Answer of Estate of Chandler LeCroy

E-FILED IN OFFICE - JM
CLERK OF STATE COURT

GWINNETT COUNTY, GEORGIA
23-C-04803-S3
10/27/2023 12:19 PM
TIANA P. GARNER, CLERK
IN THE STATE COURT OF GWINNETT COUNTY
STATE OF GEORGIA
VICTORIA S. BOWLES
Plaintiff,
v.
CIVIL ACTION NO.:
UNIVERSITY OF GEORGIA ATHLETIC 23-C-04803-S3
ASSOCIATION, INC.,
A Georgia Nonprofit Corporation,
JALEN D. CARTER, individually and as an

agent and employee of BREADMAN JALEN,
LLC, a Florida Limited Liability Company;
ROBERT W. HUGHES, in his capacity As the

Court Appointed Personal Administrator of the
Estate of CHANDLER LECROY, deceased;
and
JOHN DOES Nos 1-5,
Defendants.
DEFENDANT THE ESTATE OF CHANDLER LECROY’S (DECEASED) ANSWER

AND AFFIRMATIVE DEFENSES TO PLAINTIFF’S COMPLAINT FOR DAMAGES
COMES NOW, THE ESTATE OF CHANDLER LECROY, deceased (hereinafter
“Defendant LeCroy”) in the above referenced matter, and in response to Plaintiff’s Complaint for
Damages (hereinafter “Complaint”), states as follows:
INTRODUCTION
Defendant denies and objects to the entirety of the “INTRODUCTION” section of the
Complaint – including the subheadings “Permissive Use,” “Negligent Entrustment”, and “Events
Leading to the Crash”, all of which improperly contain legal arguments and legal conclusions not
suited for an initial Complaint.
DEMAND FOR TWELVE PERSON JURY
Defendant demands a trial by jury of twelve (12) persons.
AFFIRMATIVE DEFENSES
FIRST DEFENSE
Plaintiff’s Complaint fails to state a claim against Defendant LeCroy upon which relief can
be granted.
SECOND DEFENSE
Defendant LeCroy raises the defense of improper venue.
THIRD DEFENSE
Upon information and belief, and pending further investigation and discovery, no act or
omission of Defendant LeCroy proximately caused or contributed to any of Plaintiff’s alleged
damages.
FOURTH DEFENSE
Plaintiff’s Complaint should be dismissed because Plaintiff
failed to strictly comply with the notice provisions of the Georgia Tort Claims Act
(“GTCA”), O.C.G.A. § 50-21-26.
FIFTH DEFENSE
Plaintiff was negligent in failing to use reasonable care of Plaintiff’s own safety and such
negligence was a proximate cause of Plaintiff’s damages. Accordingly, any recovery by Plaintiff’s
in this action must be reduced in accordance with Plaintiff’s own negligence, or barred completely
if Plaintiff was at least fifty percent (50%) negligent or greater.
SIXTH DEFENSE
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The damages of which the Plaintiff complains were the direct and proximate result of
negligence on the part of persons or entities other than Defendant LeCroy and Defendant LeCroy
denies that she was negligent.
SEVENTH DEFENSE
If any negligence on the part of Defendant LeCroy can be found, which negligence
Defendant LeCroy specifically denies, then Plaintiff failed to exercise ordinary care and could
have avoided the consequences of any such negligence of Defendant and the Plaintiff is thereby
barred from any recovery.
EIGHTH DEFENSE
Plaintiff’s claims for attorney’s fees fail to state a claim upon which relief can be granted.
NINTH DEFENSE
Plaintiff’s injuries, if any, were the result of pre-existing or congenital problems or
conditions unrelated to Defendant LeCroy.
TENTH DEFENSE
Defendant LeCroy affirmatively asserts that the injuries and damages alleged by the
Plaintiff are as a result or acts or omissions by other persons, corporations or professional
associations or entities other than Defendant LeCroy, for which Defendant LeCroy had no control
and is not responsible.
ELEVENTH DEFENSE
This Defendant pleads that fault must be apportioned among all persons or entities which
contributed to the alleged injury or damages in compliance with O.C.G.A. § 51-12-33(c).
TWELFTH DEFENSE
Page 3 of 45
Any loss or damage allegedly suffered by Plaintiff, if there be any, was not the direct or
proximate result of any act or omission of Defendant LeCroy.
THIRTEENTH DEFENSE
