UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRrcT OF TENNESSEE

MARRELL GRAHAM )
)
Plointiff, )
l
v ) ctvtLAcTroN
) NO:
)
UNITED STATES OF AMERICA )
I
Defendont. )
)

COMPI.AINT

lntrodustion

1. This action for monetary damages is brought pursuant to the Fourteenth Amendment to

the United States Constitution and Title 28 U.S.C. I2671, et seq. (hereinafter the "Federal Tort

Claims Act") and under the common and statutory law of the State of Tennessee. Jurisdiction is

based upon 28 U.S.C. 59 f33f and 13t16 (bland on the supplementaljurisdiction of the court

under 28 U.S.C. I 1357(a) for claims arising under state law. Venue is proper under 28 U.S.C. 99

13s1(aX1)and (bX2).

2. Plaintiff alleges that several known and unknown federal officials failed to adequately

protect a cooperating individual with the Federal Bureau of lnvestigation ("FBl") and further

failed to recognize the cooperating individual had become a target for murder. These failures

led to the untimely death of the cooperating individual on 2lotlt979. The cooperating

individ ual was Plai ntiff, s father, Sam uel Pettyjohn

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 Parties

1. The following person is the plaintiff in this action:

a Marrell Graham at all times material to this complaint was and is a resident of

Cobb County, Georgia. He is of full age. He is the son of the decedent, Samuel Pettyjohn.

2. The following person is the defendant in this action

a The United States of America is the appropriate defendant under the Federal

Tort Claims Act and was at alltimes materialto this complaint the employer of

known and unknown FBlAgents.

Facts

3. Leonard Ray Blanton ("Blanton"), a Democrat, was elected as the 44th Governor of the

State of Tennessee in 1975. Blanton served as governor from 1975-t979.

4. Blanton appointed Thomas Edward Sisk ('Sisk") as Chief Legal Counsel for the

Governor in 1975.

5. Marie Ragghianti ("Ragghianti")was hired by Sisk to be an extradition officer and

handled all communications with the State's Board of Pardons and Paroles for the

Blanton administration. She would later sue Blanton for wrongfultermination.

6. William Aubrey Thompson ('Thompson")was a Chattanooga, Tennessee

business owner and main Chattanooga politicalcontact for Blanton. Thompson was known

to have unfettered access to Blanton and his cabinet. Thompson had a reputation for dealing in

various types of illegal activities

7. Samuel Pettyjohn ("Pettyjohn") owned several businesses in Chattanooga, Tennessee.

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 ln addition to his legitimate business interests, Pettyjohn was known to engage in various

lllegal activities as well.

9. Pettyjohn owned the Stardust Lounge ("Stardust") which was a restaurant/bar located

at or near the 300 block of 9th Street in downtown Chattanooga. Severat years later, he

owned the Beverage Center located at 2001 Market Street near downtown Chattanooga

10. ln the early hours of 8129/L974, a bomb ignited on 9th Street in Chattanooga. The

blast destroyed Stardust as well as almost an entire city block. The Bureau of Alcohol,

Tobacco, Firearms, and Explosives ("ATF") investigated the explosion along with the

Chattanooga Fire Department ("CFD"). After several years of investigation, the ATF

was unable to charge any individuals with the bombing. The investigation went dormant.

11. Pettyjohn and other Thompson confidants received insurance payments for the

total property loss suffered during the explosion. These proceeds were paid by Lloyd's

of London.

L2. Sometime in 1975, an illegal scheme emerged wherein prisoners in the Tennessee

Department of Corrections ("TDOC") could pay monies, through intermediaries, to the Blanton

administration and to receive early parole

13. Larkin Bibbs ("Bibbs) was a well-known Chattanooga drug dealer who was convicted

of second-degree murder and ordered to serve fifteen (15) years in the TDOC. He began

serving his sentence on8l26lt975.

L4. ln November of L975, Thompson visited Bibbs in the TDOC for unknown reasons.

15. ln December of 1975, Pettyjohn visited Bibbs in the TDOC for unknown reasons

16. Pettyjohn secured approximately Fifteen Thousand Dollars (515,00.00)

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 and delivered it to Thompson. The funds were procured from several individuals believed

to be Chattanooga businesspeople.

L7. ln late L975, Bibbs was released from TDOC after serving less than four (4) months of

a fifteen (15)year prison sentence.

