DUPLICATE

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

Robert Wells,

§ § § § §

§

Board of Regents for the University §

System of Georgia; Savannah State §

University; Claud Flythe, individually § and in his official capacity as the Vice § President of Administration for § § § § § § § § § § § § § §

Plaintiff,

v.

Savannah State University; Julius Dixon, individually and in his official capacity as the Interim Head Football Coach for Savannah State University; Marilynn Stacey -Suggs, individually and in her official capacity as Interim Athletic Director for Savannah State

University; and Shed Dawson, [r., . individually and in his official capacity as Assistant Athletic

Director / Compliance Coordinator,

Defendants.

FILED IN CLERK'S OFFICE

U.S. D.C. Atlanta

MAY 25 2010

JAM ES~~ ~1TTEN, CU~RK

Civil Action No. 1B)l: va yv Deputy Clerk

.. -,. - ..-

1: 1 0 Q CV =0 1 5 91

COMPLAINT

COMES NOW, Robert Wells, Plaintiff, and submits his Complaint against the

Board of Regents for the University System of Georgia ("Board of Regents");

Savannah State University CSSU"); Claud Flythe, individually and in his official

capacity as the Vice President of Administration for Savannah State University;

Julius Dixon, individually and in his official capacity as the Interim Head Football

Coach for Savannah State University; Marilynn Stacey-Suggs (hereinafter "Suggs"), individually and in her official capacity as Interim Athletic Director for Savannah State University; and Shed Dawson, Jr., individually and in his official capacity as Assistant Athletic Director/Compliance Coordinator, based on the allegations set forth below.

INTRODUCTION 1.

This is a civil action brought pursuant to 42 U.S.C. § 1983 ("Section 1983"), the United States Constitution, 42 U.s.C. § 1981 ("Section 1981"), and the laws of the

. state of Georgia seeking declaratory and injunctive relief, lost wages and benefits, compensatory damages, punitive damages, and attorney's fees and costs for Defendants' violation of Plaintiff's right to equal protection of the law and freedom of association protected and secured under the First and Fourteenth Amendments of the United States Constitution, as well as Plaintiff's federally-protected right to be free from discrimination in his employment. In addition, Plaintiff seeks to recover for the Defendants' violation of Georgia's defamation laws.

-2-

JURISDICTION AND VENUE 2.

As Plaintiff brings this action to redress deprivations by the Defendants Board of Regents, SSU, Flythe, Dixon, Dawson and Suggs acting under color of state law, of certain constitutionally-secured rights, as well as Defendants intentional discrimination against Plaintiff based on his race, the claims herein present a federal question, and jurisdiction of this Court is predicated upon 28 U.s.C. §§ 1331 and 1343; 28 U.s.C. § 2201; and 42 U.S.c. §§ 1983 and 1981, The Court also has supplemental jurisdiction over Plaintiff's state law claims pursuant to 28 U.s.C. § 1367.

3.

Venue is proper in the Northern District of Georgia because Defendant Board of Regents is located and does business within the boundaries of this judicial district,

28 U.s.C. § 1391(b).

PARTIES 4.

At all times relevant to this action, Plaintiff Robert Wells was employed by or associated with Defendant Board of Regents as Head Football Coach for Defendant SSU. Plaintiff submits himself to the jurisdiction of this Court.

-3-

5.

Plaintiff is a /I complaining party" as that term is defined by Section 1981. 6.

Defendant SSU is a historically black, public, four-year, post-secondary educational institution located in Savannah, Georgia.

7.

Defendant SSU is operated by Defendant Board of Regents, a Department of the State of Georgia that oversees the State's university system. The offices of the Board of Regents are located in Atlanta, Georgia.

8.

Both Defendants SSU and the Board of Regents are in an industry affecting commerce, and both Defendants SSU and Board of Regents were an /I employer" of Plaintiff at all times relevant to this action.

9.

Defendants SSU and the Board of Regents can be served with process through the Chancellor of the Board of Regents, Erroll B. Davis, Jr., located at the Board of Regent's headquarters at 270 Washington Street, SW, Suite 7025, Atlanta, Georgia 30344.

-4-

10.

Defendant Claud Flythe ("Defendant Flythe") is the Vice President of Administration for SSU and at all times relevant to this action had responsibility for the Athletic Department at SSU, including SSU's NCAA Division 11 football program. He can be served with process at his office on the SSU campus.

