Attorneys for Tonya Craft have filed a second amended complaint in her $25 million Federal Court lawsuit.

Defense attorneys had maintained that charges brought by the former Chickamauga kindergarten teacher were still not specific enough so Judge Harold Murphy of the Northern District of Georgia in Rome directed that a new, more specific complaint be filed.

Ms. Craft was found innocent of all 23 charges of child molestation brought against her.

Ms. Craft said she is also seeking a re-write of the laws as they pertain to an individual accused of these crimes and to have a new level of training required for those who interview the children and families of suspected perpetrators.

The new complaint was again filed by attorney Scott R. King of the Atlanta firm of Jacobs, King and Wallack on Thursday.

Earlier the judge had dismissed numerous claims by the defendants to have the case dismissed outright.

The case is filed against Sandra Lamb, Sheri Wilson, Dewayne Wilson, Joal Henke, Sara Henke, and Kelli McDonald. Also being sued are Catoosa County investigator Tim Deal, Sheriff Phil Summers, the Catoosa County Sheriff’s Department, as well as Suzie Thorne, Stacy Long, Laurie Evans and the Greenhouse Counseling Center, as well as the Lookout Mountain Judicial District Children’s Advocacy Center.

Ms. Craft is also litigating the return of her children in Hamilton County Circuit Court. Until she was charged in Catoosa County, she had full custody of her children. Assisting in the case is Clancy Covert, Chattanooga attorney who was part of her trial team in the Ringgold court case, as well as Cary King of Atlanta.

Below is the entire amended complaint filed by Ms. Craft’s legal team:

IN THE UNITED STATES DISTRICT COURT FOR THE
NORTHERN DISTRICT OF GEORGIA
ROME DIVISION

TONYA RENEE CRAFT, )
)
Plaintiff, )
vs. )
)
SANDRA LAMB, in her individual ) CIVIL ACTION
capacity; SHERI WILSON, in her ) FILE NO. 4:10-CV-0068-HLM
individual capacity; DEWAYNE WILSON, )
in his individual capacity; JOAL HENKE, )
in his individual capacity; SARAH HENKE, )
in her individual capacity; KELLI )
MCDONALD, in her individual capacity )
TIM DEAL, in his individual capacity; )
CATOOSA COUNTY, GEORGIA, a gov- )
ernmental entity; THE CATOOSA )
COUNTY SHERIFF’S DEPARTMENT, a )
municipal entity; PHIL SUMMERS, in his )
individual and professional capacity; SUZIE )
THORNE, in her individual and pro- )
fessional capacity STACY LONG, in her )
individual and professional capacity; )
LAURIE EVANS, in her individual and )
professional capacity; CHILDREN’S )
ADVOCACY CENTER OF THE LOOK- )
OUT MOUNTAIN JUDICIAL CIRCUIT, )
INC. , a state contracting agency; THE )
GREENHOUSE CHILDREN’S )
ADVOCACY CENTER, a state )
contracting agency )
)
Defendants. )
__________________________________________________________________

SECOND AMENDED COMPLAINT
FOR DAMAGES AND INJUNCTIVE RELIEF

COMES NOW, TONYA RENEE CRAFT, by and through the undersigned counsel, and files this her Second Amended Complaint against the above-named Defendants, jointly and severally, as follows:
I. JURISDICTION

1. This action is brought pursuant to 42 USC §§ 1983, 1988 and the Fourth Amendment and Fourteenth Amendments of the Constitution of the United States of America. Jurisdiction is based on 28 USC §§ 1331 and 1343(1), (3), (4) and the aforementioned statutory and Constitutional provisions.
2. Suit is also brought against the Defendants pursuant to 28 USC § 1367, et seq., as supplemental claims that are part of the same case and controversy.
II. PARTIES