18. The illegal scheme that allowed Bibbs to leave prison early became known

throughout the state and various law enforcement circles. The Federal Bureau of

lnvestigation ("FBl") opened an investigation into the Blanton administration and the

parole system known as TENNPAR (Tennessee Parole). Hank Hillin ("Hillin") and other

unknown FBI Agents led the investigation.

19. During these times, other prisoners were released early from TDOC. Many of

the early releases had Chattanooga ties.

20. lnvestigative efforts led to raids of Sisk's office in the Tennessee State Capitol in

late 1976.

2L. Grand juries were convened in Nashville and Chattanooga Tennessee to examine

the growing TEN NPAR investigation.

22. Pettyjohn appeared before at least one grand jury and gave testimony. He also

further cooperated with the FBI regarding the TENNPAR investigation.

23. lt is not known how the FBI defined their relationship with Pettyjohn.

Generally, the FBI defines individuals from whom they get information as

confidential informants, cooperating witnesses, assets, or sources of information.

24. Regardless of the title, Pettyjohn testified before a federal grand jury. tn

September t977, Pettyjohn and the FBlmet at a clandestine location in Chattanooga

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 to discuss further aspects of the TENNPAR investigation. At this meeting, Pettyjohn

supplied the names of five (5) individuals who paid the proceeds to have Bibbs

released early. The names were reduced to a written document that Pettyjohn

signed. Upon information and belief, the list of five (5) names became a permanent

exhibit to the FBI's TENNPAR investigative file.

25. Sometime in 1978, the ATF reopened their investigation into the 9th Street

Explosion based upon newly developed information.

26. The Hamilton County Tennessee Grand Jury indicted Pettyjohn on the charges

of murder and arson for his involvement in the 9s Street Explosion. The indictment was

returned against Pettyjohn in November 1978.

27. On t2lL5/L978, Sisk and several other Blanton administration officials were

arrested by the FBl. Thompson was later arrested and indicted for his role in the

pardon scandal as well as unrelated tax evasion charges.

28. On t2lL8/t978, Blanton was subpoenaed to appear and testify before a coming

federal grand jury. Blanton would later publicly state he was a target of the TENNPARR

investigation. He had previously announced he would not be seeking a second term as

governor.

29. Blanton continued his suspicious activities in January 1979 and commuted the sentences

of fifty-two (52) state prisoners. Many had violent convictions. The TENNPAR investigation

revealed Blanton was set to release more prisoners.

30. Based upon conversations with federal and state law enforcement, state government

officials intervened and removed Blanton from office and Lamar Alexander (Alexander) was

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 sworn in early as the State of Tennessee's 45th Governor.

31. Pettyiohn provided the FBI vital information about criminal activities of a sitting

governor and other powerful individuals. The TENNPAR investigation was reported widely

throughout the United States. He was also the main target for the 9rh Street Explosion. The

FBI never provided any security or protection for Pettyjohn.

32. On 2ltlL979, Pettyjohn was found murdered inside of the Beverage Center. He

had been shot four times with three (3) gunshot wounds to the head and one (1) gunshot

to the chest. Robbery was not the motive. The Beverage Cente/s cash register was

untouched and Pettyjohn's jewelry valued at over One Hundred Thousand Dollars

(S100,000.00) remained on his person.

33. The FBI was on notice that the safety of cooperating TENNPAR witnesses was a serious

issue. Bernard Weinthal ("Weinthal") was involved in the pardon scheme by paying Thompson

for various individuals. Weinthal later became a cooperating TENNPAR witness and appeared

severaltimes before the federalgrand jury.

34. ln July L976, Weinthal was found dead under unusual circumstances. At the time,

police ruled his death as a suicide.

35. Kevin McCormack ("McCormack") was an assistant to Ragghianti. Ragghianti became

aware of the pardon scheme and spoke publicly at the issues. Based upon her knowledge,

Blanton terminated Ragghiantil. She later sued Blanton for wrongfultermination. McCormack

was a witness in her lawsuit against Blanton. In June t978,law enforcement found McCormack

had been strangled to death by an unknown assailant. His body was located at the Capital Park

lnn in Nashville. The inn was often the location where monies were advanced to Blanton

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 administration members in the pardon scheme. lt is not known if the FBI provided any

information about McCormack to other law enforcement agencies about his testimony

against Blanton

36. Subsequent to Pettyjohn's murder, Ernie Anglin ("Anglin") was found shot to death in

the front yard of his Columbia, Tennessee home. Anglin had previously attempted to buy his

brothe/s early release from TDOC. Anglin never wanted to cooperate with the FBI but later

told them he would. Several days prior to his FBI meeting regarding cooperation, Anglin

was brutally murdered. Anglin's case remains unsolved

37. Another cooperating witness, Lawrence Verable, was found murdered in his

Tennessee home. Verable was known to pay monies to the Blanton administration for the

protection of his liquor store.