Defendant LeCroy alleges that any damages suffered by Plaintiff are a result of
superseding, independent, or intervening causes, or are the results of yet unknown causes over
which Defendant LeCroy had no control and for which she is not responsible.
FOURTEENTH DEFENSE
Plaintiff knew about the risk, and voluntarily undertook the risk that led to the incident
and/or damages complained of in this case.
FIFTEENTH DEFNSE
Defendant affirmatively asserts the defense that Plaintiffs’ claims may be barred, in whole
or in part, by the doctrines of waiver, estoppel, laches, release, recoupment and set off.
SIXTEENTH DEFENSE
Defendant states that in the event the Plaintiff should recover under one or more of the
counts alleged in Plaintiffs’ Complaint for Damages, Defendant is entitled to a set off and/or
reduction for any and all collateral source benefits either paid or payable to the Plaintiff.
SEVENTEENTH DEFENSE
The imposition of punitive damages in this case would violate the Due Process clauses of
the Fifth and Fourteenth Amendments to the United States Constitution and the Constitution of the
State of Georgia because the standards of liability for punitive damages in Georgia are unduly
vague and subjective, and permit retroactive, random, arbitrary and capricious punishment that
serves no legitimate governmental interest.
EIGHTEENTH DEFENSE
Page 4 of 45
The imposition of punitive damages in this case in the absence of the procedural safeguards
accorded to defendants subject to punishment in criminal proceedings, including a reasonable
doubt standard of proof, would violate the Fourth, Fifth, and Sixth Amendments and the Due
Process Clauses of the Fifth and Fourteenth Amendments to the United States Constitution.
NINETEENTH DEFENSE
The imposition of punitive damages in this case would violate the Excessive Fines Clause
of the Georgia Constitution as set forth at Article I, Section I, Paragraph XVII and the Excessive
Fines Clause of the Eighth Amendment to the United States Constitution.
TWENTIETH DEFENSE
The imposition of punitive damages in this case in the absence of a showing of malicious
intent to cause harm to the Plaintiff would violate the Due Process Clauses of the Fifth and
Fourteenth Amendments to the United States Constitution.
TWENTY-FIRST DEFENSE
There is no basis in law or fact for the imposition of punitive damages with respect to the
claims of the Plaintiff against Defendant.
TWENTY-SECOND DEFENSE
Plaintiffs have failed to properly plead and/or allege the applicability of a Section 1983
claim against Defendant LeCroy, including without limitation, standing.
TWENTY-THIRD DEFENSE
To the extent that Plaintiffs have satisfied the pleading requirements as against Defendant
LeCroy for a Section 1983 claim, Plaintiffs’ claims are barred – and Defendant LeCroy is shielded
from liability – by qualified immunity.
TWENTY-FOURTH DEFENSE
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There is or may be a lack of joinder of one or more indispensable parties who should or
must be joined and, without the joinder of these proper parties, complete relief cannot be accorded
among those attempted to be made parties to this action.
TWENTY-FIFTH DEFENSE
Defendant LeCroy pleads the doctrine of last clear chance as a defense.
TWENTY-SIXTH DEFENSE
This Court lacks jurisdiction over these claims and/or Defendant LeCroy.
TWENTY-SEVENTH DEFENSE
Plaintiff’s Complaint should be dismissed due to failure of process, improper service of
process, insufficiency of service of process, and failure to comply with O.C.G.A. § 50-21-35.
Specifically, Plaintiff has failed to serve process upon the chief executive officer
of the BOR at his or her usual office address. Also, Plaintiff has failed to serve process upon the
Director of the Risk Management Division of the Department of Administrative Services at his
usual office address; and, Plaintiff has failed to mail to the Attorney General at his