3. Plaintiff Tonya Renee Craft is a resident of Tennessee. Her current address is 2191 Durban Point Drive, Soddy Daisy, Tennessee 37379.
4. Defendant Sandra Lamb at all times relevant to this cause of action has been a resident of the State of Georgia. Her address is 249 Classic Trail, Ringgold, Georgia 30736. She is being sued in her individual capacity.
5. Defendant Sheri Wilson at all times relevant to this cause of action has been a resident of the State of Georgia. Her address is 311 Cloudcrest Drive, Rossville, Georgia 30741. She is being sued in her individual capacity.
6. Defendant DeWayne Wilson at all times relevant to this cause of action has been a resident of the State of Georgia. His address is 311 Cloudcrest Drive, Rossville, Georgia 30741. He is being sued in his individual capacity.
7. Defendant Joal Henke at all times relevant to this cause of action has been a resident of the State of Tennessee. His address is 9733 Waycross Circle, Ooltewah, Tennessee 37363. He is being sued in his individual capacity.
8. Defendant Sarah Henke at all times relevant to this cause of action has been a resident of the State of Tennessee. Her address is 9733 Waycross Circle, Ooltewah, Tennessee 37363. She is being sued in her individual capacity.
9. Defendant Kelli McDonald at all times relevant to this cause of action has been a resident of the State of Georgia. Her address is 1275 Back Valley Road Chickamauga, GA 30707. She is being sued in her individual capacity.
10. Defendant Tim Deal at all times relevant to this cause of action has been an employee of Defendant Catoosa County Sheriff’s Department, a municipal agency. Defendant Deal may be served with a copy of the Summons and Complaint at 312 LaFayette Street, Ringgold, Georgia, 30736.
11. Defendant Catoosa County at all times relevant to this cause of action has been a municipal and governmental agency of the State of Georgia. Defendant may be served through the Chairman of the County Board of Commissioners, Keith Greene at 800 Lafayette Street, Ringgold, Georgia 30736.
12. Defendant Catoosa County Sheriff’s Department (hereafter CCSD”) at all times has been a division of Catoosa County Georgia, a municipal and governmental agency of the State of Georgia. Defendant CCSD may be served through the Chairman of the County Board of Commissioners, Keith Greene at 800 Lafayette Street, Ringgold, Georgia 30736.
13. Defendant Phil Summers at all times relevant to this cause of action has been an employee of Defendant CCSD, a municipal agency. His address for service of this action is 312 LaFayette Street, Ringgold, Georgia, 30736.
14. Defendant Suzie Thorne at all times relevant to this cause of action was an employee of Defendant The GreenHouse Children’s Advocacy Center (hereafter “GREENHOUSE”) and/or such other neighboring Children’s Advocacy Center of Georgia, an agency contracting with law enforcement authorities in Catoosa County, Georgia. Defendant Thorne may be served with a copy of the Summons and Complaint at the Whitfield County Sherriff’s Department, 805 Professional Boulevard, Dalton, Georgia 30720.
15. Defendant Stacy Long at all times relevant to this cause of action was an employee of Defendant Children’s Advocacy Center Of The Lookout Mountain Judicial Circuit, Inc. (hereafter “CAC-LMJC”), 510A Thomas Road, Oglethorpe, Georgia 30742, and/or such other neighboring Children’s Advocacy Center of Georgia, an agency contracting with law enforcement authorities in Catoosa County, Georgia. Defendant Long may be served with a copy of the Summons and Complaint at 510A Thomas Road, Oglethorpe, Georgia 30742.
16. Defendant Laurie Evans for all times relevant to this cause of action was an employee of Defendant CAC-LMJC and/or such other neighboring Children’s Advocacy Center of Georgia, an agency contracting with law enforcement authorities in Catoosa County, Georgia. Defendant Evans may be served with a copy of the Summons and Complaint at 510A Thomas Road, Oglethorpe, Georgia 30742.
17. Defendant CAC-LMJC was at all times relevant to this cause of action a state contracting agency doing business in Catoosa County, Georgia. CAC-LMJC may be served with a copy of the Summons and Complaint upon their registered agent, Mary Jane P. Melton, 103 East Patton Street, Lafayette, Georgia 30728.
18. Defendant GREENHOUSE was at all times relevant to this cause of action a state contracting agency doing business in Whitfield County, Georgia. In connection with the present action, Defendant GREENHOUSE performed certain functions relating to an action being investigated by Catoosa County, Georgia The GREENHOUSE may be served with a copy of the Summons and Complaint at 600 East Morris Street, Dalton, GA 30721-3405.
III. VENUE
19. Pursuant to 28 USC § 1391, et. seq., venue is proper in the Rome Division of the Northern District of Georgia as a majority of the Defendants reside therein and the transactions and occurrences complained of, occurred in the Northern District of Georgia.
IV. FACTUAL ALLEGATIONS
20. Plaintiff has two minor children: A.H., age eight, and K.H., age eleven.
21. On May 19, 2008, Defendant Sandra Lamb reported in a telephone call to Georgia DFCS worker Rhonda Lawson that her minor daughter, R.L. had been involved in child-on-child sexual touching with Plaintiff Tonya Renee Craft’s daughter A.H., a child two years younger than R.L.
22. Despite repeated and suggestive questioning in which Plaintiff was continually mentioned by Defendant Sandra Lamb by name, according to Defendant Sandra Lamb’s report to the DFCS worker, Plaintiff Tonya Renee Craft was not implicated.
23. Nonetheless, Sandra Lamb attempted to manipulate R.L.’s statements by questioning her on numerous occasions about alleged illegal conduct by the Plaintiff when the child had already denied such conduct.
24. On May 23, 2008, during a last-day-of-school party at her home, Defendant Sheri Wilson noticed that, K.W., a minor child, used sidewalk chalk to write “sex and kissing xoxoxo” in six inch letters.
25. (a.) Defendant Sheri Wilson called K.W.’s parents who came to the home and had a detailed discussion with Sheri Wilson and Defendant DeWayne Wilson.
(b.) In that discussion, no child raised any allegations against Plaintiff, but Mr. and Mrs. Wilson suggested that she was the perpetrator behind the childrens’ allegations.
26. During this discussion, Defendants DeWayne and Sheri Wilson made numerous false and derogatory comments about Plaintiff to K.W.’s parents, which included, but are not limited to the following:
(a.) Sheri and DeWayne Wilson mentioned their anger towards Plaintiff as the result of Plaintiff wanting to “hold back” their child from promotion to first grade since Plaintiff was the Wilson child’s teacher in the 2007-2008 school year.
(b.) During a parent-teacher conference in the Spring of 2008 with the Plaintiff, Defendants, DeWayne and Sheri Wilson became so upset with Plaintiff that they either or individually threatened her by saying “someone will pay for this”, which was directed at Plaintiff.
(c.) Defendants DeWayne and Sheri Wilson made further comments to K.W.’s parents that were derogatory in nature concerning Plaintiff’s actions at the Walker County Gala wherein Plaintiff was a guest of Defendants Sheri and Dewayne Wilson.
(d.) During this conversation with K.W.’s parents, the Defendants, Sheri and Dewayne Wilson made further repeated derogatory comments about the Plaintiff, none of which had anything to do with the allegations of the children that existed at that time, including without limitation, statements indicating that Plaintiff drank excessively and was inappropriately promiscuous.
(e.) Defendants Sheri and DeWayne Wilson further used several expletives to describe Plaintiff.
27. Following this discussion, the parents of K.W. left the Wilson residence and, thereafter, questioned K.W. about the incident.
28. (a.) For the next 3 days, Defendant Sandra Lamb began repeatedly and suggestively questioning her daughter, R.L., including questions that directly implicated Plaintiff.
(b.) Defendant, Sandra Lamb, has no training or experience in questioning children concerning alleged sexual abuse.
29. After hours and/or days of such inappropriate questioning, R.L. allegedly made a statement regarding inappropriate touching.
30. (a.) Following the discussion with K.W.’s parents, Defendants Sheri Wilson and DeWayne Wilson had discussions with Defendant Sandra Lamb and Defendant Joal Henke about these allegations. During the period from May 30, 2008 through April 2009, Defendants Joal Henke, Sandra Lamb, and Sheri Wilson had more than 300 phone calls amongst each other, as was shown by the telephone records produced at the criminal trial.
(b.) In the midst of such discussions, Defendant DeWayne Wilson, the former coroner of neighboring Walker County, Georgia, initiated the CCSD’s involvement in this case by contacting his close personal friend, Detective Steven Keith, an employee of Defendant CCSD.
(c.) During this conversation, DeWayne Wilson reported that Plaintiff had allegedly engaged in inappropriate touching of minor children.
(d.) In fact, DeWayne Wilson had no actual knowledge of such alleged conduct and had no good faith basis to believe that such conduct had occurred.
31 (a.) Thereafter, Defendant Sandra Lamb contacted Detective Steven Keith of the CCSD, and arranged a first interview of R.L. with Defendant CAC-LMJC.
(b.) At the time Detective Keith arranged such interview, he had no evidence to indicate that Plaintiff had engaged in any illegal conduct.
32. On May 27, 2008, R.L., Defendant Sandra Lamb’s minor daughter, was interviewed by Defendant Stacy Long at Defendant CAC-LMJC.
33. Under repeated and suggestive questioning by Defendant Long during this interview, the child told Defendant Stacy Long about child on child touching with Mrs. Craft’s six-year-old daughter A. H. but made no allegations against Plaintiff which would represent any of the crimes Plaintiff was charged with.
34. R.L. further stated that Plaintiff kissed her on the head, neck and shoulder and would pat her.
35. When asked about the, child on child touching, R.L. said she knew about this because “My momma told me.”
36. On May 27, 2008, R.L. was interviewed a second time by Defendant Stacy Long at Defendant CAC-LMJC.
37. What transpired in the interval between the two interviews of R.L. is undocumented; however, it is un-rebutted that R.L. spent the interval between the two interviews primarily with her mother.
38. Under repeated and suggestive questioning, the child told Defendant Stacy Long she allegedly remembered (paraphrasing) that Plaintiff allegedly made her “touch her back” (signaling her neck and chest) and (paraphrasing) “She told me I had to do it or I had to go home.”
39. Throughout these two interviews, Defendant Long repeatedly attempted to modify R.L.’s answers to get R.L. to implicate Plaintiff in criminal activity.
40. During the numerous phone calls described in Paragraph 30 above between Defendants Sheri Wilson, Sandra Lamb, Joal Henke, these Defendants conspired to falsely claim that E.M. was also an alleged victim of inappropriate touching by Plaintiff.