38. Despite other instances of witnesses being killed, the FBI abandoned Pettyjohn and

his safety.

39. As the TENNPAR investigation concluded, Sisk, Thompson, Blanton, and other

administration members were convicted of federal crimes dealing with the pardon scheme

and the additional investigation into illegal liquor licenses.

40. Pettyjohn's murder remained unsolved

4L. ln the 1990s, the FBI began investigating a multi-state bank robbery scheme. The

investigation revealed the leader of the robbery gang to be William Edward Alley ("Alley'')

Alley and other individuals were later indicted and sentenced to federal prison for

multiple bank robberies.

42. lnformation was provided to the FBI by Alley's co-defendants. Such information

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 included the reason(s) why Pettyjohn was murdered and the identity of the

murderer.

43. Pettyjohn was murdered because he had cooperated against the Blanton

administration during the TENNPAR scheme and other information he had related to

other illegal activities like the 9s Street Explosion.

44. Alley was paid by various individuals including some closely connected to the

Blanton administration to murder Pettyjohn. On 2lt/t979, Alley carried out the

contract murder.

45. lt is unknown what the FBI did with the information regarding Pettyjohn's murder

that was discovered from the bank robbery investigation.

46. lt is unknown what the FBI did with the information about the five (5) names they were

provided to by Pettyjohn. These five (5) people would have been considered suspects in

Pettyjoh n's contract murder.

46. lt is known that the FBI never shared any information regarding Pettyjohn's

murder with the plaintiff, Marrell Graham.

47. The FBI had a duty to recognize the potential threats posed by Pettyjohn for his

cooperation in a highly visible federal investigation

48. The FBI had a duty to protect Pettyjohn and his family due to his cooperation

in a highly visible federal investigation.

49. The FBI had a duty to protect Pettyjohn because they were aware other

cooperating TENNPAR witnesses were murdered and/or died under unusual

circumstances.

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 50. The FBI had a duty to protect Pettyjohn because at the time of his cooperation

they knew Pettyjohn was terrified for his own safety.

51. The aforesaid acts and omissions of the defendant and its employees were

motivated, in part, by the intention of the defendant and its employees to obtain

further pertinent information to a federal investigation and successful prosecution(s) despite

any dangers subjected to cooperating individuals.

52. As a direct and proximate result of the intentional, reckless and/or negligent actions

and omissions of the defendant as set forth above, the plaintiffs father, Samuel Pettyjohn,

suffered a wrongful death. As a surviving child, Graham can seek recovery for the wrongful

death of his father, including the monetary value of the decedent's life.

53. As a direct and proximate result of the intentional, reckless, and/or negligent actions

and omissions of the defendant as set forth above, the plaintiff was deprived of the loss of the

income, services, protection, care, assistance, society, companionship, comfort, guidance,

counsel, and advice of his father. Plaintiff continues to be deprived of the loss of income,

services, protection, care, assistance, society, companionship, comfort guidance, counsel,

and advice of his father.

54. As a direct and proximate result of the intentional, reckless, and/or negligent actions

and omissions of the defendant as set forth above, the decedent was denied his fundamental

right, guaranteed by the 14th Amendment of the United States Constitution, of the right to

direct the care, upbringing, and education of the Plaintiff. Plaintiff was denied similar

fundamental rights in a relationship with his father, the decedent.

55. The defendant and its employees never shared any of the vital information surrounding

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 Pettyjohn's murder with Graham or any of his family members. Other than to leave the

information stored away in the defendant's investigative case files; it is not known if the

defendant did anything with the information surrounding Pettyjohn's murder.

56. ln June 202L, a Hamilton County Tennessee Grand Jury returned findings that if Alley

were alive today, they would have indicted him for the first-degree murder of Peftyjohn

57. Prior to the June 202L grand jury findings, the plaintiff was never made aware of the

lnformation held by the defendant relating to his father's death.