usual office address, by certified mail or statutory overnight delivery, return receipt requested, a
copy of the Complaint showing the date of filing.
TWENTY-EIGHTH DEFENSE
Plaintiff’s Complaint against the Defendant LeCroy is barred by official immunity,
pursuant to O.C.G.A. § 50-21-25.
TWENTY-NINTH DEFENSE
This action is barred in whole or in part by the doctrine of sovereign immunity.
THIRTIETH DEFENSE
Page 6 of 45
Plaintiff’s Complaint against Defendant LeCroy should be dismissed because she was in
acting within the scope of their official duties and employment with a
state government entity of the State of Georgia; thus, Defendant LeCroy is not subject to
lawsuit or liability therefor, pursuant to O.C.G.A. § 50-21-25(a).
THIRTY-FIRST DEFENSE
Plaintiffs’ action against Defendant LeCroy should be dismissed to the extent it is
based upon the acts or omissions of persons who are not state officers or employees as defined
by the Georgia Tort Claims Act (“GTCA”), O.C.G.A. § 50-21-22(7).
THIRTY-SECOND DEFENSE
Plaintiffs’ action against Defendant LeCroy should be dismissed to the extent it seeks
recovery for losses resulting from acts or omissions for which there is no waiver of sovereign
immunity under the GTCA, pursuant to O.C.G.A. § 50-21-24.
THIRTY-THIRD DEFENSE
Plaintiffs’ action against Defendant LeCroy should be dismissed to the extent it seeks
recovery for losses resulting from the exercise or performance of or the failure to exercise or
perform a discretionary function or duty on the part of a state officer or employee, for which
there is no waiver of sovereign immunity under the Georgia Tort Claims Act, pursuant to
O.C.G.A. § 50-21-24(2).
THIRTY-FOURTH DEFENSE
Defendant LeCroy adopts and incorporates by reference any affirmative defenses raised by
other defendants in this action.
THIRTY-FIFTH DEFNSE
Page 7 of 45
Defendant LeCroy specifically reserves the right to amend her Answer and Affirmative
Defenses to Plaintiffs’ Complaint to assert any defense, avoidance or affirmative defense which
may become apparent during the course of this litigation.
THIRTY-SIXTH DEFENSE
Defendant LeCroy further reserves the right to assert any other defenses as may be shown
through discovery or pleadings including all those set forth in O.C.G.A. § 9-11-8(c).
DEFENDANT CHANDLER LECROY’S ANSWER TO PLAINTIFF’S COMPLAINT
Defendant LeCroy answers the numbered paragraphs of Plaintiff’s Complaint as follows,
however, objects to each of the headings in the Complaint to the extent they contact legal
conclusions, arguments, or allegations:
PARTIES
1.
Defendant LeCroy is without knowledge and information sufficient to form a belief as to
the truth of the allegations set forth in Paragraph No. 1 of Plaintiff’s Complaint, and on that basis,
deny the same and demands strict proof thereof.
2.
3.
Page 8 of 45
4.
5.
6.
Defendant LeCroy admits that Robert W. Hughes was appointed as a Personal
Administrator of the Estate of Defendant LeCroy for limited purposes, but denies the remaining
allegations contained in Paragraph 6 of Plaintiff’s Complaint as worded.
7.
Defendant LeCroy denies the allegations set forth in Paragraph No. 7 of Plaintiff’s
Complaint and demands strict proof thereof.
8.
9.
Page 9 of 45
10.
11.
12.
Defendant admits that Gwinnett County might have jurisdiction, but denies that venue is
proper in Gwinnett County.
FACTS GIVING RISE TO PLAINITIFF’S CLAIMS
13.
Defendant LeCroy restates all affirmative defenses and responses to Paragraphs 1-12 of
the Complaint as if fully restated herein.
14.
Defendant LeCroy admits the allegations contained in Paragraph 14 of Plaintiff’s
Complaint.
15.
Defendant LeCroy admits the allegations contained in Paragraph 15 of Plaintiff’s
Complaint.
16.
Page 10 of 45
17.
Defendant LeCroy admits she was assigned to host football recruits and their families but
denies the remaining allegations contained in Paragraph No. 17 of Plaintiff’s Complaint.
