8 S os INTHE STATE COURT OF CHATHAM COUNTY & 388 STATE OF GEORGIA 1, os x o He BECKI TERRY, ) g 2 <8 ) € 237 Plaintiff, ) Lg Se Civil Action No. STCVIDOVES v ) ) SAVANNAH BAIL BONDING and ) JOHN DOE ) ) Defendants. ) d COMPLAINT COMES NOW Becki Terry, plaintiff in the above-styled case, and files this Complaint as follows: PARTIES, JURISDICTION, AND VENUE a Plaintiff is a resident of Chatham County, State of Georgia. 2. Defendant Savannah Bail Bonding, Inc., is a Georgia corporation with its principal place of business located at 618 West Highway 80, Garden City, Chatham County, Georgia 31408. Savannah Bail Bonding, Inc. may be served via its Registered Agent: Mcia Joiner, located at 618 ‘West Highway 80, Garden City, Georgia 31408. 3. Defendant John Doe was a bail bondsman and agent working for the Defendant on or about February 27, 2012. While acting within the scope of his employment, John Doe inflicted negligent and/or intentional acts upon Plaintiff, Becki Terry. Defendant Savannah Bail Bonding, Page -1-Inc., is liable for John Doe's negligent and intentional acts perpetrated within the scope of his employment, pursuant to O.C.G.A. § 51-2-2. 4. ‘Venue and jurisdiction are proper in this Court, There is no diversity of citizenship between the parties. EVENTS AND FACTS SUPPORTING CAUSES OF ACTION 5. Becki Terry was at home with her roommate and fiancé on the morning of February 27, 2012. At around 7:30 a.m. there was a knock on the door. 6 When Ms. Terry’s roommate answered, a man-Defendant John Doe, a “bounty hunter” for Defendant Savannah Bail Bonding, Inc.-stood outside. The man did not identify himself, but stated that he was looking for Becki Terry and demanded that she come with him. 7. Confused, Ms. Terry's roommate allowed the man in. ‘The man immediately went looking for Ms. Terry. When he found her, she was undressed. 8. ‘The man-still unidentified to Ms. Terry and her fianeé-informed Ms. Terry that she was under arrest, He did not expiain why. 9. Ms. Terry pleaded with the man: she told him that there were no charges pending against her. The man, without explanation, grabbed her and handcuffed her. Ms. Terry was still undressed-her fiancé begged the man to allow her to clothe herself before he led her from her Page -2-home, Once Ms. Terry was dressed, the man took her to his car. 10. ‘The man put Ms. Terry in his car and closed the door behind her. Ms. Terry's fiancé watched as the man drove her away. In the car, Ms. Terry pleaded with the man again, explaining that there were no charges pending against her. He continued driving to the Chatham County Jail without further ado, VW. ‘When they arrived at the Chatham County Jail, Ms. Terry was still in handcuffs. At this time, the man identified himself to a corporal as a bail bondsman for Savannah Bail Bonding, Inc. 12. Ms. Terry was taken to receiving, where she was placed in a chair to wait for 15 minutes. The corporal asked for Ms. Terry’s arrest paperwork. The corporal informed John Doe there was ‘no paperwork for the Plaintiff, Becki Terri. The corporal spoke with the bonding company and then the colonel of the jail. With no paperwork, the colonel and corporal instructed the bondsman to take Ms. Terry home. 13, The bondsman refused to take Ms. Terry home unless she paid him gas money. Ms. Terry called her fiancé who was forced to pay the man $20.00 before he would let her free. 14, ‘While returning home around 9:15 a.m., Ms. Terry called Savannah Bai] Bonding, Inc. ‘on the bondsmen’s phone, and demanded an explanation. She described to the Defendant what their bondsman had done to her. Defendant Savannah Bail Bonding, Inc., said they were “sorry” Page -3-