document examination
Mr. Carnet',
I have attached a letter to you, the same letter is is below .
Will be in touch, I feel that we will be having the document examined, waiting to see
what is going to happen, once I file Response to GA Power's Motion to Dismiss,
they will only have 10 days to reply if they are going to . In the Response to GA Power's
Motion to Dismiss, I will be including the information that is in the letter .
I have the "Agreement" form you sent and it is filled out .
Didn't want you to think we either forgot or are not serious, as we are veryy serious .
Thanks so much, will be in touch,

-3-

Case 1:08-cv-01971-WSD

Document 12

Filed 07/25/2008

Page 26 of 29

3anet and James


The information contained in this message and any attachments are confidential and
intended only for the named recipient(s) . If you have received this message in error, you
are prohibited from copying, distributing or using the information . Please contact the
sender immediately by return email and delete the original message .

From: Brian Carnet


Date: 07/04/08 18 :43:38
To: 'Janet McDonald'
Subject: RE : document examination

Mrs. McDonald ,
Received your letter via e-ma il . Let me know when you need my serv ices .
Sincerely ,
Brian B . Carney , Forensic Document Examiner

_4_

Case 1:08-cv-01971-WSD

r- -I

Document 12

Filed 07/25/2008

LJ

Page 27 of 29

Att?~chment "C"

DOCUMENTS LIST
Copy o1937 Easement Agreement providedd by Georgia Power Co .
Copy of 1937 Railway/Power Co . Map provided by Georgia Power Co .
Copy of 1941 Easement Agreement provided by Georgia Power Co .
Documents filed in Superior Court for Civil action File No .: 07-cv-1 1398-6
Plaintiffs' Real Property Documents

Plaintiffs reserve the right to add to this information as it becomes available .

Case 1:08-cv-01971-WSD

Document 12

Filed 07/25/2008

Page 28 of 29

Att~hment "D"

DOCUMENTS AND EVIDENCE

Plaintiffs do not have this information at this time, reserve the right to add to this
information as it becomes available .

Case 1:08-cv-01971-WSD

Document 12

Filed 07/25/2008

Page 29 of 29

IN THE UN ITED STATES DISTRICT COURT


FOR THE NORTHERN DI STRICT O F GEORGIA,
Atlanta Division
JAMES B. STEGENLAN,
JANET I3. MCDONALD,

CIVIL ACTION
FILE NO: 1 :(!8-CV- 019 1 -WSD

vs.

SUPERIOR COURT, et, a l.,


Defendants

CERTIFICATE OF SERVICE
I Certify that I have this 23rd day of July, 2008, served a true and correct
copy of the foregoing Plaintiffs' Initial Disclosures upon Defendants, through
their attorney on file b y causing to be depos ited with U .S. P. S., F i rst Class Ma i l,
proper postage affixed thereto, addressed as follows :
D aniel S. Reinhardt
Troutman Sanders, LLP
Bank of America Plaza --Suite 5200
600 Peachtree Street, NE
Atlanta, GA 30308-2216

~.

Devon Orland
State of Georgia Dept. of Law
40 Capitol Square, S .W.
Atlanta, GA 30334-1300

B.

31

Se

NET D . MCDONALD, Pro Se


821 Sheppard Rd
Stone Mountain, GA 30083
(770) 879-8737

-5-