41. In conjunction with these efforts, these Defendants notified Defendant CCSO and/or Defendant Tim Deal, about an incident in 2006 involving child on child contact between E.M. and A.H.
42. Thereafter, on May 29, 2008, E.M. was interviewed by Defendant Tim Deal at Defendant CAC-LMJC.
43. Prior to this interview, Defendant Kelli McDonald spoke with Defendants Sandra Lamb and/or Sheri Wilson concerning their plan to raise these false allegations against Plaintiff.
44. As a result, Defendant Kelli McDonald, asked E.M. directly certain suggestive questions on the way to E.M.’s interview on May 29, 2008, leading the child to falsely indicate that Plaintiff had touched her inappropriately.
45. Prior to Defendant Kelli McDonald questioning her daughter about these allegations, E.M. had made no allegations against Plaintiff of any kind.
46. Specifically, Defendant Kelli McDonald asked E.M. directly if Plaintiff had “touched her on her privates” or otherwise hurt her, an issue which had never been raised by the child prior to this questioning.
47. Further, Defendant Kelli McDonald asked E.M. directly whether Plaintiff had threatened to kill her, or otherwise hurt her, issues which had never been raised by the child prior to this questioning.
48. On May 29, 2008, in her interview with Defendant Tim Deal, E.M. told Defendant Deal “My momma told me which is which and where they touched me.”
49. In this interview, under repeated and suggestive questioning by Defendant Deal, E.M. told Defendant Deal about child on child touching with Plaintiff’s six-year-old daughter A.H. and that Plaintiff allegedly touched her on top of her clothes.
50. (a.) Throughout this interview, Defendant Deal repeatedly attempted to modify E.M.’s answers to get E.M. to implicate Plaintiff in criminal activity.
(b.) In several instances, Defendant Deal did in fact modify R.L.’s answers to certain questions.
51. On May 30, 2008, Defendant Catoosa County, by and through Defendant CCSD, Defendant Tim Deal and the Catoosa County Department of Family and Children (“DFACS”) forced Plaintiff to agree to having her minor children removed from her residence and placed with their father, Defendant Joal Henke.
52. Specifically, Defendants Catoosa County and CCSD sent armed police officers (including Defendant Deal) to Plaintiff’s property to wait while a representative of DFACS informed Plaintiff that she could either agree to the removal or the children would be taken into custody of the County authorities.
53. Such actions were taken at the direction and/or with the consent of Defendant Phil Summers.
54. At the time Defendants Catoosa County and CCSD took such actions, they did not have any evidence that Plaintiff had committed any crimes.
55. Thereafter, Defendant Joal Henke received numerous and repeated telephone calls from Defendants Sheri Wilson and Sandra Lamb in which they accused Plaintiff on inappropriately touching minor children.
56. After receiving these calls Defendant, Joal Henke repeatedly and suggestively questioned A.H., Plaintiff’s then six-year-old daughter with questions formulated or based upon the telephone calls he had with Defendants Sheri Wilson and Sandra Lamb.
57. During such questioning, Defendant Joal Henke suggested the idea that Plaintiff had inappropriately touched her, even though A.H. continued to assert that the only time Plaintiff had touched her was when applying medicine to her and when bathing her.
58. Despite these statements from A.H., Defendant Joal Henke continued to question A.H. as to whether Plaintiff had touched her inappropriately.
59. Defendant Joal Henke’s statements to A.H. included, without limitation, statements indicating that Plaintiff had “lied to the police,” that Plaintiff had “lied for a lot of people,” that Plaintiff had engaged in wrongdoing and that Plaintiff was going to be sent to jail.
60. Defendant Sarah Henke also informed A.H. that Plaintiff, her mother, had lied and had engaged in other wrongful conduct.
61. Such actions by Defendants Sarah Henke and Joal Henke were intentionally designed to alienate A.H.’s affections for Plaintiff and to try to manipulate A.H. to make false allegations regarding Plaintiff.
62. Prior to any of these allegations arising, Defendant Sarah Henke had showered with A.H. on multiple occasions and had shaved her genital area in front of A.H. while A.H. was in the shower with her.
63. Such actions were psychologically devastating to A.H.
64. On June 3, 2008, following her May 30, 2008 removal from her mother’s care, custody and control, A.H. was interviewed by Defendant Suzie Thorne at Defendant GREENHOUSE.
65. Defendant GREENHOUSE and Defendant Suzie Thorne were utilized for this interview at the request of Defendant CCSD, Defendant Tim Deal, the Catoosa County District Attorney’s Office and/or Defendant Catoosa County.
66. During this interview, under Defendant Suzie Thorne’s repeated and suggestive questioning, A.H. told Defendant Thorne that her mother had put medicine on her bottom because she had belly aches and diarrhea, which her father, Defendant Joal Henke, opined was attributable to allergies.
67. A.H. further stated that Plaintiff had touched her vaginal area while applying this medicine.
68. Other than applying medicine to A.H., A.H. made no other disclosures about Plaintiff.
69. During this June 3, 2008 interview, AH also told Defendant Thorne that her father, Defendant Joal Henke, told her that her mother had lied to the police and lied about a lot of people, although A.H. could not remember what her father claimed Plaintiff had lied about.
70. Throughout this interview, Defendant Thorne repeatedly attempted to modify A.H.’s answers to get A.H. to change her story.
71. On June 4, 2008, R.L. was interviewed a third time, this time by Defendant Suzie Thorne at Defendant GREENHOUSE.
72. (a.) What transpired in the interval between interviews two and three for R.L. is undocumented; however, it is un-rebutted that R.L. spent the interval between the two interviews primarily with her mother, Defendant, Sandra Lamb.
(b.) During this time period, the telephone calls and discussions between Defendants Sheri Wilson, Sandra Lamb, Kelli McDonald and Joal Henke continued.
73. Under repeated and suggestive questioning, R.L. told Defendant Suzie Thorne that she remembered that Plaintiff would touch her in her vaginal area with RL’s clothes on.
74. During this third interview, R.L. was asked sixteen times if there was “anything else?”, whereupon the child produced a number of fantasy stories involving non-sexual related incidents.
75. Throughout this lengthy third interview, R.L. continued to stick to her story that Plaintiff had only allegedly touched her in the vaginal area with R.L.’s clothes on.
76. Throughout this interview, Defendant Thorne repeatedly attempted to modify R.L.’s answers to change her story.
77. On June 11, 2008, E.M. was interviewed a second time by Defendant Deal at Defendant CAC-LMJC.
78. (a.) E.M. spent the interval between the two interviews in the care and custody of her mother, Defendant, Kelli McDonald.
(b.) The telephone calls and discussions between Defendants Sheri Wilson, Sandra Lamb, Kelli McDonald and Joal Henke continued throughout this time period.
79. (a.) Under repeated and suggestive questioning, E.M. told Defendant Deal that she could not remember what she had said thirteen days before but she remembered that Plaintiff allegedly (paraphrasing) “touched me inside my panties”.
(b.) This statement was directly contrary to the information E.M. provided in her first interview.
80. During this interview, E.M. also remembered that her mother told her that if she did a good job, she would get a toy.
81. On several occasions during the two interviews he conducted with E.M., Defendant Deal manipulated E.M. into giving different responses to questions he had originally asked.
82. Prior to this interview and after numerous calls with Defendants Sheri Wilson and Sandra Lamb, E.M.’s mother, Defendant Kelli McDonald, “intuited” that E.M. had failed to disclose all of the negative things she had to say about Plaintiff.
83. As such, Defendant Kelli McDonald proceeded to repeatedly and suggestively question E.M. until E.M. made additional negative allegations against Plaintiff.
84. Such questioning was intentionally designed to cause E.M. to change her story and provide statements which implicated Plaintiff of a crime.
85. Shortly after Defendant DeWayne Wilson initiated the ‘investigation’ of Plaintiff by CCSD, Defendant Deal was assigned as the lead investigator in this case.
86. Detective Steven Keith also participated in such ‘investigation’, despite the fact that he had personal friendships with one or more of the parent’s who were alleging that Plaintiff had engaged in this inappropriate behavior.
87. Throughout the course of this investigation, Defendant Deal and the other members of the CCSD who were working on this case refused to interview witnesses who indicated they had information which would tend to show Plaintiff did not commit the acts alleged.
88. Defendant Deal and the other members of the CCSD working on this case also failed and refused to interview other teachers, students and/or parents who regularly observed Plaintiff’s interaction with A.H., R.L. and/or E.M. and who could have disputed the allegations that Plaintiff had engaged in any illegal or improper conduct.
89. Defendant Deal and the rest of the members of the CCSD working on this investigation repeatedly ignored evidence and statements which tended to show Plaintiff did not commit the acts alleged.
90. All such actions of Defendant Deal and the rest of the members of the CCSD working on this investigation described in Paragraphs 87 through 89 above were taken intentionally in an effort to ensure that Plaintiff was convicted of the offenses with which she was charged.
91. At all times throughout this investigation, Defendant Deal and the rest of the members of the CCSD working on this investigation, were employees of Defendant CCSD, a division of Defendant Catoosa County, and were acting under the direction and supervision of Defendant Phil Summers.
92. In or around Spring 2008, Defendant CAC-LMJC hired Defendant Laurie Evans a social worker with a documented history of serious mental illness, as an employee to provide “therapy” for children who were alleged to be victims of abuse.
93. From June 2008 through December 2008, A.H., R.L. and E.M. attended “therapy” with Defendant Laurie Evans at Defendant CAC-LMJC.
94. In December 2008, A.H. ceased attending such sessions after a court reviewing the situation determined that Defendant Laurie Evans should have no further contact with A.H.
95. R.L. and E.M. continued in “therapy” with Defendant Laurie Evans at Defendant CAC-LMJC, until at least April , 2010.
96. At the onset of “therapy”, while exercising no critical judgment whatsoever, Defendant Evans assumed that sexual abuse, as Defendants Suzie Thorne, Stacy Long, Tim Deal and CAC-LMJC had described it, was in fact true.
97. Defendant Evans did not think it appropriate to question Defendants Suzie Thorne, Stacy Long and Tim Deal’s manipulative interviewing techniques or their consequences.