18.
The allegations contained in Paragraph No. 18 of Plaintiff’s Complaint apply to a different
defendant and require no response from Defendant LeCroy. To the extent a response is deemed
necessary, Defendant LeCroy is without sufficient knowledge or belief to admit or deny the
allegations contained in Paragraph No. 18 of Plaintiff’s Complaint, and therefore denies the same.
19.
Defendant LeCroy admits she was assigned an SUV to use over but denies the remaining
allegations contained in Paragraph No. 19 of Plaintiff’s Complaint.
20
21.
Defendant LeCroy admits she was assigned an SUV to use over but denies the remaining
22.
Page 11 of 45
23.
24.
Defendant LeCroy admits she was assigned an SUV to use but denies the remaining
25.
Defendant LeCroy admits she was assigned to host football recruits and their families but
denies the remaining allegations contained in Paragraph No. 25 of Plaintiff’s Complaint.
26.
27.
28.
The allegations contained in Paragraph No. 28 of Plaintiff’s Complaint apply to the
Plaintiff and require no response from Defendant LeCroy. To the extent a response is deemed
Page 12 of 45
EVENTS AT AND FROM SAKURA RESTAURANT
29.
The allegations contained in Paragraph No. 29 of Plaintiff’s Complaint apply to the
Plaintiff and require no response from Defendant LeCroy. To the extent a response is deemed
30.
Defendant LeCroy is without knowledge or information sufficient to form a belief as to the
truth of the allegations contained in Paragraph 30 of Plaintiff’s Complaint, and therefore denies
the same.
31.
the same.
32.
truth of the allegations contained in Paragraph 32 of Plaintiff’s Complaint.
33.
the same.
34.
Page 13 of 45
the same.
35.
the same.
36.
the same.
37.
Defendant LeCroy is without knowledge or information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 37 of Plaintiff’s Complaint, and therefore denies
the same.
38.
the same.
39.
the same.
Page 14 of 45
40.
the same.
41.
the same.
42.
Defendant LeCroy is without knowledge or information sufficient to form a belief as to
the truth of the allegations contained in Paragraph 42 of Plaintiff’s Complaint, and therefore denies
the same.
43
the same.
44.
the same.
45.
Page 15 of 45
the same.
46.
the same.
47.
the same.
48.
the same.
49.
the same.
50.
the same.
51.
Page 16 of 45
the same.
52.
the same.
53
the same.
54.
the same.
55
the same.
56.
Defendant LeCroy is without sufficient knowledge or belief to admit or deny the
57.
Page 17 of 45
58.
59.
60.
61.
62.
63.
64.
Page 18 of 45
65
66.
67.
68.
69.
70.
71.
72.
Page 19 of 45
73.
74.
75.
76.
77.
78.
79.
80.
Page 20 of 45
81.
Defendant LeCroy admits that Ms. Bowles rode with her in the assigned SUV but denies
the remaining allegations contained in Paragraph No. 81 of Plaintiff’s Complaint.
82.
Defendant LeCroy admits that Ms. Bowles rode with her in the assigned SUV but denies
the remaining allegations contained in Paragraph No. 82 of Plaintiff’s Complaint.
83.
84.
Defendant LeCroy admits that Warren McClendon and Devin Willock rode with her in the
assigned SUV but denies the remaining allegations contained in Paragraph No. 84 of Plaintiff’s
Complaint.
EVENTS OF THE FATAL TRIP
85.
86.
87.
Page 21 of 45
88.
89.
90.
91
92.
93
94.
Page 22 of 45
95.
96.
97.
98.
99.
100.
101.
102
Page 23 of 45
103.
104
105
106
107.
108.
109.
110.
Page 24 of 45
111.
112.
113.
114.
115.
116.
117.
Page 25 of 45
118.
119
120.
121.
122.
123.
124.
Page 26 of 45
125.
126.
127.
128.
Defendant LeCroy admits that Chandler LeCroy and Devin Willock died from the subject
crash but denies the remaining allegations contained in Paragraph No. 128 of Plaintiff’s Complaint,
and therefore denies the same.
PERMISSIVE USE
129.
130.
Page 27 of 45
131.
132.
allegations contained in Paragraph No. 132 of Plaintiff’s Complaint, and therefore denies the same
133.
134.
135.
136.
Page 28 of 45
137.
UGA ATHLETIC ASSOCIATION’S KNOWLEDGE IF LECROY’S PRIOR RECKLESS