58. lt is unknown if the FBI maintained any relationship with Alley.

59. Since the defendant withheld the information from the plaintiff and the rest of society,

the plaintiff continues to suffer emotional distress and the losses as alleged in prior

paragraphs. Plaintiff continues to search for more truth surrounding his fathe/s untimely

death

60. After the June 2021 grand jury findings, the defendant has failed to share with the

plaintiff any information surrounding his fathe/s death.

couNT r

CAUSE OF ACNON AGAINSTTHE UNITED STATES

UNDER THE FEDERAT TORT CI.AIMS AgT

51. Paragraphs 1 through 60 are incorporated herein by reference as though fully

set forth.

62. At all times material to this complaint, the agents and employees of the Department

of Justice and the FBI referred to herein, were acting within their scope of employment

53. The United States, if a private person, would be liable to the plaintiffs for the acts

and omissions of its employees and agents described herein under the law of the place

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 where said acts and omissions occurred.

64. The plaintiff submitted an Administrative Claim to the FBI on or about April 12, 2023.

Such claim has subsequently been denied by the FBl.

COUNT I
COMMON I.AW WRONGFUI DEATH UNDER TENNESSEE IAW

65. Paragraphs l through 60 are incorporated herein by reference as though fully

set forth.

65. The defendant is liable to the plaintiff for injuries and damages resulting from

the defendant's failure to protect Samuel Pettyjohn which lead to his wrongful death.

couNT il
COMMON LAW IOSS OF CONSORTIUM UNDERTENNESSEE IAW

67. Paragraphs 1 through 60 are incorporated herein by reference as though fully

set forth.

68. The defendant is liable to the plaintiff for injuries and damages resulting from

the loss of consortium the plaintiff has experienced and continues to experience since

the death of his father.

couNT ilt
COMMON tAW INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS UNDER TENNESSEE I.AW

69. Paragraphs 1 through 60 are incorporated herein by reference as though fully

set forth.

70. The defendant is liable to the plaintiff for injuries and damages resulting from the

intentional infliction of emotional distress that the plaintiff has experienced and continues

to experience due to the acts and/or omissions of the defendant

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 cout{T rv
COMMON I.AW NEGUGENT INFUCTION OF EMONONAT DISTRESS UNDER TENTIIESSEE I.AW

7L. Paragraphs 1 through 50 are incorporated herein by reference as though fully

set forth.

72. The defendant is liable to the plaintifffor injuries and damages resulting from the

negligent infliction of emotional distress that the plaintiff has experienced and continues to

experience due to the acts andlor omissions of the defendant.

WHEREFORE, plaintiff requests that this Court:

1. Award compensatory damages to the plaintiff against the defendant;

2 Award costs and attorney's fees to the plaintiff;

3 Award such other and further relief as this court may deem appropriate.

THE PLAINNFF HEREBY DEMANDSA,URYTRIALON THOSE COUNTS ON WHICH HE IS

ENNTLED TO HAVE A TRIAT BY JURY.

Submitted this the 16th day of May,2022

/s/ Neal Pinkston

Neal Pinkston, TN BPR # OZL245
Pinkston Law, PLLC
L2l6E. Main St., Ste. 206
Chattanooga, TN 37408
(Office Number) (423) 654-8325
mnealpinkston @gmail.com

t2
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 JS {,{ (Rct. 0{21)
CIVIL COVER SHEET
Thc JS.l4 civil covcr shat rrtd &c informarion containcd hcrcin rcithcr rcplc nor supplcnrnt rhc filiry and scrvicc of plcdings or othcr popcrs
as rcquircd by lsti., cxccp as
providcd by local rules of cour Thb form. approvcd by rhc Judicial Confcrencc of Oc Unircd Srercs in Scptcmbcr l9?4, is cquircd
for thc usc of thc Clcrk of Courr for dlc
of thc civil docka street , ts?R0'cIro,t5 oiv NErT PAGE oF rH toRM) $
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MarrellGraham United Strates Of Amerie

@) Coumy of Residcncc of Finr Lisrcd Plaindff Cobb County CrA County of Rcidcrte of First Lisrd Defcndanr
(UGEPT IN U.S PIJIIfl'II;I; CASES) (tN U S. pIAilvTtFFCASESONLT)
NOTE: ry L{!rD IOND€MNATION cAsEs. UsE THE LOCATTON OF
THE TRACT OF IAND INVOLVED.
(C) Anorncys frn Namc, ,tdnss, od Telcptwc Nlnlrrr) Attorncys (IlKrc*n)
Pinkston Law, PLLC 1216E. Main St., Ste.206
Chattanooga, TN 37408 (423)654€326

