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IN THE SUPERIOR COURT

OF DEKALB COUNTY
GEORGIA
ANTHONY S. TRICOLI,
Plaintiff,
vs.

ROB WATTS; RON CARRUTH; JIM


RASMUS; MARK GERSPACHER;
SHELETHA CHAMPION; HENRY
HUCKABY; JOHN FUCHKO; STEVE
WRIGLEY; BEN TARBUTTON; THE BOARD
OF REGENTS OF THE UNIVERSITY
SYSTEM OF GEORGIA; SAM OLEI\S, THE
ATTORNEY GENERAL OF GEORGIA; and
ROBIN JENKINS
Defendants.

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CIVIL ACTION NO. 14.CV-49II


JURY TRIAL DEMANDED

AMENDED VERIFIED COMPLAINT

Comes now Plaintiff Anthony Tricoli pursuant to OCGA S 9-11-15

and amends the Complaint for Damages and Injunctive Relief filed on
May 7 , 201,4, as follows:

L
The following pleadings are incorporated by reference herein:

a) Complaintfor Damages and Injunctive Relief, filed May 7,201.4.


b) Affidavit. of Anthony S. Tricoli, filed September 19,21,04.
c) Notice of Filing of Evidence of Written Contract and Motionfor
Ssnctions, filed October

t0,2014.

d) supplementto Notice of Filing of Evidence of written contract


and Motion for sanctions
Requests

/ Reply to Defendants, Responses to plaintiffs

for Admissions / and Reply to Defendants'

Filing of Evidence of Written Contract and Motion

Response to

for

plainitiffs

Sanctions, including

Defendant's )bjections and Responses to plaintiffs Requests


for
Admissions, filed Novembe r 4, 20'J,4.

Motion

for Interlocutory Injunction, filed

Novembe

1.9, 2104.

2.

'

The exhibits to the above-referenced pleadings are also

incorporated by reference herein, as follows:


a) True and correct copies of documents kept by Defendants
in

the regular course of business and produced pursuant to


requests under
the Georgia Open Records Act.
bJ True and correct copies of documents kept by Defendants
in

the regular course of business in electronic form and downloaded


from
Defendants' websites.

c) True and correct copies of media reports as they appeared in

the referenced media companies'reports and downloaded from their


websites.
3.

Plaintiff, according to the attached Verification, attests to the truth


of all facts alleged and incorporated within this Verified Amended

Complaint.

Respectfully submitted this 5th day of December,2UI4.

$'1kl'Htf* I " *l**tPt4r*-iY$"

I'f

't

P.O. Box 192


Athens, GA 30603
1671 Meriweather Drive

Bogart, GA30622
(706) s43-r844
(706) 207-6e82 p

CERTIFICATE OF SERVICE
Undersigned counsel hereby certifies that all Defendants in this action have
been served this Amended Verified Complaint via US mail, this 5th day of
December, 20t4, as follows:

Samuel S. Olens
Dennis R. Dunn
Kathleen M. Pacious
Annette M. Cowart
Loretta L. Pinkston
Christopher A. McGraw
C. Mclaurin Sitton
Office of the Attorney General
40 Capitol Square, SW
Atlanta, Georgia 30334- 1 300

1
t

ra
1,'

P.O. Box 192


Athens, GA 30603
1671 Meriweather Drive

Bogart, GA30622
(706) s43-1844
(706) 207-6982 p

VERIFICATION

the undersigned Plaintiff Anthony S. Tricoli, upon being duly sworn, and
having reviewed the Verified Amended Complaint and all documents incorporated
by reference therein, including the exhibits, do hereby attest that all matters averred
therein are true and correct, to the best of my personal knowledge. As to any
matters not within my personal knowledge, I believe them to be true and correct
based on the supporting documentation as duly authenticated in the Verified
Amended Complaint. Further, as to all matters alleged upon information and beliel I
believe them to be true.
I,

This 5th day of December,20L4.

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i |i.,i -, l'

Anthony S.iTricoli

r*1'l-

- dayof December,201.4.l amcertified


Sworn and subscribed beforeme,this >
to administer oaths, and have verified the identity of the Plaintiff who signed the
above Verification in my presence.

Notary Public