98. Defendant Evans, throughout such therapy, continued to manipulate A.H., R.L. and E.M. to make them assert that Plaintiff had inappropriately touched them, when in fact no such touching had occurred.
99. At all times throughout this “therapy” Defendant Evans was acting as an employee of Defendant CAC-LMJC.
100. Defendant Evans, like other state actors, simply assumed that A.H., R.L. and E.M. had been sexually molested by Plaintiff Tonya Renee Craft.
101. In fact, no such molestation ever occurred.
102. Ignoring the coercive and manipulative nature of the interviews by Defendants Suzie Thorne, Stacy Long, Tim Deal and CAC-LMJC, the lack of physical evidence that would corroborate allegations of sexual abuse, the clear denials of eye-witnesses and peer-reviewed scientific literature in the area of child sexual abuse, Defendant Laurie Evans carried on a course of “therapy” that was designed to make these children allege that they had been molested.
103. Defendant Evans continued to manipulate the children with coercive interrogations and continued to write reports to CAC-LMJC designed to deny Plaintiff visitation access to her children.
104. In their efforts to conspire and perfect their fabricated and fraudulent criminal charges against Plaintiff and to interfere with the parental and familial relationships of the Plaintiff, Defendant Evans, Defendant Long, Defendant Deal and other members of the “Treatment Team”, regularly met for “case conferences” at the CAC-LMJC.
105. These “case conferences” began soon after the children were placed in therapy and they continued until April, 2010.
106. In their efforts to perfect fabricated and fraudulent criminal charges against Plaintiff, as shown above, Defendants Joal Henke, Sarah Henke, Sandra Lamb, Sheri Wilson, DeWayne Wilson, Kelli McDonald manipulated and/or coerced A.H., R.L and E.M. to falsely claim Plaintiff had improperly touched them.
107. In a further effort to perfect fabricated and fraudulent criminal charges against Plaintiff, as shown above, Defendants Thorne, Long, Evans and Deal manipulated A.H., R.L. and E.M. in “therapy” and in interviews and meetings with personnel from the CAC-LMJC, the GREENHOUSE, the CCSD and the Catoosa County District Attorney’s Office, a division of Defendant Catoosa County, to falsely allege that Plaintiff had improperly touched these children.
108. All such actions described in Paragraph 107 above were done while such individuals were employed by Defendants GREENHOUSE, CAC-LMJC and CCSD respectively and were done in the course of their employment with such agencies.
109. Further, Defendants CCSD and Catoosa County, by and through members of the CCSD and the Catoosa County District Attorney’s Office intimidated and manipulated A.H., R.L. and E.M. with leading and suggestive questions in a Grand Jury proceeding designed to once again cause these children to make false allegations of abuse by Plaintiff in order to obtain a criminal indictment against Plaintiff.
110. On April 1, 2009 R.L. was interviewed a fourth time, now by interviewer Holly N. Kittle at Defendant CAC-LMJC.
111. During this interview, R.L. completely contradicted her statements in previous interviews and made many serious and inculpatory statements of and concerning Plaintiff.
112. At trial on April 14, 2010 in the matter of State of Georgia vs. Tonya Renee Craft - [Superior Court of Catoosa County - Case No. 2008-SU-CR-534] R.L. testified that after the June 4, 2008 interview was completed . . . after she had been asked sixteen times if there was “anything else?” . . . R.L. was walking down the hallway with interviewer Suzie Thorne and “just remembered” that Plaintiff put all four of her fingers together and with her fingers and thumb, penetrated R.L.’s vagina.
113. Defendant Suzie Thorne testified that after such interview, R.L. wondered the halls of the GREENHOUSE and located her in a conference room to tell her similar allegations that she had “just remembered”.
114. Defendant Suzie Thorne did not recall R.L. making any such inculpatory statements to her regarding Plaintiff in the hallway following the June 4, 2008 interview, but only some time later when R.L. located her in the building where she was working.
115. Neither Defendant Suzie Thorne, nor any other employee of Defendant GREENHOUSE or of Defendant CCSD considered such alleged statement significant enough to record such statement on video or audio.
116. Additionally, although Defendant Thorne stated that a member of the CCSD was present when this statement was made and took contemporaneous notes, no such contemporaneous notes are contained in the CCSD file and no such notes were produced in discovery in connection with the pending criminal charges against Plaintiff relating to these allegations.
117. At trial April 19, 2010 in the matter of State of Georgia vs. Tonya Renee Craft - [Superior Court of Catoosa County - Case No. 2008-SU-CR-534] Defendant Sheri Wilson testified that on or about May 24, 2008, RL had a discussion with her in Defendant Wilson’s driveway.
118. According to Defendant Sheri Wilson, R.L. told her that Plaintiff had touched her in her privates while she was in the bathtub and in the kitchen.
119. Defendant Wilson demonstrated for the jury with a hand gesture with four fingers together & thumb moving up and down.
120. There was absolutely no documentation of this conversation, or any conversation with Sheri Wilson, in any file, document, report or summary delivered by the State to the Defense in connection with discovery compliance.
121. In fact, Defendant Tim Deal testified during the criminal trial that Defendant Sheri Wilson’s testimony to this effect in trial was the first that he had heard of any such disclosure.
122. Such testimony by Sheri Wilson was false and was made in an effort to have Plaintiff convicted for a crime she did not commit.
123. At trial on April 21 and 22, 2010, Defendant Tim Deal testified that his file in the past was in the same condition and with the same documentation “as it is today”.
124. Whereupon Defendant Deal produced an Investigative Summary authored by his co-detective, Steven Keith, which was allegedly dictated 07-08-08 / allegedly typed 07-27-08, but which was never provided to Plaintiff in connection with discovery, even though the entire CCSD investigative file was supposedly provided to Plaintiff’s counsel for review prior to the criminal trial.
125. In this summary, Defendant Keith, an employee of Defendant CCSD, wrote as follows:
“After the interview, [R.L.] came back in to speak with Suzie. [R.L.] thanked Suzie for allowing her to speak with her and stated there was something else that she did not tell Suzie. [R.L.] then told Suzie that Tonya had inserted her fingers into her vagina and it felt bad.” emphasis added.
126. This document was absolutely not in the material turned over in discovery nor was it in the material two defense attorneys pored over, a month before trial, which included the entire CCSD file on this investigation.
127. Several of the named Defendants herein intentionally provided false testimony under oath in an effort to convince the jury to convict Plaintiff of offenses which she had not committed, including, without limitation the following:
(a.) Defendant Deal provided false testimony, as described in paragraphs 123 through 125 above, and indicated that the document had been in his file at all times.
(b.) Defendant Sheri Wilson provided false testimony regarding the alleged disclosure by R.L. in her driveway and the demonstration by R.L. of the hand gesture described in Paragraphs 117 through 119 above.
(c.) Defendant Thorne provided false testimony regarding the alleged off-camera disclosure by R.L. between interviews as described in Paragraphs 112-116 above.
(d.) Defendant Joal Henke provided false testimony about an alleged lesbian affair that Plaintiff had engaged in and about an alleged incident when Plaintiff had insisted that they watch lesbian pornography. Neither of these incidents in fact occurred.
(e.) Defendant Sarah Henke provided false testimony indicating that she had never shaved her vaginal area in the shower in front of A.H. when in fact she had already admitted to Dr. Ann Hazzard, a court-appointed forensic evaluator, that she had shaved her vaginal area while showering with A.H.
(f.) Additionally, Defendant Sarah Henke falsely testified that A.H. had horrible grooming habits, had matted hair, was constantly dirty and needed Defendant Sarah Henke to bathe with her in order to assist her in maintaining her hygiene;
(g.) Defendant Kelli McDonald provided false testimony under oath that she had not requested Plaintiff to co-sign on a utility account with her in an effort to allow her son to play baseball at a park which was not zoned for her residence.
(h.) Defendant Lamb provided false testimony about allegations which she claimed R.L. had made to her about alleged improper touching by Plaintiff which allegations were never in fact made by R.L.
(i.) Defendant Evans provided false testimony regarding the diagnosis of her own mental health impairment, as well as regarding pleadings which she had filed in court.
128. In addition, the Catoosa County District Attorney’s office permitted a live feed of all testimony to go to a room where many of their witnesses were waiting prior to their testimony in direct violation of the rule of sequestration which was invoked.
129. Such live feed was designed to allow many of the State’s witnesses, including, without limitation, Defendants Lamb, Sheri Wilson, Thorne, Long, Joal Henke, Sarah Henke and Kelli McDonald to listen to the testimony of other witnesses to allow them to alter their testimony to match that of the other witnesses testifying for the State.
130. At trial in connection with these criminal charges, Plaintiff was found not guilty of each and every allegation contained in the indictment relating to the allegations described herein.
131. Thereafter, Defendant Sandra Lamb and Defendant Phil Summers made statements to the press about Plaintiff and relating to the allegations involved in the criminal case.
132. Specifically, in May 2010, Defendant Lamb gave a recorded interview on television in which she states, inter alia, that the “jury got it wrong” and that the “justice system failed our children”.
133. Lamb further indicated in this interview that Plaintiff was guilty of child molestation.
134. Such statements were made by Lamb maliciously and with knowledge that they were false.
135. Defendant Summers made at least two statements to the press in May 2010 following Plaintiff’s not guilty verdict that contained defamatory information.
136. In such statements, Defendant Summers also indicated that the jury verdict was incorrect and that Plaintiff was in fact guilty of the crimes with which she was charged.
137. Defendant Summers further compared Plaintiff to O.J. Simpson in several instances, indicating that Plaintiff and Simpson were both guilty of the crimes with which they were charged and had manipulated the media to assist them in getting not guilty verdicts.
138. Such statements by Summers were made maliciously and with knowledge that they were false.
V. STATEMENT OF CLAIMS
COUNT ONE

