NO.

JEFFERSON CIRCUIT COURT

CIVIL DIVISION
JUDGE

SHARITA BRANSFORD PLAINTIFFS

6608 Miller Park Drive
Louisville, Ky. 40258

TAMERA COLLINS
Fern Creek High School

KELLY HINKLE
Fern Creek High School

JANE BRAGG
7732 Third Street Road
Louisville, Ky. 40214

DANA VINSON

-and-

TERRI DAWSON, as Mother and

Next Friend of K.C., a Minor

v. COMPLAINT and COMPLAINT FOR DECLARATION OF RIGHTS

JARRAD DURHAM, Principal DEFENDANTS

c/o Jeffersontown High School
9600 Old Six Mile Lane
Jeffersontown, Ky. 40299

MARY BETH SMITH, Assistant Principal

c/o Jeffersontown High School
9600 Old Six Mile Lane
Jeffersontown, Ky. 40299

REBECCA NICHOLAS, Principal

c/o Fern Creek High School
9115 Fern Creek Road
Louisville, Ky. 40291

NATE MEYER
Former Principal, Fern Creek High School
AMANDA HERZOG
Open Records Coordinator
3332 Newburg Road
Louisville, Ky. 40218

S.J., a minor

DR. MACIA CARMICHAEL-MURPHY, Principal

c/o Coleridge-Taylor Montessori Elementary
1115 West Chestnut Street
Louisville, Ky. 40208

MEG THOMAS, former Principal

c/o Coleridge-Taylor Montessori Elementary
1115 West Chestnut Street
Louisville, Ky. 40208

DALTON HOLT, Assistant Principal

c/o Coleridge-Taylor Montessori Elementary
1115 West Chestnut Street
Louisville, Ky. 40208

KIMBERLY MORALES, Principal

c/o Seneca High School
3510 Goldsmith Lane
Louisville, Ky. 40220

TRACEY FUSSNECKER, Counselor

c/o Seneca High School
3510 Goldsmith Lane
Louisville, Ky. 40220

MICHAEL GUY, Assistant Principal

c/o Seneca High School
3510 Goldsmith Lane
Louisville, Ky. 40220

S.G. a minor
c/o her Parents and/or Guardians
4398 Hannah Avenue
Louisville, Ky. 40213 DEFENDANTS

******************
Comes the Plaintiffs, by and through counsel, and for their cause of action; and,

Declaration of Rights, state as follows:

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 PARTIES

1. That the Plaintiff, SHARITA BRANSFORD, is a certified employee of the

Jefferson County Public Schools (hereinafter, “JCPS”), and employed as a Counselor at

Jeffersontown High School.

2. That, JARRAD DURHAM, Principal, at Jeffersontown High School is a

named party, solely, because he is the person in charge to ensure and maintain a safe

learning environment for the employees under his control; and was in possession of the

documentation of injuries to Sharita Bransford.

3. That Defendant, MARY BETH SMITH is named as a party Defendant for

possession of a videotape documenting the injuries to Plaintiff, Sharita Bransford.

4. That the Plaintiff, TAMERA COLLINS, is a classified employee of JCPS

and an attendance clerk at Fern Creek High School.

5. That, Defendant, REBECCA NICHOLAS, is the Principal at Fern Creek

High School is a named party, because she is the person in charge to ensure and maintain

a safe learning environment for the employees under his control.

6. That the Plaintiff, KELLY HINKLE, is a School Resource Officer (“SRO”)

and a JCPS classified employee at Fern Creek High School. She is a security officer at

Fern Creek High School, employed and paid by JCPS.

7. That Defendant Amanda Herzog is a named Defendant who has possession

of the video recording and has refused to allow Sharita Bransford to view the tape.

8. That Defendant S.J. is the student who violently assaulted Plaintiff Sharita

Bransford.

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 9. That Plaintiff, TERRI DAWSON’S daughter, K.C., a minor, is a student at

Seneca High School, a Junior.

10. That Defendant, S.G., is a student at Seneca High School who constantly

bullied, intimidates, harasses, stalks, and assaults K.C.

11. That Defendant, KIMBERLY MORALES, is the Principal at Seneca High

School who was advised of the torment that K.C. was going through and has failed to

protect said minor Plaintiff.

12. That Defendant, TRACEY FUSSNECKER, is a Counselor at Seneca High

School who was aware and advised of the torment and hell, K.C. was going through, and

did nothing to prevent said harm or protect K.C.

