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IN THE SUPERIOR COURT OF COWETA COUNTY
STATE OF GEORGIA
Rhonda McClendon,
as Guardian of Gary Wayne Thompson,
an incapacitated adult
Plaintiff,
v.
Civil Action No.
JURY TRIAL DEMANDED
Mark Andrew Gomez,
Tina Barron,
Leigh Ann Ware (formerly Leigh Ann Robertson),
James Bret Robertson,
Jamie Robertson,
Derwin Ware,
Nathaniel Russell,
John Doe 1,
John Doe 2,
John Doe 3,
Jane Doe 1,
Jane Doe 2, and
Jane Doe 3
Defendants
COMPLAINT
FOR VIOLATIONS OF
RACKETEER INFLUENCED AND CORRUPT ORGANIZATIONS ACT and
TORTIOUS CONDUCT
Preliminary Statement
1. Preface
1.1
The unlawful and unconscionable conduct by the Defendants, often acting
together and in concert, gives rise to this cause of action. The Georgia Racketeer
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