II. BASIS OF JURISDICTION ano* a, -x' one bx onty) CITIZENSIIIP OF PRINCIPAL PARTIES r2... a -x- mau hxfu prai*,lf
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VI. CAUSE OF ACTION
('calh tnd ol'lcr brtixr! lctivitiy
vrr. REQUESTED IN CHECK IF THIS IS A CINSS ACTION DE,unn.-D S CHECK YTS only if dcmrndcd in complaint:
CO}TPLAINT: m,tDER RULE 23, F.R.Cv.P. JTISYDEMAND: EIYGS EINO
vItI. RELATED CASE(S)
(Stt uuttrlr,ttuts):
TFANY ruDCE MCKET NUMBER
IJAI ts 5IqNA I UKts UI AI-I(,XAIIY Q}- REC\)RD
0t1&:m23 /!t t{€el Piri(ltn
FOR OFIICE USE ONLY

RECEIPT ICase 1:23-cv-00115-KAC-CHS

AVOI'NT
Document 1-1 Filed 05/16/23
APPLYNG trP JIjDGE
Page 1 of 2 PageID #: 13
TTAG, .IUDGE
JS.tl Rcvarc (Rcv 0rl4l )

INSTRUCTIONS FOR ATTORNEYS COMPLETING CTVIL COVER SHEET FORM JS 44

Authority For Civil Cover Sheet

The JS 44 civil covcr shcct and the informalion containcd hcrein neither rcplaccs nor supptemans the filings and scrvicc ofplcading or other papcrs as
required by law. cxccPt as provided by local rulcs of coun. This form, approvcd by the Judicial Confercncc of thc Unitcd Stares in Septembcr l9?4. is
rcquirtd for the usc of thc Clcrk of Coun for the purposc of initiating the civil dockct shect. Consequently. a civil covcr shc.ct is submitrcd to rhe Clcrk of
Court for cach civil complaint filed. The attorncy filing a case should complctc ths form as follorvs:

l(r) Plrintiffs-Defendents. Enter names (lasL ftrsL middle initial) of plaintiffand dcfendant lf rhe plaintiffor dcfcndant is a governmenl agcncy. ssc
only thc full namc or standard abbrcviuions. If thc plaintiffor defendant is an official rvithin a governmcnt agcncy. identi$ first rhe agency and thcn
the oflicial, giving both narne and rirle.
(b) CountyofRcsidcoce. Foreachcivil cascfildcxccptU.S.plainriffcascs,cntcrthcnameofthecountywhcrcthcfirstlistcdplainriffresidesatrhc
time of filing' ln U'S. plaintiffcas€s, cntcr thc namc of the county in which thc firs listed defendant residcs ar rhc rimc of filing. (NOTE: ln land
condernnation cascq thc county ofrcsidancc ofthc "dcfcndant" is rhe location ofrhc tract of land involvod.)
(c) Attorneys. Enter the firm namc. addrcss. telephone numbcr, and attomey of record. If therc arc scvcnal anomeys, list them on an attachmcflt, noting
in this section "(sce atachmcnt)".

lI. Jurisdiction. Thc basis ofjurisdiction is sct forth undcr Rule 8(a), F.R.Cv.P., which rcquircs rhat jurisdictions 619 sho$.n in plcadings. place an "X'
in onc of thc boxcs. lf there is morc than onc basis ofjurisdiction, pr€ccdcncc is given in rhe order shown bclow.
Unitcd States plaintiff. (l) Jurisdiction besed on 28 U.S.C. 1345 and 13a8. Suis by agencics and oflicsrs of the United Sarcs arc includcd hcre.
United Starcs dcfcndant. (2) When the plaintiff is suing the Unitcd States is ofliccrs or agcncieq place an "X" in this box.
Fedcralqucslion. (3)Thisrcferstosuitsunder28U.S.C. l33l,whcrcjurisdictionarisesundertheConstitutionofthcUnitcdStates,anamcndmcnr
to thc Constitutioq an act of Congrcss or a trcaty of the Unircd Statcs. In cascs where the U.S. is a pany, thc U.S. plaintiffor defendant codc takcs
precodcncc, and box I or 2 should bc markcd.
Diversity of citizcnship. (a) This refers to suits undcr 28 U.S.C. 1332, wherc partics arc citizcns of differcnt gaes. When Box 4 is checke4 rhe
citizcnship of the differcnt partics must bc checked. (See Secrion III bclow; NOTE: federel question ections tlkc prccc{cncc ovcr diversity
cascr.)