11.

Defendant Julius Dixon CDefendant Dixon") is the Interim Head Football Coach for SSU and can be served with process at his office on the SSU campus.

12.

Defendant Marilynn Stacey-Suggs (" Defendant Suggs") is the Interim Athletic Director for S SU and can be served with process at her office on the SSU campus.

13.

Defendant Shed Dawson("Defendant Dawson") is the aAssistant Athletic Director / Compliance Coordinator for SSU and can be served with process at his office on the SSU campus.

FACTS 14.

Plaintiff Robert Wells is a white male who was hired as the head football coach for SSU in approximately December 2007.

-5-

15.

Coach Wells had 18 years of experience in coaching and was given the challenge of revitalizing SSU's football program when he was hired.

16.

Coach Wells was the University's twenty-first head football coach and the first white individual to hold the job at this historically black university.

17.

In his first year as coach, Coach Wells successfully led the football team to five

victories.

18.

The five victories under Coach Wells in 2008 equaled the total number of wins the team had accumulated over the previous five seasons and was also the best season Savannah State had experienced in eleven years.

19.

After the 2008 football season, Defendant, Flythe, announced publicly that Coach Wells, "has a job as long as I have one here."

20.

In addition to improving the Team's win/loss record, Coach Wells instituted a number of changes to ensure that the team members were living up to their educational responsibilities, resulting in an overall improved academic performance -6-

of the team.

21.

During the 2009 football season, Coach Wells used his own money to produce a televised" coach's show" similar to the shows that many other Division I football teams have established. The purpose of the show was to boost visibility and support for SSU's football program.

22.

Coach Wells' II coach's show" reached the Savannah community and surrounding area, aired on each Saturday morning during football season, included commentary and game highlights from Coach Wells, and offered a behind-thescenes look at SSU's football.

23.

Coach Wells' "coach's show" was hosted by his fiance, Nicole Miller, a black female.

24.

Coach Wells' completed his second season as head footbal coach for SSU on November 21, 2009.

25.

On or about November 23, 2009, Defendant Suggs, was named Interim Athletic Director when the employment of SSU's first White Athletic Director -7-

ended.

26.

On December 18, 2009, SSU President Yarbrough offered and Coach Wells accepted a one year extension of his contract as Head Football Coach at SSU.

27.

After the 2009 season, Coach Wells felt that some coaching staff changes needed to be made in order to better the performance of the team.

28.

One person Coach Wells wanted to terminate after the 2009 season was Coach Julius Dixon; however, he was not permitted by interim Athletic Director Defendant Suggs or Defendant Flythe to make this change.

29.

Immediately after Coach Wells' termination, Ms. Suggs and Dr. Flythe named Coach Dixon, a Black male as the new interim head coach.

30.

Coach Wells and his coaching staff were given the directive to go out and recruit the best players possible from the class of 2010 high school graduates, without restrictions on where to recruit or whom to recruit.

-8-

31.

Coach Wells' staff recruited from southern Florida up the entire eastern seaboard and into Canada.

32.

The administration, including Defendant Flythe, DefendantSuggs, and others were aware of, and encouraged and approved both the in-state and out-of-state recruiting done by Coach Wells and his staff.

33.

In January of 2010, Coach Wells and hisstaff of coaches were vigorously recruiting the 2010 high school seniors in preparation for National Signing Day (February 3, 2010), the first day when college football players from across the nation are allowed to sign a binding National Letter of Intent to attend a specific school.

34.

In January 2010, Coach Wells was twice summoned to mandatory meetings with his superiors, Defendant Flythe and Defendant Suggs.

35.

On January 19, 2010, Coach Wells was called in from a recruiting trip to a meeting with Defendant Flythe and Defendant Suggs.

-9-

36.

In the January 19,2010, Defendant Flythe indicated to Coach Wells that things

were not working out due to his race, specifically stating that Coach Wells would

never have the support of the SSU alumni nor be able to reach those individuals

because he is White.

37.

In the January 19, 2010 meeting, Defendant Flythe further stated that Coach

Wells would never have the support of the citizens of Savannah, because he is White

and his fiance is Black.

38.

. .

In the January 19,2010 meeting, Defendants Flythe and Suggs criticized Coach

Wells for his association with his fiance, a black female, including, his use of her to

host his weekly coach's show, his allowing her to ride with him on a parade float,

and her accompanying him on away football games.

