IN THE SUPERIOR COURT OF BROOKS COUNTY

STATE OF GEORGIA

RICHARD JERRY McLEOD,

Plaintiff/ Petitioner

v. CASE NO.

BILLY INGRAM et. al.

Defendants/Respondents

PLAINTIFF/PETITIONERS MOTION AND AFFIDAVIT FOR RECUSAL OF JUDGE

Comes now Richard Jerry McLeod Plaintiff/Petitioner in the above styled action

And requests recusal of all Judges in the Southern Judicial circuit during the pendency of his

Petition for writs of Mandamus and prohibition against Billy Ingram, zoning administrator of

Brooks County. Defendant Billy Ingram committed the unlawful acts petitioner seeks
mandamus for in concert and collaboration with Mike Dewey, Animal control director and
sheriff of Brooks County
The Georgia code of Judicial Conduct, Canon 3(E) provides that Judges shall disqualify
themselves in any proceeding in which their impartiality might be reasonably be questioned, in
which the Judge has a personal bias or prejudice concerning a party or a partys lawyer, or
personal knowledge of disputed evidentiary facts concerning the proceeding.
All of the judges of the Southern Judicial circuit can reasonably be presumed to have a bias

in favor of defendant Mike Dewey of such a nature and intensity to prevent Plaintiff/Petitioner

from obtaining a trial uninfluenced by the Courts prejudgment. The origin and evidence of this

bias is fully explained in the following:

Mike Dewey serves as sheriff of Brooks County and as Brooks County animal control

officer and employee of Brooks County. The offenses for which plaintiff seeks writs involve
Acts performed by Billy Ingram while purporting to perform duties of the Brooks County

Animal Control officer. Dewey and Ingram are alleging he is authorized to perform these acts

under color of law.

It is impossible to conclude that any reasonable person could expect a Judge to conduct an

unbiased hearing concerning activities of a county sheriff with whom he has almost daily

interactions. (As stated by Chief Judge Harry J. Altman when confronted by a motion from CNN

news and the Kendrick Wilson family against Sheriff Prine in a Lowndes County Case). Judge

Altman recused all judges of the Southern Judicial Circuit to ensure the plaintiff was afforded a

fair hearing before an unbiased judge. The Mandamus action against the defendant Dewey and

the Temporary restraining order against defendant Watkins, a collaborator acting in concert with

Dewey presents a situation almost identical to Judge Altmans Lowndes County case. Thus, all of

the Judges of the Southern Judicial Circuit should be recused in the case at bar.

Respectfully submitted,

Richard Jerry McLeod Pro Se

 Personally appeared before me, the undersigned Notary Public duly authorized to administer

oaths, Richard Jerry McLeod, who after being duly sworn deposes and states he is authorized to

make this application on behalf of himself and that the facts alleged in the foregoing affidavit are

true and correct based on his personal knowledge.

Richard Jerry McLeod

Notary
 CERTIFICATION

I hereby certify that I have duly served the defendants/responders with a copy of the foregoing

Motion and Affidavit for recusal of Judge by mailing a copy to the addresses listed below
This day of May, 2017
Mike Dewey
100 Screven Street
Quitman Georgia 31643
Howell L. Watkins II
1716 22nd Street
Vero Beach, Florida 32960