III. Resftlencc (citizcnship) of Priocipel Pertics. This section of thc JS 44 is to be completed if divcrsity of citizcnship was indicared abovc. Mark rhis
section for cach principal party.

ry. Neturc of SuiL Placc an "X" in the appropriate box. If thcrq are multiple naturc of suit codcs associated with the case, pick rhe naturc of suit code
that is most applicable. Click herc for: Naurre of Suir Code Dcsgiorions.

V. Origin. Place an "X" in one of thc scvcn boxes.

(l) Cascs which originatc in thc United Srares disrrict courrs.
Original Procccdings.
Removcd from State Coun. (2) hocccdings initiatcd in state couns may bc rcmovcd to thc discict couns under Titlc 2E U.S.C., Scction 1441.
Rcmanded fr'om Appelluc Court. (3) Check this box for cascs rcrnandcd to the district court for furthcr action. Use the date of remand as thc filing
darc.
Rcinstarcd or Reopened. (a) Chcck this box for cascs rcinstated or rcopcncd in rhe districr court Usc thc rcopcning datc as the filing dare.
Transfened from tuiothcr Distict. (5) For cases transfcrrc{ undcr Title 28 U.S.C. Secdon la0a(a). Do nor usc rtriJ for wirhin disuict ransfcrs or
multidisrict litieuion transfers.
Multidisrricr Litiguion - franifcr. (6) Check this box when a multidisrrict case is trans{brred inro rhe disrrict undcr aurhority of Title 28 U.S.C.
Scction 14O7.
Multidisria Litigation - Dircct Filc. (8) Check this box when a multidistricr casc is filed in rhe same disrricr as rhc Mastcr MDL docker
PLEASE NOTE THAT THERE IS NOT AN ORIGIN CODE 7. Origin Codc 7 was tscd for historical records and is no longcr rclcvanr due to
changes in statute.

V[ Crusc of Actioo. Rcport thc civil statute dircctly rclatcd to thc causc of action and give a bricf dcscription of thc causc. Do not cite jurisdictionel
ttrtutc unlcss divcrsity. Examplc: U.S. Civil Staturc:47 USC 553 Bricf Dcscription: Unauthorized reception of cablc scrvicc.
VIt. Rcquestcd in Complrinl Class Action. Placc an "X" in this box if you arc liling a class:rcrion under Rule 23, F.R.Cv.P.
Dcmand. ln this spacc entcr thc actual dollar amount being demandcd or indicate orher deman4 such as 8 prcliminary injunction.
Jury Dcrnand. Check the appropriate box to indicatc whether or not a jury is bcing dcmandcd.

VllI. Rchtcd Cucs. This scction of the JS 44 is uscd to rcfcrcncc rclued pcnding cascs, if any. If thcrc are relared pending cases, insert the dockct
numbers and the conespondingjudge names for such cases

Drtc end Attoracy Sfnrturc. Due and sign thc civil covcr sheer

Case 1:23-cv-00115-KAC-CHS Document 1-1 Filed 05/16/23 Page 2 of 2 PageID #: 14

AO,l40 (Rev. 06/12) Sumrnons in a Civil Acrion

UNrrep Srnres Dlsrrucr CoURT

for the

ftiarrellGraham
)
)
)
)
Pl4intifls) )
v. )
Civil Action No.
United States of America )
)
)
)
)
Dcfendands) )

SUMMONS IN A CTUL ACTION

T o : ( D dendan r' s rwne and dd rc s s,

;liffJ*:l'loo,,.,"r,, orri ce
Civil Process Clerk
800 lvlarket St, Suite 211
Knoxville, TN 37902

A lawsuit has been filed againsr you.

