In the State Court of Dekalb County State of Georgia
IN THE STATE COURT OF DEKALB COUNTY STATE OF GEORGIA PATRICK C. DESMOND AND MARY C. DESMOND, INDIVIDUALLY, AND MARY C. DESMOND, AS ADMINISTRATRIX OF THE ESTATE OF PATRICK W. DESMOND, Civil Action No. 10-A-28641-2 Plaintiffs, v. JURY TRIAL DEMANDED NARCONON OF GEORGIA, INC. DELGADO DEVELOPMENT, INC., LISA CAROLINA ROBBINS, M.D. THE ROBBINS GROUP, INC., NARCONON INTERNATIONAL, Defendants. PLAINTIFFS' FIRST AMENDED COMPLAINT TO ADD ALLEGATIONS AND CLAIMS Plaintiffs Patrick C. Desmond and Mary C. Desmond, individually, and Mary C. Desmond, as Administratrix of the Estate of Patrick W. Desmond, file this First Amended Complaint. The Plaintiffs add counts of Civil RICO by Fraudulent Statements to a Government Agency, Mail Fraud, and Theft by Deception. Plaintiffs hereby incorporate by reference each allegation, count, claim, request for damages, and all supporting evidence set out in their Original Complaint, filed with this Court on May 19, 2011. PARTIES, JURISDICTION, AND VENUE 1. Patrick W. Desmond ("Patrick" or "Patrick Desmond"), deceased, was the natural son of Patrick C. Desmond and Mary C. Desmond. Patrick W. Desmond was a resident of Brevard County, Florida at the time of his death. Patrick C. Desmond and Mary C. Desmond are residents of Brevard County, Florida. 1 2. Patrick W. Desmond died intestate. The Circuit Court for the Eighteenth Judicial Circuit in and for Brevard County, Florida issued Letters of Administration duly appointing Mary C. Desmond as Administratrix of the Estate of Patrick W. Desmond on July 9, 2009. 3. Narconon of Georgia, Inc. ("NNG") is a business incorporated under the laws of the State of Georgia.
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