13. That Defendant, MICHAEL GUY, is an Assistant Principal at Seneca High

School that was aware and advised of the torment and Hell, K.C. was going through, and

did nothing to prevent said harm or protect K.C.

STATEMENT OF FACTS

A. Sharita Bransford

14. That on or about August 28, 2018, in the scope of her duties, Plaintiff

Sharita Bransford entered a classroom at Jeffersontown High School where she could hear

loud and argumentative voices. She called “code 3” to alert the school security that they

were needed immediately. As she entered the classroom, she encountered two (2) female

students arguing, with the teacher in the middle. One student on one side of the room

where she had entered, M.S., and the other student on the other side of the room, S.J.

Plaintiff Bransford tried to deescalate the situation with the student near her, M.S., whom

she had previously spoken to because this student, M.S. has been assigned to Jeffersontown

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from Minor Daniels, an alternative school, after a violent middle school history. Sharita

Bransford finally coaxed M.S. out of the room, and was walking with her toward her

counseling office. The other student, S.J. who should not have left the room, came out of

the room charging at Sharita, from behind, jumped on Sharita’s back and started beating

Sharita beating her about the head, neck and back. The other student, M.S. turned and

started fighting S.J. causing Sharita to fly across the hallway, striking her head on the hall

floor; leaving Sharita dazed on the floor! When she came to, three male students were

protecting her. Security, finally, showed up and were handcuffing both students. Both

students were suspended to the board for six (6) days. The student, M.S. was sent to an

alternative school. Plaintiff has reason to believe that her assailant. S.J. was returned to

Jeffersontown High School.

15. As a result of the assault, Sharita Bransford, suffered and/or continues to

suffer from: concussion, post-concussion protocol and then post traumatic stress disorder;

which include anxiety, depression, panic attacks and insomnia, injured left shoulder, lower

back injury, neck injury multiple bruises, headaches; and pain, horrific mental pain, and

suffering.

16. That Plaintiff was intentionally and violently assaulted by Defendant, S.J.;

that said conduct constitutes the tort of battery.

17. That security failed to come immediately to a code 3, which is the custom

and practice at Jeffersontown High School. That Security failed to respond in a timely

manner to this code 3 adding to the anarchy that exists at Jeffersontown High School!

18. That Sharita has incurred medical bills, horrific pain and suffering

prescription costs, counseling, loss of wages, and/or use of sick days for the injuries.

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 19. That all requests for the video of the assault have been refused, including a

request through open records, but we have been advised that the video tape will be

preserved in its original condition.

20. That there has been continuous violence at Jeffersontown High School that

has included the fight with the police that caused a student to be tased by the police.

21. That Sharita is disabled American Veteran of the United States Air Force,

loves her job, but requests that she be entitled to work in a safe environment.

22. That the principal, Jarrad Durham, fails to maintain a safe working

environment and a safe learning environment at Jeffersontown High School.

23. That the continued failure to maintain a safe working environment caused

the injuries to Plaintiff. Defendant, Jarrad Durham was grossly negligent, negligent per se,

and his conduct was negligent, careless and reckless.

B. Tamera Collins

24. That Plaintiff Tamera Collins is an attendance clerk at Fern Creek High

Schools and had worked for JCPS for approximately twelve (12) years.

25. That on or about September 30, 2014, there was a shooting over the shooter

being given a counterfeit one hundred dollar ($100.00) bill by the student buyer of a stolen

iPad. Other staff members were aware of the counterfeit $100 bills proffered by this same

student at registration, but Plaintiff Tamera Collins “did not need to know,” according to

her supervisors, and was unaware. When the shooter reported to Tamera because he was

tardy, he could have had a loaded gun on his person. Another teacher interceded as said

shooter was shooting, and instead of the intended target, a promising student athlete was

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shot. The buyer, another student at Fern Creek, was found dead in the Fern Creek Park

near the High School, thereafter.

26. That since that triggering event, Plaintiff, Tamera Collins, has suffered

tension, and post-traumatic stress disorder (PTSD). Because Tamera is also in charge of

submitting reports when weapons are confiscated, the PTSD is activated whenever she

must send in a report about another student suspension with weapons involved.