39.

Coach Wells was shocked by the comments made by Defendants Flythe and

Suggs in the January 19, 2010 meeting.

40.

Coach Wells was dismissed from the January 19, 2010 meeting and told to be

thinking about the situation.

-10-

41.

As a result of the January 19, 2010 meeting, Coach Wells suffered severe emotional and physical distress.

42.

On January 28, 2010, five (5) days before National Signing Day for high school seniors, Defendants Flythe and Suggs again called Coach Wells in from a recruiting trip; and Defendant Flythe advised Coach Wells that he had the choice of resigning right then or being terminated immediately.

43.

In the January 28, 2010 meeting with Defendants Flythe and Suggs, Coach Wells also was told that if he refused to resign and opted for termination, his pay and benefits would cease that day and he would be given a poor recommendation when attempting to find another coaching position.

44.

In the January 28, 2010 meeting with Defendants Flythe and Suggs, Coach Wells was told that if he elected to resign, he would receive pay and benefits through the end of March 2010 and get a positive reference.

45.

In May 2010, Defendant Suggs admitted in a nationally-televised interview that if Coach wells had not resigned, he would have been terminated.

-11-

46.

Coach Wells understood quite well that he had no choice but to resign based. on the information provided to him in the January 2010 meeting with Defendants Flythe and Suggs.

47.

On January 28th Coach Wells tendered his forced resignation.

48.

In the interest of being professional, protecting his players and the Savannah community from any embarrassment and preventing the recruits who were less than a week away from National Signing Day from experiencing anxiety, Coach Wells agreed to announce that he resigned voluntarily.

49.

National Signing Day came on February 3, 2010, and by the end of the day Coach Wells learned that five of the young men he had recruited for the 2010 season and who had given the school a verbal commitment to play football for SSU were not offered scholarships or a spot on the team.

50.

All five of the high school seniors that Coach Wells had recruited but who had not received offers to play at SSU were White.

-12-

51.

For the 2010 season, SSU signed no white high school players as incoming freshmen.

52.

Within a week after National Signing Day, when the press began investigating the recruiting story, reporters started asking administrators at the school why SSU had failed to make offers to the white recruits.

53.

In February 2010, SSU responded to press questions about offers not being made to the white recruit; SSU's Interim Head Football Coach Defendant Dixon responded in an aired television interview by saying that Coach Wells had received a directive not to recruit high school seniors from outside of the State of Georgia but chose to ignore that directive, and that the five young men who did not receive scholarship offers were from outside the state.

54.

Defendant Dixon's assertion regarding a directive to Coach Wells prohibiting out-of-state recruiting was patently and knowingly false.

55.

One of the young White men to whom Coach Wells had made a verbal commitment, but who was not given a scholarship offer or a non-scholarship offer

-13-

to play on the football team, was an :in-state player out of Morrow, Georgia.

56.

Another of the players that Coach Wells had recruited and who was made an offer by SSU on National Signing Day was Black and was from the Tampa area, the same area as one of the White recruits who was not offered a position with the SSU football team.

57.

No directive was ever issued during Coach Wells' employment from anyone at SSU to only recruit :in-state football players.

·58.

For the 2010 freshman recruiting class, Coach John Montgomery traveled to Florida alone and with Coach Wells for recruiting, Coach Barry Casterlin traveled extensively throughout the Northeast and Canada attempting to recruit players, and Coach Hans Batichon also recruited out-of-state in Miami.

59.

Recruiting out-of-state was done by the SSU coach:ing staff for the 2010 freshman class with the SSU Administration's full knowledge, consent and approval.

-14-

60.

During neither of the meetings that Coach Wells attended with his superiors in January 2010 were his activities with regard to recruiting criticized.

61.

The attempt by any administrator or coach at SSU to say that there was not to be any out-of-state recruiting is nothing more than a justification fabricated after the events at issue to make Coach Wells look bad to the recruits, to the fans, to the players, and to other football coaches.

62.

During neither of the January 2010 Meetings with Coach Wells and Defendants Flythe and Suggs were his coaching abilities discussed.

63.

During the January 2010 meetings, Coach Wells was criticized for having his own coach's TV show and using his black fiance as the hostess; for letting his fiance drive his car; and for riding on a float with his fiance and representing SSU at the annual St. Patrick's Day parade ten months earlier in March of 2009.