VIOLATION OF CIVIL RIGHTS, 42 U.S.C. § 1983 et seq.
AS TO ALL DEFENDANTS

139. Defendants Suzie Thorne, Stacy Long, Phil Summers, Tim Deal and Laurie Evans, for all times relevant to this cause of action, were state actors within the meaning of 42 U.S.C. § 1983, et seq.
140. Defendants Catoosa County, the CCSD, the GREENHOUSE and the CAC-LMJC, at all times relevant to this cause of action, were state actor/agencies within the meaning of 42 U.S.C. § 1983 et seq.
141. These state actors, along with Defendants Sandra Lamb, Sheri Wilson, DeWayne Wilson, Joal Henke, Sarah Henke, and Kelli McDonald, private individuals, engaged in a course of conduct which violated Plaintiff’s statutory and Constitutional rights, contrary to clearly established law.
142. Specifically, Defendants Sandra Lamb, Sheri Wilson, DeWayne Wilson, Joal Henke, Sarah Henke, Kelli McDonald, Tim Deal, Catoosa County, GA, CCSD, Phil Summers, Suzie Thorne, Stacy Long, Laurie Evans, CAC-LMJC, and GREENHOUSE conspired in an effort to have Plaintiff convicted of false allegations of child molestation, aggravated child molestation and aggravated sexual battery through their conduct described in the Plaintiff’s Factual Allegations, above, which includes, without limitation, the specific acts described in Paragraphs 143 through 160 hereinafter below.
143. Defendants Lamb, McDonald, Sheri Wilson and Joal Henke each intentionally asked suggestive, manipulative and deceiving questions to R.L., E.M. and/or A.H. both prior to and during the investigation in this case, using questions which were designed to alter the children’s answers to cause them to falsely implicate Plaintiff of criminal conduct.
144. Defendants Lamb, McDonald, Sheri Wilson, Sarah Henke and Joal Henke made numerous disparaging comments about Plaintiff to R.L., E.M. and A.H., including statements that Plaintiff had engaged in illegal conduct, and the comments were designed to manipulate these children into falsly stating that Plaintiff had improperly touched them.
145. Defendant DeWayne Wilson initiated a criminal investigation centered on Plaintiff when in fact he had no reasonable belief that any such criminal conduct had taken place and he had heard or seen no evidence indicating that Plaintiff had engaged in any criminal conduct.
146. Defendant Joal Henke attempted to alienate the affections of A.H. for her mother by making false statements to her indicating that Plaintiff had “lied to the police,” had “lied for a lot of people” and was likely going to be incarcerated. Additionally, Defendant Joal Henke attempted to alienate A.H.’s affections for Plaintiff by refusing to allow Plaintiff to visit with A.H. through Four Points visitation center, even though such visitation was authorized through Plaintiff’s bond conditions.
147. Defendants Sandra Lamb, Joal Henke and Catoosa County, through the actions of the CCSD arranged and encouraged intimidating and manipulative interviews of A.H. , R.L. and E.M., when in fact there was insufficient evidence to warrant such interviews based upon the statements these children had made prior to the interviews.
148. Defendant Long, through her employer, Defendant CAC-LMJC, intentionally manipulated the statements of R.L. throughout her two interviews with R.L. by asking suggestive, leading and repeated questions designed to cause R.L. to implicate Plaintiff in illegal conduct. Defendant Long further modified certain answers of R.L. to have R.L. further implicate Plaintiff. Defendant Long also disregarded inconsistent statements made by R.L. and repeatedly attempted to convince R.L. to state that Plaintiff had engaged in illegal conduct with R.L. Such conduct, coupled with the ongoing suggestive questioning of Defendant Lamb, Defendant Sheri Wilson and Defendant Thorne, along with the “therapy” provided by Defendant Laurie Evans, eventually caused R.L. to falsely allege that Plaintiff had committed numerous serious felonies which R.L. did not initially disclose during her first three interviews.
149. As to Defendant Suzie Thorne:
(a.) Defendant Thorne and her employer, Defendant GREENHOUSE, intentionally manipulated the statements of R.L. through Thorne’s interview with R.L. by asking suggestive, leading and repeated questions designed to cause R.L. to falsely implicate Plaintiff in illegal conduct. Defendant Thorne further modified certain answers of R.L. to cause R.L. to falsely implicate Plaintiff of criminal offenses. Defendant Thorne also disregarded inconsistent statements made by R.L. and repeatedly attempted to convince R.L. to falsely state that Plaintiff had engaged in illegal conduct with R.L. Such conduct, coupled with the ongoing suggestive questioning of Defendant Lamb, Defendant Sheri Wilson and Defendant Long, along with the “therapy” provided by Defendant Laurie Evans, eventually caused R.L. to falsely allege that Plaintiff had committed numerous serious felonies which R.L. did not initially disclose during her first three interviews.
(b.) Defendant Thorne further alleged that allegations against Plaintiff were made by R.L. following a formal videotaped interview but failed to videotape the alleged allegations as required by GREENHOUSE protocol. Therefore, no formal record existed of the alleged statements. The allegations which were allegedly made by R.L. were the most serious allegations raised in the State’s case against the Plaintiff, but Defendant Thorne failed to record the alleged allegations which hampered Plaintiff’s ability to prepare for and defend her case at trial.
(c.) Defendant Thorne, through her employer, Defendant GREENHOUSE, intentionally manipulated the statements of A.H. through her interview with A.H. by asking suggestive, leading and repeated questions designed to cause A.H. to falsely implicate Plaintiff of illegal conduct. Defendant Thorne also disregarded statements made by A.H. to the effect that the only touching that had occurred between Plaintiff and A.H. was when Plaintiff was applying medicine to A.H. or bathing A.H. Defendant Thorne repeatedly attempted to convince A.H. to falsely state that Plaintiff had engaged in illegal conduct with A.H. Such conduct, coupled with the ongoing suggestive questioning of Defendant Joal Henke, Defendant Sarah Henke and the “therapy” provided by Defendant Laurie Evans, eventually caused A.H. to falsely implicate Plaintiff in criminal conduct by denying her previous statements that all such touching occurred when applying medicine or bathing.
150. Defendant Kelli McDonald attempted to reward E.M. with a toy in exchange for providing incriminating information against Plaintiff, when in fact McDonald knew any such incriminating information would be false. Further, Defendant Deal knew that E.M. was providing implicating information against the Plaintiff based solely on the promise of a reward.
151. Defendant Deal, as an employee of CCSD and Catoosa County, intentionally manipulated the statements of E.M. through his two interviews with E.M. by asking suggestive, leading and repeated questions designed to cause E.M. to falsely implicate Plaintiff of illegal conduct. Defendant Deal further modified certain answers of E.M. to cause E.M. to implicate Plaintiff in criminal conduct. Defendant Deal also disregarded inconsistent statements made by E.M., disregarding statements clearly indicating that E.M was being rewarded by her mother, Defendant Kelli McDonald, for providing negative testimony against Plaintiff and repeatedly attempted to convince E.M. to falsely state that Plaintiff had engaged in illegal conduct with E.M. Such conduct, coupled with the ongoing suggestive questioning of Defendant McDonald and the “therapy” provided by Defendant Laurie Evans, eventually caused E.M. to falsely allege that Plaintiff had committed numerous serious felonies which E.M. did not initially disclose during her first interview.
152. Defendant CCSD, through Defendant Deal and the other members of the CCSD who were working on this case refused to interview witnesses who indicated they had exculpatory information about Plaintiff which would tend to show Plaintiff did not commit the acts alleged. They also failed and refused to interview other teachers, students and parents who regularly observed Plaintiff’s interaction with A.H., R.L. and/or E.M. and who could have disputed the allegations that Plaintiff had engaged in any illegal or improper conduct and that the charges as alleged could not have occurred on the dates and times, or in the manner alleged. Defendants Deal and CCSD further repeatedly ignored evidence and statements which tended to show Plaintiff did not commit the acts alleged, including without limitation direct contradictions in the testimony/statements of R.L., E.M. and A.H. All such actions/inactions were done at the direction of, and under the supervision of Defendant Phil Summers.
153. Defendant Laurie Evans manipulated the statements of R.L., E.M. and A.H., through her therapy sessions, to get these children to falsely assert that Plaintiff had improperly touched them when in fact Evans knew or should have known that no such improper touching had occurred. Such conduct, coupled with the ongoing suggestive questioning of Defendants Joal Henke, Sarah Henke, Kelli McDonald, Sandra Lamb, Sheri Wilson, Suzie Thorne, Stacy Long and Tim Deal eventually caused R.L., E.M. and A.H. to falsely allege that Plaintiff had committed numerous serious felonies which these children did not initially disclose during their initial interviews.
154. Defendant Catoosa County, through Defendant CCSD and the Catoosa County District Attorney’s Office, intentionally arrested Eric Echols, an investigator working for Plaintiff and her attorneys as they were preparing for trial and falsely charged him with witness tampering in an effort to prevent Plaintiff from adequately preparing for her criminal trial, thereby violating her due process rights by attempting to prevent her from presenting a defense and to question potential witnesses against her.
155. Defendant Catoosa County, through Defendant CCSD and the Catoosa County District Attorney’s Office intentionally encouraged the subornation of perjury by knowingly encouraging witnesses to provide false testimony at trial, including the testimony of Defendant Deal described above regarding the falsified report of R.L. which was not recorded.
156. Defendant Catoosa County, through Defendant CCSD and the Catoosa County DFACS forced Plaintiff to execute a “safety plan” to give up temporary custody of her children to Defendant Joal Henke when they had no evidence of any wrongdoing on Plaintiff’s part and no reasonable belief that any such wrongdoing had occurred. To this date, Plaintiff has not been able to regain such custody.
157. Defendants Deal, Sheri Wilson, Suzie Thorne, Joal Henke, Sarah Henke, Kelli McDonald, Sandra Lamb and Laurie Evans all provided false testimony under oath during Plaintiff’s criminal trial, as described in Paragraph 127, above, in an effort to convince a jury to convict Plaintiff of crimes which she never committed.
158. As shown in Paragraph 132, Defendant Sandra Lamb gave a televised interview that was broadcast over the airwaves after Plaintiff was acquitted by a jury on all counts, in which she made false, malicious and defamatory statements following Plaintiff’s acquittal of all charges indicating that Plaintiff had in fact committed the acts of child molestation, knowing that Plaintiff was seeking the return of her children in an ongoing Tennessee custody case with Defendant Joal Henke and further knowing that such statements could impact her ability to regain custody of her children.
159. As shown in Paragraph 135, Defendant Phil Summers made false, malicious and defamatory statements following Plaintiff’s acquittal of all charges indicating that Plaintiff had in fact committed the acts of child molestation, knowing that Plaintiff was seeking the return of her children in an ongoing custody case with Defendant Joal Henke and further knowing that such statements could impact her ability to regain custody of her children.
160. Defendants CAC-LMJC and GREENHOUSE failed to properly train their employee interviewers, leading to the suggestive, manipulative and leading interviews of the three children at issue in this case which formed the basis for the indictment and prosecution of Plaintiff.
161. All such conduct described in Paragraphs 143 through 160 above was a conscious effort by Defendants Sandra Lamb, Sheri Wilson, DeWayne Wilson, Joal Henke, Sarah Henke, Kelli McDonald, Tim Deal, Catoosa County, GA, CCSD, Phil Summers, Suzie Thorne, Stacy Long, Laurie Evans, CAC-LMJC, and GREENHOUSE, in concert, to have Plaintiff falsely convicted of criminal offenses to take away her freedom, to alienate the affections of her children from her and to prevent her from having contact with her children.
162. (a.) Defendants Tim Deal and Phil Summers are employees of Defendant CCSD and Defendant Catoosa County, GA.
(b.) Defendant Suzie Thorne is an employee of Defendant GREENHOUSE.
(c.) Defendants Stacy Long and Laurie Evans are employees of Defendant CAC.
(d.) Defendants Joal Henke, Sarah Henke, Sandra Lamb, Kelli McDonald, DeWayne Wilson, and Sheri Wilson are private persons acting in collaboration and/or conspiracy with the Defendants who are and were state actors.
163. Among other wrongs described in Paragraphs 143 through 160, Defendants CAC-LMJC, CCSD, Catoosa County, GA, Tim Deal, Laurie Evans, Greenhouse, Joal Henke, Sarah Henke, Sandra Lamb, Stacy Long, Kelli McDonald, Phil Summers, Suzie Thorne, DeWayne Wilson, and Sheri Wilson attempted to deprive Plaintiff of her freedom by having her arrested and charged with crimes she did not commit, by falsifying evidence, and by manipulating the statements of R.L., A.H. and E.M. to get them to implicate Plaintiff.
164. Defendants CAC-LMJC, CCSD, Catoosa County, GA, Tim Deal, Laurie Evans, Greenhouse, Joal Henke, Sarah Henke, Sandra Lamb, Stacy Long, Kelli McDonald, Phil Summers, Suzie Thorne, DeWayne Wilson, and Sheri Wilson deprived Plaintiff of her relationship with her children through their individual efforts in fostering false allegations of criminal conduct and/or by removing the children from Plaintiff’s care using threats.
165. The acts of Defendants CAC-LMJC (as stated in Paragraphs 148 and 160), CCSD (as stated in Paragraphs 147, 151, 152, 154, 155, and 156), Catoosa County, GA (as stated in Paragraphs 147, 151, 154, 155, and 156), Tim Deal (as stated in Paragraphs 150, 151, 152, and 157), Laurie Evans (as stated in Paragraphs 153 and 157), GREENHOUSE (as stated in Paragraphs 149, 150, and 160), Joal Henke (as stated in Paragraphs 143, 144, 146, 147, and 157), Sarah Henke (as stated in Paragraphs 144 and 157), Sandra Lamb (as stated in Paragraphs 143, 144, 147, 157, and 158), Stacy Long (as stated in Paragraph 148), Kelli McDonald (as stated in Paragraphs 143, 144, 150, and 157), Phil Summers (as stated in Paragraph 159), Suzie Thorne (as stated in Paragraphs 149 and 157), DeWayne Wilson (as stated in Paragraph 145), and Sheri Wilson (as stated in Paragraphs 143, 144, and 157) were conducted in bad faith.
166. The acts of Defendants CAC-LMJC (as stated in Paragraphs 148 and 160), CCSD (as stated in Paragraphs 147, 151, 152, 154, 155, and 156), Catoosa County, GA (as stated in Paragraphs 147, 151, 154, 155, and 156), Tim Deal (as stated in Paragraphs 150, 151, 152, and 157), Laurie Evans (as stated in Paragraphs 153 and 157), GREENHOUSE (as stated in Paragraphs 149, 150, and 160), Joal Henke (as stated in Paragraphs 143, 144, 146, 147, and 157), Sarah Henke (as stated in Paragraphs 144 and 157), Sandra Lamb (as stated in Paragraphs 143, 144, 147, 157, and 158), Stacy Long (as stated in Paragraph 148), Kelli McDonald (as stated in Paragraphs 143, 144, 150, and 157), Phil Summers (as stated in Paragraph 159), Suzie Thorne (as stated in Paragraphs 149 and 157), DeWayne Wilson (as stated in Paragraph 145), and Sheri Wilson (as stated in Paragraphs 143, 144, and 157) were conducted with deliberate indifference to the effect they had on the life of the Plaintiff.
167. The acts of Defendants CAC-LMJC (as stated in Paragraphs 148 and 160), CCSD (as stated in Paragraphs 147, 151, 152, 154, 155, and 156), Catoosa County, GA (as stated in Paragraphs 147, 151, 154, 155, and 156), Tim Deal (as stated in Paragraphs 150, 151, 152, and 157), Laurie Evans (as stated in Paragraphs 153 and 157), GREENHOUSE (as stated in Paragraphs 149, 150, and 160), Joal Henke (as stated in Paragraphs 143, 144, 146, 147, and 157), Sarah Henke (as stated in Paragraphs 144 and 157), Sandra Lamb (as stated in Paragraphs 143, 144, 147, 157, and 158), Stacy Long (as stated in Paragraph 148), Kelli McDonald (as stated in Paragraphs 143, 144, 150, and 157), Phil Summers (as stated in Paragraph 159), Suzie Thorne (as stated in Paragraphs 149 and 157), DeWayne Wilson (as stated in Paragraph 145), and Sheri Wilson (as stated in Paragraphs 143, 144, and 157), were conducted with reckless disregard for their consequences in the life of the Plaintiff and her immediate family.
168. The acts of Defendants CAC-LMJC (as stated in Paragraphs 148 and 160), CCSD (as stated in Paragraphs 147, 151, 152, 154, 155, and 156), Catoosa County, GA (as stated in Paragraphs 147, 151, 154, 155, and 156), Tim Deal (as stated in Paragraphs 150, 151, 152, and 157), Laurie Evans (as stated in Paragraphs 153 and 157), GREENHOUSE (as stated in Paragraphs 149, 150, and 160), Joal Henke (as stated in Paragraphs 143, 144, 146, 147, and 157), Sarah Henke (as stated in Paragraphs 144 and 157), Sandra Lamb (as stated in Paragraphs 143, 144, 147, 157, and 158), Stacy Long (as stated in Paragraph 148), Kelli McDonald (as stated in Paragraphs 143, 144, 150, and 157), Phil Summers (as stated in Paragraph 159), Suzie Thorne (as stated in Paragraphs 149 and 157), DeWayne Wilson (as stated in Paragraph 145), and Sheri Wilson (as stated in Paragraphs 143, 144, and 157) were unilateral attempts to influence the family relationships enjoyed by the Plaintiff with her children.
169. The acts of Defendants CAC-LMJC (as stated in Paragraphs 148 and 160), CCSD (as stated in Paragraphs 147, 151, 152, 154, 155, and 156), Catoosa County, GA (as stated in Paragraphs 147, 151, 154, 155, and 156), Tim Deal (as stated in Paragraphs 150, 151, 152, and 157), Laurie Evans (as stated in Paragraphs 153 and 157), GREENHOUSE (as stated in Paragraphs 149, 150, and 160), Joal Henke (as stated in Paragraphs 143, 144, 146, 147, and 157), Sarah Henke (as stated in Paragraphs 144 and 157), Sandra Lamb (as stated in Paragraphs 143, 144, 147, 157, and 158), Stacy Long (as stated in Paragraph 148), Kelli McDonald (as stated in Paragraphs 143, 144, 150, and 157), Phil Summers (as stated in Paragraph 159), Suzie Thorne (as stated in Paragraphs 149 and 157), DeWayne Wilson (as stated in Paragraph 145), and Sheri Wilson (as stated in Paragraphs 143, 144, and 157), were committed in gross disregard for clearly-established Constitutional rights of the Plaintiff and her immediate family.
170. As a proximate result of the acts and omissions described herein by state actors Tim Deal, Phil Summers, Suzie Thorne, Stacy Long, Laurie Evans in collaboration and/or conspiracy with employer Defendants Catoosa County, GA, CCSD, CAC-LMJC, and GREENHOUSE, along with private Defendants Sandra Lamb, Sheri Wilson, DeWayne Wilson, Joal Henke, Sarah Henke, and Kelli McDonald, the Plaintiff has been damaged.
171. The damages to the Plaintiff including compensatory, general, and punitive damages are set forth below.
COUNT TWO