27. That Fern Creek High School is not secure and wide-open, over capacity,

and on numerous occasions, firearms are confiscated, with the student possessing the gun

being sent back to class, rather than properly reported and/or other action taken.

28. That whenever Tamera has to send in another weapons report, she usually

breaks out in hives and feels the stress. Whenever she is alerted that there is another weapon

was confiscated, but the incident was swept under the proverbial rug, her symptoms are

worse.

29. That on at least one (1) occasion, an intruder entered Fern Creek High

School during normal school hours. This event was also not reported.

30. That a safety plan was presented to the “board” for $5,000.00, which was

denied.

31. That the Defendants, Principal Rebecca Nicolas, Principal Meyer, and other

past principals have failed to maintain a safe environment for Plaintiff, herein and a safe

learning environment for the students.

32. Tammy Collins fears that she will be shot and killed on a daily basis, thus

her PTSD continues on a frequent, if not, daily basis.

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 33. That the Defendant, Rebecca Nicolas, has violated the Gun-Free School Act

of 1999, and past principals before her. This has been an ongoing problem. The shooting

at Fern Creek High School was foreseeable. And now students with guns, who are

reported, are sent to alternative schools for six (6) weeks; and then returned to all other

high schools in the District without notice that they have previously brought a gun to

school.

34. That the damages of the Plaintiffs, herein, exceed the jurisdictional limit of

the Jefferson Circuit Court. The relief sought grants jurisdiction to the Jefferson Circuit

Court. The Declaration of Rights requested herein states a justiciable issue.

C. Kelly Hinkle

35. That Plaintiff, Kelly Hinkle, is an In-School Security Monitor since

November 3, 1997; substantially all at Fern Creek High School.

36. That Kelly has suffered from and been diagnosed with PTSD, depression

and cardiac related stress which causes her to black out at various times. Her lupus is also

at an extremely high dangerous figures.

37. That the medical problems set out above are related to the unsafe working

environment at Fern Creek High School.

38. That Kelly has panic seizures, blood pressure elevates to dangerous levels,

sweats, and even blacks out from the unsafe working environment.

39. That Kelly heads the entire security team as to searches and investigations

for weapons and outside intruders. Kelly is the first responder to constant fights between

students (gang members) and students and faculty. These also are seldom reported. Kelly

investigates social media and any other outside threats such as bomb threats or terrorist

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threats. There is no longer any discipline for students violating school rules in connection

with being in gangs; students possessing marijuana are not sent home.

40. That Kelly has now been placed in the center of the first floor hallway near

the main entrance. Tamera has been placed in a heated closet surrounded by windows.

Both are now totally unprotected and their safety is at a greater risk than it was before.

They are sitting ducks. Both Kelly and Tamera believe they have been retaliated against

because of their verbal complaints.

41. That students who are suspended and/or referred to alternative school are

then returned to Fern Creek. Some of these students were referred for having weapons,

(including guns, tasers, knives, etc.) and are returned to Fern Creek. Many students

transferred to Fern Creek have had weapon violations at other schools. If a student has had

previous weapon violation, then Fern Creek is their designated school of choice. The

student who shot the other student on the premises on September 30, 2014 was an example

of a student returned after a weapons violation.

42. By the Grace of God, no one yet has been killed at Fern Creek High School,

but one student the rightful recipient of the Andre Banks’ shooting; Cameron White was

found with a bullet in his head in the adjacent parking lot.

43. All security has been advised that the mass shooting will be triggered by the

fire alarm going off and student and staff will be shot as they exit the building. When the

fire alarm recently went off, it was totally mishandled; and has been mishandled numerous

times thereafter. Kelly, was the only JCPS employee sent to the Regional Chiefs of Police

Institute (RCPI) which was taught by the Federal Bureau of Investigation (FBI); but when

she made recommendations, she was totally ignored.

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 44. All principals are named because of their position and statutory law, in their

individual capacities.

45. That Plaintiffs will not be protected if they put their hands on a student even

in self defense. No one has their back even if they are being killed! And the students know

this. Plaintiffs can grab a student’s shirt, per SCM, so now the students (especially the

gangs) take their shirts off first.

46. That JCPS had made admissions against interest that they do not have to

provide and/or maintain a safe educational environment.

D. Jane Bragg

47. That Plaintiff, Jane Bragg, was a MSD teacher with JCPS for the last four

years at Coleridge-Taylor Elementary School. Jane has been a teacher for a total of fourteen

(14) years.