DRIVING
138.
necessary, Defendant LeCroy denies the allegations contained in Paragraph No. 138 of Plaintiff’s
Complaint.
139.
140.
141.
142.
143.
Page 29 of 45
144.
145.
146.
147.
148.
149.
Defendant Carter’s Driving Conduct Prior To The Day of the Championship Celebration
Page 30 of 45
150.
151.
152.
153.
154.
Page 31 of 45
155.
156.
157.
158.
159.
Page 32 of 45
Defendant Jalen Carter Illegally Left the Scene Of the Crash
160.
161.
162.
163.
164.
165.
Page 33 of 45
166.
167.
Plaintiff Victoria Bowles Was Not Negligent
168.
169.
170.
Page 34 of 45
171.
172.
173.
174.
Injuries, Disability and Damages Sustained By Plaintiff Victoria Bowles
175.
176.
allegations contained in Paragraph No. 176 of Plaintiff’s Complaint and demands strict proof
thereof.
177.
Page 35 of 45
thereof.
178.
thereof.
179.
thereof.
180.
thereof.
181.
thereof.
182.
thereof.
183.
Page 36 of 45
thereof.
184.
thereof.
185.
thereof.
COUNT 1
NEGLIGENCE: UGA ATHLETIC ASSOCIATION
186.
187.
188.
Page 37 of 45
189.
190.
191.
192.
Page 38 of 45
193.
COUNT II
NEGLIGENCE & GROSS NEGLIGENCE: DEFENDANT JALEN CARTER
194.
195.
The allegations contained in Paragraph No. 195 and subpart (a) - (d) of Plaintiff’s
Complaint apply to a different defendant and require no response from Defendant LeCroy. To the
extent a response is deemed necessary, Defendant LeCroy is without sufficient knowledge or belief
to admit or deny the allegations contained in Paragraph No. 195 and subpart (a) - (d) of Plaintiff’s
Complaint, and therefore denies the same.
196.
allegations contained in Paragraph No. 196 of Plaintiff’s Complaint
COUNT III
NEGLIGENCE & GROSS NEGLIGENCE: CHANDLER LECROY
197.
198.
Defendant LeCroy denies the allegations set forth in Paragraph No. 198 and subpart (a) –
Page 39 of 45
(e) of Plaintiff’s Complaint and demands strict proof thereof.
199.
COUNT IV
NEGLIGENCE & GROSS NEGLIGENCE: DEFENDANT BREEDMAN JALEN, LLC
200.
201.
202.
203.
Page 40 of 45
204.
allegations contained in Paragraph No. 204 of Plaintiff’s Complaint
COUNT IV
PUNITIVE DAMAGES
205.
206.
DEFENDANT UGA ATHLETHIC ASSOCIATION
207.
DEFENDANT CARTER
208.
Page 41 of 45
209.
210.
211.
212.
213.
Page 42 of 45
214.
215.
COUNT VI
ATTORNEYS’ FEES UNDER O.C.G.A. § 13-6-11
216.
217.
218.
PRAYER FOR RELIEF
In response to the Paragraph beginning “WHEREFORE,” Defendant denies any and all
Page 43 of 45
allegations and prayers for relief contained therein, including subparts (a) – (k) and demands strict
proof thereof.
All remaining allegations, inferences, conclusions, headings, and argument contained in
Plaintiff’s Complaint not heretofore specifically addressed are denied in their entirety.
Defendant having fully responded to and answered Plaintiff’s Complaint, hereby prays that
it be henceforth discharged without cost to Defendant, with all costs charged to Plaintiff. If the
Court does not discharge the Plaintiff’s Complaint, Defendant demands trial by a jury of twelve.
Respectfully submitted, this 27TH day of October 2023.
QUINTAIROS, PRIETO, WOOD & BOYER, P.A.
/s/ Babatunde Abdulrahman