VIOLATION OF FOURTEENTH AMENDMENT:
PROCEDURAL DUE PROCESS AS TO ALL DEFENDANTS

172. Defendant Catoosa County, through the CCSD and/or the Catoosa County DFACS, state actors, required the removal of Plaintiff’s children from her care and custody without probable cause, exigent circumstances or a pre-deprivation hearing;
173. Defendant Catoosa County, by and through the CCSD and the Catoosa County District Attorney’s Office, state actors, seized and incarcerated Plaintiff without probable cause, exigent circumstances or a pre-deprivation hearing;
174. Defendant Catoosa County, through the CCSD and/or the CAC-LMJC, both of whom are state actors, performed an intrusive and intimate medical search of the minor A.H., Plaintiff’s daughter, without probable cause, exigent circumstances or a pre-deprivation hearing;
175. Defendant Catoosa County, by and through the CCSD and the Catoosa County District Attorney’s Office, state actors, conspired to subject the Plaintiff to illegal and unconstitutional procedures in the Catoosa County Criminal Courts, including, but not limited to:
(a.) the development of fabricated claims of child sexual abuse;
(b.) the coercion of the minor children A.H., R.L. and E.M. to “remember” and then to “rehearse” the Defendants’ version of A.H., R.L. and E.M.’s statements in the Suzie Thorne, Stacy Long, Tim Deal and Laurie Evans interviews;
(c.) the subornation of perjury from witnesses for the State;
(d.) the delivery of perjured testimony by witnesses for the State;
(e.) the creation of false and fraudulent documentation to buttress and support the states’ specious case;
(f.) the intentional and deliberate refusal to seek and/or investigate exculpatory evidence as to Plaintiff.
176. Based upon these statements, without any proper investigation, and without taking into consideration the obvious parental coaching and outside influences which were wholly independent from Plaintiff, Defendant Catoosa County, Georgia (as stated in Paragraphs 147, 151, 154, 155, and 156), the CAC-LMJC (as stated in Paragraphs 148 and 160), by and through the Catoosa County Department of Family and Children’s Services and Defendant CCSD (as stated in Paragraphs 147, 151, 152, 154, 155, and 156), as well as Defendants Tim Deal (as stated in Paragraphs 150, 151, 152, and 157), Suzie Thorne (as stated in Paragraphs 149 and 157) and Stacy Long (as stated in Paragraph 148), individually; deliberately, intentionally and with reckless disregard ignored the constitutional and civil rights of the Plaintiff by continuing to investigate and ultimately prosecute the Plaintiff. In addition, as a result of the intentional, deliberate and reckless acts of Defendant Catoosa County, Georgia, by and through the Catoosa County Department of Family and Children’s Services and Defendant CCSD, as well as Defendants Tim Deal, Plaintiff’s daughter was taken from Plaintiff’s custody and care under threat of harm, which caused Plaintiff to acquiesce to the unreasonable demands of these Defendants.
177. The violations of the Plaintiff’s rights to due process of law caused by Defendants CAC-LMJC (as stated in Paragraphs 148 and 160), CCSD (as stated in Paragraphs 147, 151, 152, 154, 155, and 156), Catoosa County, GA (as stated in Paragraphs 147, 151, 154, 155, and 156), Tim Deal (as stated in Paragraphs 150, 151, 152, and 157), Laurie Evans (as stated in Paragraphs 153 and 157), GREENHOUSE (as stated in Paragraphs 149, 150, and 160), Joal Henke (as stated in Paragraphs 143, 144, 146, 147, and 157), Sarah Henke (as stated in Paragraphs 144 and 157), Sandra Lamb (as stated in Paragraphs 143, 144, 147, 157, and 158), Stacy Long (as stated in Paragraph 148), Kelli McDonald (as stated in Paragraphs 143, 144, 150, and 157), Phil Summers (as stated in Paragraph 159), Suzie Thorne (as stated in Paragraphs 149 and 157), DeWayne Wilson (as stated in Paragraph 145), and Sheri Wilson (as stated in Paragraphs 143, 144, and 157), were not based upon exigent circumstances or imminent danger.
178. The violations of the Plaintiff’s rights to due process of law caused by Defendants CAC-LMJC (as stated in Paragraphs 148 and 160), CCSD (as stated in Paragraphs 147, 151, 152, 154, 155, and 156), Catoosa County, GA (as stated in Paragraphs 147, 151, 154, 155, and 156), Tim Deal (as stated in Paragraphs 150, 151, 152, and 157), Laurie Evans (as stated in Paragraphs 153 and 157), GREENHOUSE (as stated in Paragraphs 149, 150, and 160), Joal Henke (as stated in Paragraphs 143, 144, 146, 147, and 157), Sarah Henke (as stated in Paragraphs 144 and 157), Sandra Lamb (as stated in Paragraphs 143, 144, 147, 157, and 158), Stacy Long (as stated in Paragraph 148), Kelli McDonald (as stated in Paragraphs 143, 144, 150, and 157), Phil Summers (as stated in Paragraph 159), Suzie Thorne (as stated in Paragraphs 149 and 157), DeWayne Wilson (as stated in Paragraph 145), and Sheri Wilson (as stated in Paragraphs 143, 144, and 157), were not objectively reasonable.
179. The violations of the Plaintiff’s rights to due process of law caused by Defendants CAC-LMJC (as stated in Paragraphs 148 and 160), CCSD (as stated in Paragraphs 147, 151, 152, 154, 155, and 156), Catoosa County, GA (as stated in Paragraphs 147, 151, 154, 155, and 156), Tim Deal (as stated in Paragraphs 150, 151, 152, and 157), Laurie Evans (as stated in Paragraphs 153 and 157), GREENHOUSE (as stated in Paragraphs 149, 150,, , and 160), Joal Henke (as stated in Paragraphs 143, 144, 146, 147, and 157), Sarah Henke (as stated in Paragraphs 144 and 157), Sandra Lamb (as stated in Paragraphs 143, 144, 147, 157, and 158), Stacy Long (as stated in Paragraph 148), Kelli McDonald (as stated in Paragraphs 143, 144, 150, and 157), Phil Summers (as stated in Paragraph 159), Suzie Thorne (as stated in Paragraphs 149 and 157), DeWayne Wilson (as stated in Paragraph 145), and Sheri Wilson (as stated in Paragraphs 143, 144, and 157), were conducted with reckless disregard for the consequences in the life of the Plaintiff.
180. The violations of the Plaintiff’s rights to due process of law caused by Defendants CAC-LMJC (as stated in Paragraphs 148 and 160), CCSD (as stated in Paragraphs 147, 151, 152, 154, 155, and 156), Catoosa County, GA (as stated in Paragraphs 147, 151, 154, 155, and 156), Tim Deal (as stated in Paragraphs 150, 151, 152, and 157), Laurie Evans (as stated in Paragraphs 153 and 157), GREENHOUSE (as stated in Paragraphs 149, 150, and 160), Joal Henke (as stated in Paragraphs 143, 144, 146, 147, and 157), Sarah Henke (as stated in Paragraphs 144 and 157), Sandra Lamb (as stated in Paragraphs 143, 144, 147, 157, and 158), Stacy Long (as stated in Paragraph 148), Kelli McDonald (as stated in Paragraphs 143, 144, 150, and 157), Phil Summers (as stated in Paragraph 159), Suzie Thorne (as stated in Paragraphs 149 and 157), DeWayne Wilson (as stated in Paragraph 145), and Sheri Wilson (as stated in Paragraphs 143, 144, and 157), were motivated by animus and were unilateral attempts to influence the family relationships enjoyed by the Plaintiff.
181. The violations of the Plaintiff’s rights to due process of law caused by Defendants CAC-LMJC (as stated in Paragraphs 148 and 160), CCSD (as stated in Paragraphs 147, 151, 152, 154, 155, and 156), Catoosa County, GA (as stated in Paragraphs 147, 151, 154, 155, and 156), Tim Deal (as stated in Paragraphs 150, 151, 152, and 157), Laurie Evans (as stated in Paragraphs 153 and 157), GREENHOUSE (as stated in Paragraphs 149, 150, and 160), Joal Henke (as stated in Paragraphs 143, 144, 146, 147, and 157), Sarah Henke (as stated in Paragraphs 144 and 157), Sandra Lamb (as stated in Paragraphs 143, 144, 147, 157, and 158), Stacy Long (as stated in Paragraph 148), Kelli McDonald (as stated in Paragraphs 143, 144, 150, and 157), Phil Summers (as stated in Paragraph 159), Suzie Thorne (as stated in Paragraphs 149 and 157), DeWayne Wilson (as stated in Paragraph 145), and Sheri Wilson (as stated in Paragraphs 143, 144, and 157), were undertaken with gross disregard for the clearly established Constitutional rights of the Plaintiff.
182. As a proximate result of the violations of the Plaintiff’s rights to due process of law the Plaintiff was damaged.
183. The damages to the Plaintiff including compensatory, general, exemplary and punitive damages are as set forth below and as will be shown by the evidence at trial.
COUNT THREE