64.

On February 22, 2010, Defendant Dawson submitted to the National Collegiate Athletic Association ("NCAA") a Self-Report of NCAA Secondary Violation, stating, "After resigning his employment at Savannah State, Former

-15-

football coach Robert Wells provided names and possibly contact information for select prospective student-athletes to local news reporter Ken Slac [sic]."

65.

The statement contained in the Self-Report of NCAA Secondary Violation referenced in paragraph 63 above was knowingly false and/ or made with reckless disregard for the truth, with the intent of showing Coach Wells in a poor light and defaming him to the NCAA in order to injure his reputation as a college football coach.

66.

In May 2010, in an interviews aired on the ESPN television network, Defendants Suggs and Dixon stated that the reason the five (5) White recruits were not signed to play for the SSU football team is that Coach Wells had not followed applicable rules and regulations regarding paperwork, thus the White players were not official recruits and no one at SSU knew of them.

67.

In fact, in addition to there being files on the White recruits, several of them had conducted official college recruiting visits to SSU and met with Defendant Dixon and others in the Athletic Department.

-16-

68.

The attempt by any administrator or coach at SSU to say that Coach Wells had not followed applicable rules and regulations regarding paperwork for the White recruits is nothing more than a justification fabricated after the events at issue to make Coach Wells look bad to the recruits, to the fans, to the players, and to other football coaches.

COUNT I - RACE DISCRIMINATION - SECTION 1981 69.

Plaintiff hereby incorporates as if set forth fully herein paragraphs 1 through 68 of this Complaint.

70.

Defendants Board of Regents, SSU, Flythe and Suggs subjecting Plaintiff to different terms and conditions of employment due to his race, for example, by terminating his employment for pretextual reasons and replacing him with a black employee, constitutes unlawful intentional discrimination in violation of Section

1981.

71.

Defendants Board of Regents, SSU, Flythe and Suggs subjecting Plaintiff to different terms and conditions of employment, including his constructive termination, due to his engaging in an inter-racial relationship with a Black female

-17-

constitutes unlawful intentional discrimination in violation of Section 1981.

72.

As a result of the unlawful actions of Defendants Board of Regents, SSU, Flythe and Suggs, Plaintiff has suffered loss of income and benefits, as well as emotional pain, suffering, mental anguish, and other non-pecuniary losses.

73.

Because Defendants Flythe and Suggs willfully and wantonly disregarded Plaintiff's rights, and their discriminatory acts against Plaintiff were undertaken in bad faith, Coach Wells is entitled to recover punitive damages.

COUNT II - FOURTEENTH AMENDMENT 74.

Plaintiff hereby incorporates as if set forth fully herein paragraphs 1 through 73 of this Complaint.

75.

Defendants Board of Regents, SSU, Flythe and Suggs violated Plaintiff's Fourteenth Amendment right to equal protection under the law, by, for example, terminating his employment for pretextual reasons on account of his race.

-18-

76.

Defendants Board of Regents, SSU, Flythe and Suggs violated Plaintiff's Fourteenth Amendment right to equal protection under the law by subjecting Plaintiff to different terms and conditions of employment, including his termination and replacement by a Black employee, due to his engaging in an inter-racial relationship with a Black female.

77.

As a result of the unlawful actions of Defendants Board of Regents, SSU, Flythe and Suggs, Plaintiff has suffered loss of income and benefits, as well as emotional pain, suffering, mental anguish, and other non-pecuniary losses.

78.

Because Defendants Flythe and Suggs willfully and wantonly disregarded Plaintiff's rights, and their acts against Plaintiff were undertaken in bad faith, Coach Wells is entitled to recover punitive damages.

COUNT lIT -FIRST AMENDMENT FREEDOM OF ASSOCIATION 79.

Plaintiff hereby incorporate as if set forth fully herein paragraphs 1 through 78 of this Complaint.

-19-

80.

Defendants Board of Regents, SSU, Flythe and Suggs violated Plaintiff's First Amendment Right to Association by subjecting Plaintiff to different terms and conditions of employment, and specifically terminating his employment, due to his engaging in an inter-racial relationship with a Black female.

81.