48. That Defendant, Meg Thomas, was a former principal at Coleridge-Taylor

Montessori School. She was terminated at the end of the 2017-2018 school year. She was

replaced by Dr. Marcia Carmichael-Murphy.

49. Defendant, Dalton Holt, has been Assistant Principal at all times herein.

50. That in or about May of 2018, Plaintiff Bragg was accused of inappropriate

behavior toward a child in her room. The alleged incident was discussed on or about May

11, 2018 in front of Defendant Thomas, and Defendant Holt. Because of the previous

behavior problems of this child, Principal Thomas basically dismissed them; also because

of Bragg’s clean record. Bragg was ordered to obtain safe crisis management training.

51. That Bragg requested the safe management training from Defendant Holt.

Defendant Holt intentionally denied placing her in the training class; knowing full well she

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was supposed to attend. A student repeatedly kicked, bit and spit Bragg. Holt tore up

Bragg’s referral to safe management crisis and advised her she would get no help and don’t

refer any student.

52. That at the start of the next school year, the investigation of abuse came

back again. All allegations were determined to be unfounded and Bragg was reinstated to

her teaching duties.

53. That newly appointed Carmichael is now principal, and starts inquiring

what happened. As to the alleged incident, Bragg was already cleared of all allegations.

But Bragg is delayed another week before returning to class. Bragg starts in the classroom

on October 12, 2018.

54. Defendant, Carmichael, then advised Bragg that she no longer had control

over her assistants. Now Principal Carmichael has created a hostile work environment full

of stress and tension. In or about mid October 2018, Defendants, Carmichael and Holt

being able to listen, “chewed out” Bragg in front of students walking by and in class

because the discussion was in the hallway, Plaintiff Bragg was being bullied and verbally

harassed by Defendant, Carmichael.

55. On or about November 14, 2018; Plaintiff Bragg overheard Carmichael tell

a custodian to get rid of the couches Bragg had in her room the entire time; that afternoon,

Bragg’s personal furniture was thrown away.

56. That on or about November 15, 2018, due to icy weather, and electricity

being out, she was unable to come in timely. Although Bragg notified Carmichael, said

Defendant continued the harassment by advising Bragg she would be docked for the day.

This verbal attack continued even with Bragg being five minutes away.

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 57. That at the end of the same day, Holt confronted Bragg with the students

in the room; and demanded testing material for the alternate assessment, and seating charts

for the students; and other material. Defendant, Carmichael came in and told Holt like she

wasn’t there and advised Holt there were new allegations. Bragg was advised that she

could not defend herself. There would be no support, presumably even if when was being

killed.

58. That Bragg never returned to the school. Said Plaintiff took sick days, and

leave under the Family Emergency Medical Leave Act (FEMLA) was approved. The

physical and verbal treatment by Defendants Holt and Carmichael triggered PTSD and

after thanksgiving she was forced to resign.

59. That based upon the hostile work environment, no aides, no help from

Defendants, Holt and Carmichael, Bragg’s PTSD was triggered into a full blown

occurrence, and she suffered damages, mental anguish; and, pain, and suffering.

60. That all Plaintiffs request that they be protected from retaliation and upon

facts so presented; be granted injunctive relief.

E. Dana Vinson

61. That Plaintiff, Dana Vinson, was a MSD teacher with JCPS for the last nine

(9) years at Coleridge-Taylor Elementary School. Dana has been a teacher for a total of

nineteen (19) years.

62. That Defendant, Thomas, was a former principal at Coleridge-Taylor. She

was terminated at the end of the 2017-2018 school year. She was replaced by Dr. Marcia

Carmichael-Murphy.

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 63. Defendant, Dalton Holt, has been Assistant Principal at all times herein at

Coleridge-Taylor.

64. That on or about October 17, 2018, Dana was physically assaulted in front

of Principal Carmichael. Dana then hugged the child that just assaulted her, until she

calmed down. Ice was brought for Dana’s face. Dana took absences for her swollen face

until October 19, 2019.

65. Defendant Holt was present finally after C.B. had run all over the school.

Defendant Holt stated Dana was responsible for this child and needed a plan, even though

there was a plan on file. Dana had signed up for safe crisis management last May, but

Defendant Holt picked out ten (10) to go and intentionally excluded Dana Vinson.