CONSPIRACY UNDER 42 U.S.C. § 1983
STATE ACTORS WITH PRIVATE PERSONS
AS TO ALL DEFENDANTS
184. Defendants Suzie Thorne, Stacy Long, Phil Summers, Tim Deal and Laurie Evans, for all times relevant to this cause of action, were state actors within the meaning of 42 U.S.C. § 1983, et seq.
185. Defendants CCSD, the GREENHOUSE, the CAC-LMJC and Catoosa County, Georgia, for all times relevant to this cause of action, were state actor / agencies within the meaning of 42 U.S.C. § 1983 et seq.
186. Defendants Sandra Lamb, Sheri Wilson, DeWayne Wilson, Kelli McDonald, Sarah Henke and Joal Henke are private persons.
187. These private actors by themselves and through their acts, specifically Joal Henke (as stated in Paragraphs 143, 144, 146, 147, and 157), Sarah Henke (as stated in Paragraphs 144 and 157), Sandra Lamb (as stated in Paragraphs 143, 144, 147, 157, and 158), Stacy Long (as stated in Paragraph 148), Kelli McDonald (as stated in Paragraphs 143, 144, 150 and 157), DeWayne Wilson (as stated in Paragraph 145), and Sheri Wilson (as stated in Paragraphs 143, 144, and 157), conspired and or agreed to a common objective with the state actors, specifically, CAC-LMJC (as stated in Paragraphs 148 and 160), CCSD (as stated in Paragraphs 147, 151, 152, 154, 155, and 156), Catoosa County, GA (as stated in Paragraphs 147, 151, 154, 155, and 156), Tim Deal (as stated in Paragraphs 150, 151, 152, and 157), Laurie Evans (as stated in Paragraphs 153 and 157), GREENHOUSE (as stated in Paragraphs 149, 150, and 160), Phil Summers (as stated in Paragraph 159), and Suzie Thorne (as stated in Paragraphs 149 and 157), to influence the familial and parental relationships of the Plaintiff, and to subject her to a thoroughly illegal and unconstitutional process in the Catoosa County Superior Court.
188. As a proximate result of Defendants’ agreement, conspiracy and overt acts and/or omissions, the Plaintiff was damaged.
189. As a result of such conduct, Plaintiff is entitled to recover of Defendants, jointly and severally, compensatory damages, general damages, exemplary damages, and punitive damages as set forth hereinbelow.
COUNT FOUR
42 U.S.C. § 1983 et seq.
“MONELL” LIABILITY FOR CATOOSA COUNTY,
PROSPECTIVE RELIEF FOR CAC-LMJC, GREENHOUSE AND CCSD

190. After E.M.’s initial interview with Tim Deal, Defendants CCSD, Catoosa County and the CAC-LMJC should have been aware that Tim Deal had failed to receive adequate training on the techniques interviewers should use when interviewing children while investigating allegations of child sexual abuse.
191. (a.) After R.L.’s first interview, which was conducted by Staci Long, Defendants CCSD, Catoosa County, GA, and the CAC-LMJC should have been aware that Staci Long had failed to receive adequate training on the techniques one should use when interviewing children during the course of investigating allegations of child sexual abuse.
(b.) After R.L.’s second interview, which was conducted by Suzie Thorne, Defendants CCSD, Catoosa County, and the GREENHOUSE should have been aware that Suzie Thorne had failed to receive adequate training on the techniques one should use when interviewing children during the course of investigating allegations of child sexual abuse.
192. Staci Long, Tim Deal and Suzie Thorne used leading questions and suggestive techniques in such interviews, as well as ignoring statements that indicated Plaintiff’s innocence in the course of their investigation of this complaint.
193. Prior to the interviews of any of the children at issue in this case, Defendants GREENHOUSE, CAC-LMJC, and CCSD were aware that Defendants Thorne, Long, and Deal had not received proper training in forensic interviewing.
194. These Defendant agencies took no action to discipline their employees for using these improper techniques and failed to take any actions to prevent the repetition of such behavior, or to take any action against or even adequately investigate the incidents similar to the ones described in this lawsuit.
195. These Defendant agencies tacitly authorized and continued to authorize such improper conduct by their Defendant employees, without which the Defendants’ conduct as described in this complaint would not have occurred.
196. Defendants CCSD, Catoosa County, the GREENHOUSE and the CAC-LMJC were aware of a pattern of statutory and Constitutional violations of citizens’ rights and were aware of the inadequate training and supervision of its employees.
197. It was obvious that failing to correct these patterns of statutory and Constitutional rights violations as well as violations of clearly established law, together with the inadequate training and supervision of employees, would lead to further violations of citizens’ legal and Constitutional rights.
198. Defendants CCSD, Catoosa County, the GREENHOUSE and the CAC-LMJC were and continue to be deliberately indifferent to the risk that the inadequate training and supervision of their employees would very likely lead to violations of citizens’ legal and Constitutional rights.
199. Defendants CCSD, Catoosa County, the GREENHOUSE and the CAC-LMJC have adopted a policy, practice, or custom of permitting and tolerating Constitutional violations by their employees in the State of Georgia.
200. Defendants CCSD, Catoosa County, the GREENHOUSE and the CAC-LMJC and/or their employees have provided and continue to provide false, negative and damaging information concerning the Plaintiff to the press, and continue to interfere with the Constitutional rights of the Plaintiff.
201. As a proximate result of the unconstitutional policies, practices, or customs of these Defendants, the Plaintiff continues to suffer violations of her rights under the laws of the State of Georgia, the Constitution of the State of Georgia and the Fourteenth Amendment of the Constitution of the United States of America.
202. As a result of such conduct, Plaintiff is entitled to recover of Defendants, jointly and severally, compensatory damages, general damages, exemplary damages, and punitive damages as set forth hereinbelow.
SUPPLEMENTAL STATE LAW CLAIMS
COUNT FIVE

ORDINARY OR “COMMON LAW” NEGLIGENCE
AS TO DEFENDANT JOAL HENKE

203. At the time of the incidents described hereinabove, Defendant Joal Henke owed a specific statutory duty not to alienate the affections of his children, including A.H., from Plaintiff, their mother, pursuant to T.C.A. § 36-6-101(a)(3)(F).
204. Defendant Joal Henke breached that duty by providing negative information to A.H., as described in Paragraphs 56 through 61, above, in an effort to alienate her affections for Plaintiff and to cause her to provide false statements regarding Plaintiff.
205. Defendant Joal Henke did not use ordinary and reasonable care in his interactions with the Plaintiff, or with the children.
206. The lack of ordinary and reasonable care constituted a breach of the duty Defendant Joal Henke owed to this Plaintiff.
207. As a proximate result of such breach, the Plaintiff was damaged.
208. As a result of such conduct, Plaintiff is entitled to recover of Defendant Joal Henke compensatory damages, general damages, exemplary damages, and punitive damages as set forth hereinbelow.
COUNT SIX

DEFAMATION PER SE AS TO DEFENDANTS
SANDRA LAMB AND PHIL SUMMERS

209. In May 2010, during the pendency and following the conclusion of the criminal proceedings in the State of Georgia, Defendants Sandra Lamb and Phil Summers published in writing and by speech various documents, reports, statements and pleadings making false and defamatory statements of and concerning Plaintiff, as detailed above in Paragraphs 131 through 138.
210. The false and defamatory statements published by speech and in writing, by Defendants Lamb and Summers included but were not limited to statements which directly and by innuendo expressed that Plaintiff Tonya Renee Craft was a criminal and had engaged in acts of child molestation.
211. At the time they published by speech and in writing the false and defamatory statements of and concerning Plaintiff, Defendants knew or should have known that the statements were false.
212. These statements were lacking in reasonable basis in fact and were false.
213. These statements were defamatory, as they were false and inflammatory.
214. These statements were published to third parties.
215. These statements were made maliciously.
216. Based upon the nature of these statements, they represent slander per se under Georgia law.
217. As a proximate result of Defendants Lamb and Summers’ publication of these false and defamatory remarks, Plaintiff was damaged.
218. As a result of such conduct, Plaintiff is entitled to recover of Defendants Lamb and Summers, jointly and severally, compensatory damages, general damages, exemplary damages, and punitive damages as set forth hereinbelow.
COUNT SEVEN

INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
AS TO ALL DEFENDANTS

219. Defendants CAC-LMJC (as stated in Paragraphs 148 and 160), CCSD (as stated in Paragraphs 147, 151, 152, 154, 155, and 156), Catoosa County, GA (as stated in Paragraphs 147, 151, 154, 155, and 156), Tim Deal (as stated in Paragraphs 150, 151, 152, and 157), Laurie Evans (as stated in Paragraphs 153 and 157), GREENHOUSE (as stated in Paragraphs 149, 150, and 160), Joal Henke (as stated in Paragraphs 143, 144, 146, 147, and 157), Sarah Henke (as stated in Paragraphs 144 and 157), Sandra Lamb (as stated in Paragraphs 143, 144, 147, 157, and 158), Stacy Long (as stated in Paragraph 148), Kelli McDonald (as stated in Paragraphs 143, 144, 150, and 157), Phil Summers (as stated in Paragraph 159), Suzie Thorne (as stated in Paragraphs 149 and 157), DeWayne Wilson (as stated in Paragraph 145), and Sheri Wilson (as stated in Paragraphs 143, 144, and 157), acted as to the Plaintiff with conduct a reasonable person would describe as extreme and outrageous.
220. Such extreme and outrageous conduct was done recklessly and without regard to whether it might cause injury to the Plaintiff and her relationships with her family.
221. The extreme and outrageous conduct of Defendants CAC-LMJC, CCSD, Catoosa County, GA, Tim Deal, Laurie Evans, GREENHOUSE, Joal Henke, Sarah Henke, Sandra Lamb, Stacy Long, Phil Summers, Suzie Thorne, DeWayne Wilson, and Sheri Wilson was designed to subvert the parental and familial relationships between the Plaintiff and her family.
222. Additionally, the extreme and outrageous conduct of Defendants CAC-LMJC, CCSD, Catoosa County, GA, Tim Deal, Laurie Evans, GREENHOUSE, Joal Henke, Sarah Henke, Sandra Lamb, Stacy Long, Phil Summers, Suzie Thorne, DeWayne Wilson, and Sheri Wilson was designed to cause the Plaintiff to lose custody of her children and to be falsely prosecuted for offenses she never committed.
223. As a proximate result of the Defendants’ extreme and outrageous conduct, the Plaintiff was damaged.
224. As a result of such conduct, Plaintiff is entitled to recover of Defendants CAC-LMJC, CCSD, Catoosa County, GA, Tim Deal, Laurie Evans, Greenhouse, Joal Henke, Sarah Henke, Sandra Lamb, Stacy Long, Kelli McDonald, Phil Summers, Suzie Thorne, DeWayne Wilson, and Sheri Wilson, jointly and severally, compensatory damages, general damages, exemplary damages, and punitive damages as set forth hereinbelow.
COUNT EIGHT

INVASION OF PRIVACY AS TO DEFENDANTS
CCSD, CATOOSA COUNTY, GA, TIM DEAL, and PHIL SUMMERS

225. Plaintiff, her children, her parents and her husband are members of a close-knit family.
226. Plaintiff has a right to privacy guaranteed by the First and Fourteenth Amendments to the Constitution of the United States of America.
227. In May of 2008, with no reasonable or probable cause, with no competent evidence of any crime, with no exigent circumstances and with no imminent danger to any member of the Plaintiff’s immediate family, Defendants CCSD, Catoosa County, GA, Tim Deal, and Phil Summers used their power and that of the State of Georgia to remove Plaintiff’s children from her house with threats that the children would otherwise be taken into the custody of the State and intimidated Plaintiff by using said threats to induce her to sign the “safety plan.”
228. All such acts of the Defendants described in this pleading were further aimed at portraying Plaintiff in a false light to the public.
229. As a proximate result of such conduct and their intrusion and invasion of the Plaintiff’s privacy, the Plaintiff was damaged.
230. As a result of such conduct, Plaintiff is entitled to recover of Defendants, jointly and severally, compensatory damages, general damages, exemplary damages, and punitive damages as set forth hereinbelow.
COUNT NINE

MALICIOUS PROSECUTION/FALSE ARREST
UNDER GEORGIA STATE LAW AS TO ALL DEFENDANTS

231. Defendants CAC-LMJC (as stated in Paragraphs 148 and 160), CCSD (as stated in Paragraphs 147, 151, 152, 154, 155, and 156), Catoosa County, GA (as stated in Paragraphs 147, 151, 154, 155, and 156), Tim Deal (as stated in Paragraphs 150, 151, 152, and 157), Laurie Evans (as stated in Paragraphs 153 and 157), GREENHOUSE (as stated in Paragraphs 149, 150, and 160), Joal Henke (as stated in Paragraphs 143, 144, 146, 147, and 157), Sarah Henke (as stated in Paragraphs 144 and 157), Sandra Lamb (as stated in Paragraphs 143, 144, 147, 157, and 158), Stacy Long (as stated in Paragraph 148), Kelli McDonald (as stated in Paragraphs 143, 144, 150, and 157), Phil Summers (as stated in Paragraph 159), Suzie Thorne (as stated in Paragraphs 149 and 157), DeWayne Wilson (as stated in Paragraph 145), and Sheri Wilson (as stated in Paragraphs 143, 144, and 157), acted in furtherance of the common objective of framing Plaintiff with false charges of sexual battery, child molestation, aggravated child molestation and/or aggravated sexual battery.
232. As a result of the Defendants’ actions, including without limitation, the creation of false evidence against Defendant through the use of manipulative, suggestive and repeated questioning of the children, the Plaintiff was arrested on charges she did not commit.
233. These Defendants, each of them, further caused the criminal proceedings to be initiated against Plaintiff in connection with charges Plaintiff did not commit.
234. These criminal proceedings had no reasonable basis, were not supported by probable cause and were initiated out of sheer malice on these Defendants’ part.
235. Among other things, these Defendants used false statements to cause the initiation of these criminal proceedings and/or to cause the furtherance of such proceedings.
236. The criminal proceedings terminated in Plaintiff’s favor, through a unanimous jury verdict of ‘not guilty’ on all counts.
237. As a proximate result of Defendants’ agreement, conspiracy and/or overt acts or omissions, the Plaintiff was damaged.
238. As a result of such conduct, Plaintiff is entitled to recover of Defendants, jointly and severally, compensatory damages, general damages, exemplary damages, and punitive damages as set forth hereinbelow.
DAMAGES
239. Plaintiff suffered damages which were proximately caused by the conduct of the Defendants, jointly and severally, which included, without limitation, the following:
(a) humiliation;
(b) outrage;
(c) indignity;
(d) conscious pain and suffering;
(e) loss of custody, society and companionship of her family members;
(f) mental suffering and sorrow;
(g) headaches and the physical sequella of emotional stress;
(h) grief, anger, horror, fright;
(i) the stress and costs of legal fees and scores of court appearances;
(j) outright distrust of law and judicial officials;
(k) and all other damages fair and equitable under the circumstances.
240. Plaintiff claims that the acts of these Defendants and the damages to Plaintiff proximately flowing from those acts entitle her to exemplary damages, because the acts of the Defendants:
(a) Caused injuries to Plaintiff’s feelings not capable of precise computation;
(b) Caused Plaintiff intensified injury due to the Defendants’ acts of
bad faith or ill will;
(c) Caused Plaintiff intensified injury due to the willful and wanton nature of the Defendants’ acts;
(d) Caused Plaintiff intensified injury due to the sheer
reprehensibility of the Defendants’ conduct;
(e) Caused Plaintiff intensified injury attributable to Plaintiffs
indignation and outrage;
(f) Demonstrated on the part of each of these Defendants a conscious indifference to the consequences of their actions and a series of malicious and intentional acts designed to harm Plaintiff and deny her freedom.
241. Plaintiff claims that the acts of the Defendants and the damages to Plaintiff proximately flowing from those acts entitle her to punitive damages pursuant to 42 U.S.C.§ 1983 et. seq.
DEMAND FOR TRIAL BY JURY
The Plaintiff demands that her case be tried before a jury of her peers
RELIEF REQUESTED
WHEREFORE, Plaintiff demands as follows:
(a) With respect to all Defendants, the Plaintiff requests that the trier of fact award her TWENTY-FIVE MILLION DOLLARS, jointly and severally from each of these Defendants, in the form of:
1) Compensatory, economic damages;
2) Damages for emotional distress;
3) Exemplary damages;
4) Punitive damages;
5) Attorneys fees and costs under 42 U.S.C. § 1988; and
6) Such other relief as is just and equitable under the circumstances.
(b) With respect to Defendants CAC-LMJC, the GREENHOUSE and the CCSD, the Plaintiff requests that this Court order them to comply with federal law and:
1)Remove Plaintiff Tonya Renee Craft from the records of any Georgia site or list of child abusers;
2)Establish a protocol to competently investigate claims of sexual abuse which includes corroborating information and/or competent forensic evaluation;
3)Establish a protocol to competently conduct investigatory interviews of children concerning possible sexual abuse which specifically requires video taped interviews and avoids adult interviewer sexualization of the interview, use of leading questions, multiply repeated questions, disconfirmation, and anatomically detailed dolls;
4)Competently train and supervise their employees to enable them to effectively investigate claims of sexual abuse and interview children that have alleged sexual abuse in keeping with the established protocol.
(c) that this Court award Plaintiff such other and further relief as is just and equitable.
Respectfully submitted this 30th day of September, 2010.

_/s/ ______________________
Scott R. King
Georgia Bar No. 421345
Cary S. King
Georgia Bar No. 419810
Attorneys for Plaintiff

JACOBS, KING & WALLACK
1117 Perimeter Center West, Suite W501
Atlanta, Georgia 30338
(404) 920-4490
scott@jkwlawfirm.com
cary@jkwlawfirm.com