As a result of the unlawful actions of Defendants Board of Regents, SSU, Flythe and Suggs, Plaintiff has suffered loss of income and benefits, as well as emotional pain, suffering, mental anguish, and other non-pecuniary losses.

82.

Because Defendants Flythe and Suggs willfully and wantonly disregarded Plaintiff's rights, and their discriminatory acts against Plaintiff were undertaken in bad faith, Coach Wells is entitle to recover punitive damages.

COUNT N - DEFAMATION AGAINST DEFENDANT DIXON 83.

Plaintiff hereby incorporate as if set forth fully herein paragraphs 1 through 82 of this Complaint.

84.

In February 2010, Defendant Dixon published false, defamatory, and disparaging statements to the media and the public about Plaintiff having violated

-20-

SSU directives.

85.

In the May 2010 ESPN-aired television interview, Defendant Dixon published false, defamatory, and disparaging statements to the media and the public about Plaintiff having violated SSU rules and regulations regarding the White recruits. 86.

The false and defamatory nature of the statements made by Defendant Dixon, referred to Plaintiff by name, were made of and concerning Plaintiff, and were so understood by those who heard the news report and saw news clips containing the statements.

87.

The statements made by Defendant Dixon regarded Plaintiff's trade, office or profession, and were calculated to injure Plaintiff and constitute slander per se.

88.

Defendant Dixon's statements that Plaintiff had violated SSU directive by recruiting out-of-state high school students was false and malicious and defamed Plaintiff.

89.

Defendant Dixon's statements were libelous on their face and were published with the intent to impeach Plaintiff's honesty, integrity, virtue, and reputation, were

-21-

calculated to injure his trade, office or profession and produced special damages which flowed naturally therefrom.

90.

Defendant Dixon's statements clearly expose Plaintiff to contempt, ridicule and obloquy because they essentially charge Plaintiff with misappropriation of public funds and misconduct in his public employment.

91.

Defendant Dixon published the defamatory statements with knowledge that they were false or with reckless disregard for the falsity of the statements, causing Plaintiff to suffer damages, including emotional distress and injury to his reputation. 92.

As a proximate result of the above-described publication, Plaintiff has suffered loss of his reputation, shame, mortification, and injury to his feelings.

93.

Because of Defendant Dixon's malice in publishing these statements, Plaintiff seeks punitive damages against Defendant Dixon in an amount to be established by proof at trial.

-22-

COUNT V - DEFAMATION AGAINST DEFENDANT SUGGS 94.

Plaintiff hereby incorporate as if set forth fully herein paragraphs 1 through 93 of this Complaint.

95.

In the May 2010 ESPN-aired television interview, Defendant Suggs published false, defamatory, and disparaging statements to the media and the public about Plaintiff having violated SSU rules and regulations regarding the White recruits. 96.

The false and defamatory nature of the statements made by Defendant Suggs, referred to Plaintiff by name, were made of and concerning Plaintiff, and were so understood by those who heard the news report and saw news clips containing the statements.

97.

The statements made by Defendant Suggs regarded Plaintiff's trade, office or profession, and were calculated to injure Plaintiff and constitute slander per se.

98.

Defendant Suggs' statements that Plaintiff had violated SSU rules regulations regarding the recruiting of the White high school recruits was false and malicious and defamed Plaintiff.

-23-

99.

Defendant Suggs' statements were libelous on their face and were published with the intent to impeach Plaintiff's honesty, integrity, virtue, and reputation, were calculated to injure his trade, office or profession and produced special damages which flowed naturally therefrom.

100.

DefendantSuggs' statements clearly expose Plaintiff to contempt, ridicule and obloquy because they charge Plaintiff with misconduct in his public employment. 101.

Defendant Suggs published the defamatory statements with knowledge that they were false or with reckless disregard for the falsity of the statements, causing Plaintiff to suffer damages, including emotional distress and injury to his reputation. 102.

As a proximate result of the above-described publication, Plaintiff has suffered loss of his reputation, shame, mortification, and injury to his feelings.

103.

Because of Defendant Suggs' malice in publishing these statements, Plaintiff seeks punitive damages against Defendant Suggs in an amount to be established by proof at trial.

-24-

COUNT VI - DEFAMATION AGAINST DEFENDANT DAWSON 104.

Plaintiff hereby incorporate as if set forth fully herein paragraphs 1 through 103 of this Complaint.