66. When Dana returned on October 19, 2018, C.B. was already out of control

on the bus. Dana helped remove C.B. from the bus, harness and all. C.B. then decided she

would run around the school with Dana in tow; and C.B. was also trying to escape through

the doors. That C.B. bolted into an empty classroom and C.B. began assaulting Dana

again trying to escape from the classroom. Defendant Holt did nothing and by doing

nothing knew or should have known that Dana was being assaulted again, when he and

others entered the classroom.

67. Defendant Holt was present finally after C.B. had run all over the school.

Defendant Holt stated Dana was responsible for this child and needed a plan, even though

a plan on file. A crisis management plan was not on file. Dana had signed up for safe crisis

management last May, but Defendant Holt picked out ten to go and intentionally excluded

Dana Vinson. Therefore intentionally denying her the ability to write a plan per crisis

management instruction.

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 68. That as a result of the assault, Dana suffered bruises, severe headaches,

severe back trauma, and incurred medical bills, prescription medicines; and triggered

PTSD which was dormant; and mental anguish. Said assaults have triggered the PTSD

which has caused temporary total disability to this day.

69. That Dana was without two (2) assistants for the last two (2) years,

especially, violating her contract and because of that there was less control in her

classroom. Because Dana voiced her complaints about the foregoing, she was retaliated

against by Defendants Holt and Carmichael.

70. Leave pursuant to the FEMLA was approved for Dana until December 1,

2018; and then Dana’s therapist and Cheryl Denzik, her nurse practitioner, recommended

retirement from JCPS due to these traumatic events.

71. Dana Vinson began her voluntary retirement on December 1, 2018.

72. That the proximate cause of her stress, tension, anxiety, all diagnosed as

PTSD; was the unsafe working conditions at Coleridge-Taylor; which caused her to take

early retirement.

F. K.C., a Minor

73. That K.C. is a Junior at Seneca High School. That on or about November 7,

2018, K.C. had to defend herself against Defendant S.G. who hit K.C. first. K.C. was

wrongfully suspended for defending herself against S.G.

74. K.C. has reason to believe that S.G. had a history of other assaultive

behavior, and Defendants at Seneca High School knew or should have known of her

dangerous propensities. That K.C. has reason to believe that S.G. is a member of a gang.

75. That since that time, K.C. has been the victim of:

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 a. Verbal bullying and harassment, battery and stalking;

b. the gang has intentionally sat close to K.C. when possible in order to

continue stalking, bullying and harassing K.C.

c. that another presumed gang member was waiting outside K.C.’s

classroom to continue the stalking, bullying and harassment;

d. That various friends and/or gang members of S.G. have harassed,

bullied, and stalked K.C. on the bus,

e. At various time, gang members have brushed by K.C. (battery), and

tried to stare her down.

f. That on Friday, February 8, 2019, K.C. with assurances from Counsel

for JCPS that she would be protected K.C. returned to school and on the

school bus away from Seneca, the gang now using K’s first name

shouted taunts and yelled; verbal harassing and verbally shouting

obscenities at K.C. The bus driver was aware of the taunts but does

nothing to stop it.

76. That on the same day, prior to the bus incident, Defendant, Fussnecker, told

K.C. to stop by the office after seeing her in the lunchroom. Defendant Fussnecker failed

to move one of the gang who was sitting in close proximity to K.C. solely in order to

intimidate K.C. That K.C. asks that the video for February 8th, 2019 on the bus ride home

be preserved by Defendants, or Defendants at Seneca High School be ordered to produce

the video in Court and same be preserved by this Honorable Court under seal during the

pendency of this action.

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 77. That Defendant Fussnecker retaliated against K.C. a known plaintiff and

witness in a civil proceeding, asking K.C. why K.C. did not come to her about the problems.

Defendant, Fussnecker, admitted that she was aware of letters (documents) sent in K.C’s

behalf and Fussnecker was not happy about it. She still did nothing to protect K.C. the rest

of the day, or on the bus.

78. That the proximate cause of K.C.’s injuries are by the bullying, harassment

and stalking by S.G. and her gang/friends and the three Defendants from Seneca: Morales,

Fussnecker, and Guy failing to stop it pursuant to the rules and regulations and the JCPD

student code of conduct; and KRS Chapter 527, et seq.

79. That all Plaintiffs request that they be protected from retaliation and upon

facts so presented; be granted injunctive relief.