C. BRENT WARDROP
Georgia Bar No: 553733
CHRISTINA ESSEX
BABATUNDE ABDULRAHMAN
365 Northridge Rd., Suite 230
Atlanta, Georgia 30350
Brent.wardrop@qpwblaw.com
Christina.essex@qpwblaw.com
babatunde.abdulrahman@qpwblaw.com
(770) 650-8737 telephone
(770) 650-8797 facsimile
Counsel for Defendant LeCroy
Page 44 of 45
CERTIFICATE OF SERVICE
This is to certify that I have this day served the foregoing Defendant Chandler Lecroy,
Answer and Affirmative Defenses to Plaintiff’s Complaint with the Clerk of Court using Odyssey
eFileGA which will automatically send e-mail notification of such filing to all parties of record
and/or by depositing a copy of same with the United States Postal Service, with first class postage
prepaid.
This 27th day of October, 2023.
QUINTAIROS, PRIETO, WOOD & BOYER, P.A.
/s/ Babatunde Abdulrahman

Babatunde Abdulrahman
Counsel for Defendant
Page 45 of 45

Answer of Estate of Chandler LeCroy

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E-FILED IN OFFICE - JM

CLERK OF STATE COURT

IN THE STATE COURT OF GWINNETT COUNTY

JALEN D. CARTER, individually and as an

ROBERT W. HUGHES, in his capacity As the

JOHN DOES Nos 1-5,

DEFENDANT THE ESTATE OF CHANDLER LECROY’S (DECEASED) ANSWER

COMES NOW, THE ESTATE OF CHANDLER LECROY, deceased (hereinafter

Damages (hereinafter “Complaint”), states as follows:

DEMAND FOR TWELVE PERSON JURY

Defendant demands a trial by jury of twelve (12) persons.

Defendant LeCroy raises the defense of improper venue.

omission of Defendant LeCroy proximately caused or contributed to any of Plaintiff’s alleged

Plaintiff’s Complaint should be dismissed because Plaintiff

(“GTCA”), O.C.G.A. § 50-21-26.

if Plaintiff was at least fifty percent (50%) negligent or greater.

denies that she was negligent.

barred from any recovery.

Plaintiff’s injuries, if any, were the result of pre-existing or congenital problems or

conditions unrelated to Defendant LeCroy.

Plaintiff are as a result or acts or omissions by other persons, corporations or professional

and is not responsible.

contributed to the alleged injury or damages in compliance with O.C.G.A. § 51-12-33(c).

proximate result of any act or omission of Defendant LeCroy.

and/or damages complained of in this case.

serves no legitimate governmental interest.

accorded to defendants subject to punishment in criminal proceedings, including a reasonable

Fines Clause of the Eighth Amendment to the United States Constitution.

Fourteenth Amendments to the United States Constitution.

claims of the Plaintiff against Defendant.

claim against Defendant LeCroy, including without limitation, standing.

from liability – by qualified immunity.

among those attempted to be made parties to this action.

Defendant LeCroy pleads the doctrine of last clear chance as a defense.

Plaintiff’s Complaint should be dismissed due to failure of process, improper service of

copy of the Complaint showing the date of filing.

Plaintiff’s Complaint against the Defendant LeCroy is barred by official immunity,

pursuant to O.C.G.A. § 50-21-25.

This action is barred in whole or in part by the doctrine of sovereign immunity.

lawsuit or liability therefor, pursuant to O.C.G.A. § 50-21-25(a).

Plaintiffs’ action against Defendant LeCroy should be dismissed to the extent it is

by the Georgia Tort Claims Act (“GTCA”), O.C.G.A. § 50-21-22(7).

immunity under the GTCA, pursuant to O.C.G.A. § 50-21-24.

other defendants in this action.

may become apparent during the course of this litigation.

DEFENDANT CHANDLER LECROY’S ANSWER TO PLAINTIFF’S COMPLAINT

Defendant LeCroy answers the numbered paragraphs of Plaintiff’s Complaint as follows,

conclusions, arguments, or allegations:

Defendant LeCroy is without knowledge and information sufficient to form a belief as to

deny the same and demands strict proof thereof.

Defendant LeCroy is without knowledge and information sufficient to form a belief as to

deny the same and demands strict proof thereof.

Defendant LeCroy is without knowledge and information sufficient to form a belief as to

Defendant LeCroy is without knowledge and information sufficient to form a belief as to

deny the same and demands strict proof thereof.

Defendant LeCroy is without knowledge and information sufficient to form a belief as to

deny the same and demands strict proof thereof.

Defendant LeCroy admits that Robert W. Hughes was appointed as a Personal

allegations contained in Paragraph 6 of Plaintiff’s Complaint as worded.

Complaint and demands strict proof thereof.

Defendant LeCroy is without knowledge and information sufficient to form a belief as to

deny the same and demands strict proof thereof.

Defendant LeCroy is without knowledge and information sufficient to form a belief as to

Defendant LeCroy is without knowledge and information sufficient to form a belief as to