Within 2l days after service of this summons on you (not counting the day you received it) days if you
- orin60Fed.
are the United States or a United States agency, or an officer or employee of the United States described R. Civ.
P.12 (a)(2) or (3) you must serve on the plaintiffan answer to the anached complainr or a motion under Rule 12 of
- Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff s anorney,
the Federal Rules of
whose name and addrcss are:
Neal pinkston
Pinkston Law, PLLC
1216 E. [Vlain St., Ste.206
Chattanooga, TN 37408
( (423) 6s4-8326
mnealpinkston@gmail.com

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT

Date:
Sigrcture of Cle*or Depurr* Clcrk

Case 1:23-cv-00115-KAC-CHS Document 1-2 Filed 05/16/23 Page 1 of 2 PageID #: 15

AO 440 (Rey. 06/12) Sumnroos in a Ctvil Acrion (Page 2)

Civil Action No.

PROOF OF SERVICE
(This sectbn st ouu not be filed with thc court unless reqabed by Fed R. Civ. P. a 0)
This summons for fuanc of Mividual and dth, if any)

was received by me onz2arc)

O I penonally served the summons on rhe individual *ebce)

on (dotc) ;or
O I left the summons at the individual's residence or usual place of abode with (nanu)

, a pe6on of suitable age and discrction who rcsides therc,

On (date) , and mailed a copy to the individual's last known address; or

O I served the summons on (narrt ofitdividual) , who is

designated by law to accept service of process on behalf of fuanu of orgoizstion)

on1ddc) ;or
Cl I rctumed the summons unexecuted because ;or
O Other gpccify):

My fees are $ for travel and $ for sewices, fora totd of $ O.OO

I declare under penalty of perjury that this infonnation is true.

Darc:
Scner's sigrutwe

Priwed rune and tillc

Scmer's address

Additional information regarding attempted service, etc:

Case 1:23-cv-00115-KAC-CHS Document 1-2 Filed 05/16/23 Page 2 of 2 PageID #: 16

AO 44O (Rcv.06/12) Summons in a Civil Acrion

UNIrep Sreres DrsrRrcr CoURT

for the

MarrellGraham
)
)
)
)
Plaintifrs) )
)
v Civil Action No.
)
United States of America
)
)
)
)
Defendant(s) )

SUMMONS IN A CTVIL ACTION

To: @cfendant's runtc and address)

united states Attomey General t\larrick Garland
United States Departnent of Justice
950 Pennsylvania Avenue, NW
washington, Dc 2053G0001

A lawsuit has been filed against you.

Within 2l days after service of this summons on you (not counting the day you received it) or 60 days if you
-
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) you must serve on the plaintiffan answer to the anached complaint or a motion under Rule l2 of
-
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff s attorney,
whose name and address are:
NealPinkston
Pinkston Laq PLLC
1216 E. tvtain St., Ste.206
Chattanooga, TN 37408
( (423) 6s4-8326

If you fail to rcspond, juifiilitififfii;TiifF""ered against you for rhe rclief demanded in the comptaint.
You also must file your answer or motion with the court.

CLERK OF COURT

Date
Sigrcture of Clcrk or Deputy Cle*,

Case 1:23-cv-00115-KAC-CHS Document 1-3 Filed 05/16/23 Page 1 of 2 PageID #: 17

AO 4a0 (Rcv. 06f 12) Sunmns in e Civil Aaioo (Ptp 2)

Civil Action No.

PROOF OT SERVICE
(Thb sectbn should rct befiled vith iltc court utbss requird by Fed R Civ. P. a 0)
This Sumrnons fot (nanu ol indivi&nl and rtne, if any)
was r€ceived by rne onuatc)

Cl I personally served the summons on the individual atebc)

on (datc) ;or
O I left the summons at the individud's rcsidcnce or usual place of abode with Owte)

,a peson of suitable age urd discretion who resides there,

ontdaQ) , and mailed a copy to the individud's last known address; or

Cl I served the sumrnons onQanuofbrdivitluat) , who is

designated by law to accept scrvice of process on behalf of Qwtuoforgoniuriott)

onUate) or

O I reurnod the summons unexecutcd bccause ;or

Cl Otherfryccrtr;

My fees are $ for tnavel and $ for services, fora toal of $ O.OO

I doclare under penalty of perjury that this information is tnre.

Date:
*ncr's signa/l,ttz

Priltcd nanu otd tith

Scncr'sddnss

Additional information rcgading anernptod sewice, etc:

Case 1:23-cv-00115-KAC-CHS Document 1-3 Filed 05/16/23 Page 2 of 2 PageID #: 18