80. That all of the damages herein exceed the jurisdictional limit of the

Jefferson Circuit Court; and, that this Honorable Court has jurisdiction of the injunctive

relief sought herein.

WHEREFORE, Plaintiffs, SHARITA BRANSFORD, TAMERA COLLINS,

KELLY HINKLE, JANE BRAGG, DANA VINSON, and K.C. by and through her Mother

and Next Friend, TERRI DAWSON, demand judgment as follows:

A. A Declaration of Rights that all staff, classified and certified, and students

are entitled to a safe working and learning environment in the Jefferson County Public

Schools.

B. Damages against Defendant, Jarrad Durham, for his negligence, gross

negligence, careless and reckless which was the proximate cause of damages to Plaintiff,

Sharita Bransford.

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 C. Damages against S.J. for the battery caused to Plaintiff Sharita Bransford.

D. Damages against the Defendant, Rebecca Nicolas, for the injuries suffered

and continue to be suffered by Plaintiff due to principal’s failure to maintain a safe

environment for Plaintiff, Tammy Collins and Plaintiff, Kelly Hinkle.

E. Damages against Defendants Holt and Carmichael for their negligence,

gross negligence, careless and reckless behavior which was the proximate cause of all

injuries and a early retirement, of Plaintiffs Bragg and Vinson.

F. Plaintiffs’ costs expended herein, and attorneys’ fees as allowed by law.

G. Trial by jury on those issues so triable

H. That Plaintiffs reserve the right to move the Court for immediate injunctive

relief if plaintiffs are retaliated against.

I. An order directing the Defendant, Morales, possessor of the video on the

bus from Seneca on February 8, 2019 preserve the video and/or be ordered to produce said

video at Court; and this Honorable Court place said video under seal, during the pendency

of this action.

J. Actual, compensatory, and punitive damages caused by S.G.’s friends

under her direction and control bullying, harassing, stalking and assaultive behavior as to

K.C.

K. Actual, Compensatory, and punitive caused by Defendants Fussnecker,

Morales and Guy for failing to protect K.C. and damages against Defendant Fussmecker

for intimidation of K.C.

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 L. That if K.C. remains at Seneca, a temporary and permanent injunction

keeping S.G. and her friends, associates and/or gang members five hundred feet away from

K.C.

M. Any and all other relief to which the Plaintiffs’ may appear entitled

Respectfully submitted,

TEDDY B. GORDON
ANDREW E. MIZE
PETER JANNACE
807 West Market Street
Louisville, Kentucky 40202
(502) 585-3534 (telephone)
(502) 585-3539 (facsimile)
Counsel for Plaintiffs,

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 Plaintiffs, TAMERA COLLINS and KELLY HINKLE states that they have read

the allegations of the foregoing Complaint, and the statements contained herein are true

and correct as they verily believes.

TAMERA COLLINS

KELLY HINKLE

SUBSCRIBED AND SWORN to before me by TAMERA COLLINS, and KELLY

HINKLE, Plaintiffs, on this day of 2019.

My commission expires:

NOTARY PUBLIC, STATE AT LARGE,

KENTUCKY

Plaintiff, JANE BRAGG states that she has read the allegations of the foregoing

Complaint, and the statements contained herein are true and correct as she verily believes.

JANE BRAGG

SUBSCRIBED AND SWORN to before me by JANE BRAGG, Plaintiff, on this

on this day of 2019.

My commission expires: _________________________.

NOTARY PUBLIC, STATE AT LARGE,

KENTUCKY

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 Plaintiff, DANA VINSON states that she has read the allegations of the foregoing

Complaint, and the statements contained herein are true and correct as she verily believes.

DANA VINSON

SUBSCRIBED AND SWORN to before me by DANA VINSON, Plaintiff, on this

on this day of 2019.

My commission expires: _________________________.

NOTARY PUBLIC, STATE AT LARGE,

KENTUCKY

Plaintiff, TERRI DAWSON, as Mother and Next Friend of K.C., states that she has

read the allegations of the foregoing Complaint, and the statements contained herein are

true and correct as she verily believes.

TERRI DAWSON

SUBSCRIBED AND SWORN to before me by TERRI DAWSON, Plaintiff, on

this on this day of 2019.

My commission expires: _________________________.

NOTARY PUBLIC, STATE AT LARGE,

KENTUCKY

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