105.

In February 2010, Defendant Dawson published false, defamatory, and/ or disparaging statements to the NCAA about Plaintiff having violated NCAA rules and regulations.

106.

The false and defamatory nature of the statements made by Defendant Dawson, referred to Plaintiff by name, were made of and concerning Plaintiff, and were so understood by those who received or saw the report.

107.

The statements made by Defendant Dawson regarded Plaintiff's trade, office or profession, and were calculated to injure Plaintiff and constitute slander per se.

108.

Defendant Diawson's statements that Plaintiff had violated NCAA rules and regulations were knowingly false and malicious or were made with a reckless disregard for the truth and defamed Plaintiff.

-25-

109.

Defendant Dawson's statements were libelous on their face and were published with the intent to impeach Plaintiff's honesty, integrity, virtue, and reputation, were calculated to injure his trade, office or profession and produced special damages which flowed naturally therefrom.

110.

Defendant Dawson's statements clearly expose Plaintiff to contempt, ridicule and obloquy because they charge Plaintiff with misconduct in his public employment.

111.

Defendant Dawson published the defamatory statements with knowledge that they were false or with reckless disregard for the falsity of the statements, causing Plaintiff to suffer damages, including emotional distress and injury to his reputation. 112.

As a proximate result of the above-described publication, Plaintiff has suffered loss of his reputation, shame, mortification, and injury to his feelings.

113.

Because of Defendant Dawson's malice in publishing these statements I Plaintiff seeks punitive damages against Defendant Dawson in an amount to be established by proof at trial.

-26-

PRAYER FOR RELIEF

WHEREFORE, Plaintiff demands a TRIAL BY JURY and judgment as follows: a) adjudge Defendants Board of Regents, SSU, Flythe and Suggs to have engaged in unlawful employment practices, specifically race discrimination in violation of Section 1981, Section 1983 and the Fourteenth Amendment;

b) adjudge Defendants Board of Regents, SSU, Flythe and Suggs to have violated Plaintiff's freedom of association guaranteed by the First Amendment to the United States Constitution by terminating his employment because of his association with his fiance, a Black female;

c) enjoin Defendants Board of Regents, SSU, Flythe and Suggs from engaging in unlawful employment practices in violation of Title VII, Section 1981, Section 1983, and the First and Fourteenth Amendments;

d) enjoin Defendants Dixon, Dawson and Suggs from making additional false and defamatory statements about Plaintiff;

e) award Plaintiff his lost pay and benefits as a result of his termination in violation of Section 1981, Section 1983 and the First and Fourteenth Amendments; f) award equitable relief against Defendants Board of Regents, SSU, Flythe and Suggs in the form of reinstatement or front pay;

g) award Plaintiff compensatory damages for violation of his statutory and constitutional rights violated by Defendants Board of Regents, SSU, Flythe and Suggs

-27-

in an amount to be determined by the enlightened conscience of the jury, including

damages for emotional distress and humiliation;

h) award Plaintiff compensatory damages for the false and defamatory

statements made about him by Defendants Dixon, Dawson and Suggs in an amount

to be determined by the enlightened conscience of the jury, including damages for

emotional distress and humiliation;

i) award Plaintiff punitive damages for the false, defamatory and malicious

statements made about him by Defendants Dixon, Dawson and Suggs in an amount

to be determined by the enlightened conscience of the jury;

j) award Plaintiff punitive damages for the intentional, willful and wanton

conduct of Defendants Suggs and Flythe in their individual capacities for their

violations of Section 1981, Section 1983 and the First and Fourteenth Amendments

in an amount to be determined by the enlightened conscience of the jury;

k) award Plaintiff pre- and post-judgment interest;

1) award Plaintiff his costs, expenses oflitigation and reasonable attorneys' fees;

and

m) award Plaintiff all other relief to which he is entitled. Respectfully su bmitted this 6\ ~ of May, 2010.

-28-

Georgia Bar. No. 631035 JAMES E. ROLLINS, JR. Georgia Bar No. 613825

LAW OFFICES OF DEBRA SCHW ARIZ LLC 1770 Resurgens Plaza

945 East Paces Ferry Road Atlanta, Georgia 30326

(404) 842-7274 jer@gaemploymentlawyers.com des@gaemploymentlawyers.com

Attorneys for Plaintiff Robert Wells

-29-