Case 7:08-Tc-05000 Document 2 Filed 01/08/2008 Page 1 of 96
Case 7:08-tc-05000 Document 2 Filed 01/08/2008 Page 1 of 96 IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF GEORGIA VALDOSTA DIVISION ASTANIEL JARVIS MANN, CIVIL ACTION NO. PIP HENG, ELIJAH ADCOCK, RONNY N. ASKEW, RICKIE LEE FOX, JODRPH DANIEL FINCHER, and SHEDRICK D. ROSS, Plaintiffs, Vs. CLASS ACTION COMMISSIONER JAMES DONALD, RICK JACOBS, SARAH DRAPER, DR. SHARON LEWIS, MD., WARDEN HART, DEPUTY WARDEN MCLAUGHLIN, ALBERT JONES, CAPTAIN MORRIS, LT. MAINE, OFFICER POWELL, OFFICER JESSE HOWELL, OFFICER T. BROWN, OFFICER YANCEY, OFFICER CANNON, OFFICER SNAKE, OFFICER SMITH, OFFICER SHANE, OFFICER GRAINGER, OFFICER RADCLIFF, SERGEANT BOND, OFFICER PAGE, OFFICER DANIEL, OFFICER BATES, OFFICER JOHN DOE NO. 1, and OFFICER JOHN DOE NO. 2, Defendants. Case 7:08-tc-05000 Document 2 Filed 01/08/2008 Page 2 of 96 COMPLAINT – CLASS ACTION Plaintiffs, Astaniel Jarvis Mann, (“Mann”), Pip Heng (“Heng”), Elijah Adcock (“Adcock”), Ronnie N. Askew (“Askew”), Ricky Lee Fox (“Fox”), Joseph Daniel Fincher (“Fincher”), and Shedrick D. Ross (“Ross”) file this Complaint pursuant to 42 U.S.C. § 1983 in accordance with FRCP Rule 23, and show the Court as follows: PLAINTIFFS 1. Plaintiffs Mann, Heng, Adcock, Askew, Fox, Fincher, and Ross were incarcerated in the Georgia Department of Corrections and at all times relevant were inmates at the Valdosta State Prison or at Lowndes State Prison in Valdosta, Georgia which is within the Middle District of Georgia. DEFENDANTS 2. Defendant James E. Donald (“ Commissioner Donald”) was at all times relevant and is currently Commissioner of the Georgia Department of Corrections; Defendant Rick Jacobs (“ Jacobs”) was at all times relevant and is currently Director of Special Operations Sections of the Corrections Divisions of the Georgia Department of Corrections; Defendant Sarah Draper (“Draper”) was at all times relevant and currently Director of Internal Case 7:08-tc-05000 Document 2 Filed 01/08/2008 Page 3 of 96 Investigations of the Georgia Department of Corrections; Defendant Dr.
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