AlPal’s Conflict of Interest, and Alleged Threats & Intimidation by Chris Corbin

Tuesday, October 27,2009

On Saturday,October 24, 2009. I receive Pleadings from Albert Palmour and Chris Corbin.� Chris Corbin was responding to my Motion to Compel, of which I wrote about last week,taking the position that he as County attorney has a say so in what individuals I have subpoenaed have to say.

I have been assured by a number of attorneys and several judges that Chris Corbin, as Chattooga County attorneys, absolutely DOES NOT have any jurisdiction over the men and women I have subpoenaed, just as he would not be involved if one of them were sued for a divorce or called to testify for a neighbor in a barking dog issue.Just because a man or woman is a government employee, does not mean a government attorney, paid for by tax payer dollars, is to interject themselves in the civil or criminal litigation of that government employee.The only time a government attorney, like a County attorney,gets involved is if the government employees was acting in an official capacity at the time an tort or a crime occurred.

At this point,it is not clear that what the Espy’s alleged in their article even occurred, and most certainly it did not occur between the Espys and any of the witnesses acting as an official spokesman or Public Relations Officer for Chattooga County Sheriff’s Office.

So, Chris Corbin has no authority in this matter.End of discussion.

But even funnier is the fact that Albert Palmour, on behalf of the City of Summerville and the City of Trion, both of whom he represents, filed Motions to Quash for two of the witnesses, who are assigned to the Chattooga County Narcotics from those two municipalities, Shannon Goins and Josh Brock.

The same applies to Mr. Palmours sad attempt at interjecting himself to cover up for the Cooks and Espys.

One retired judge I have been in contact with about these odd responses, told me that while he would certainly set Palmour and Corbin straight in his courtroom, and while he believes Chris Corbin’s actions have earned him some time in the state pen,(see threats below),that he would not let the Sheriff’s Office deputies and agents off either.As he told me,they are in violation of law,and if they do not answer their deposition questions before a hearing is had, that if it were him,he would sanction them as well.He said that each witness refusing to answer the questions could be fined either a $500.00 fine,a few days in lockup,or both.This gentleman judge reminded me that a judge is allowed to do to encourage someone to comply with the law in civil actions with these measures.

He also told me that as these agenst and investigators know,when they arrest someone for a crime,ignorance of the law they have violated is no defense.He also found it amusing that someone in the Chattooga County Sheriff’s Office, one of the witnesses,found it necessary to “Lawyer up”.

I have reprinted, below, most of what is in the pleadings I filed yesterday, but before I do, there are two other things I learned yesterday:

1)While Albert Palmour’s pleading insisted that the subpoenas I served on all the witnesses were not personally served, Sheriff John Everett insisted to me yesterday that each one was PERSONALLY served.So,what happens to a lawyer who knowingly lies in a Pleading?

2)Mr. Cordle called Douglas County’s Superior Court Judge Beau McClain yesterday,and learned that Judge McClain had not only accepted the case, buthad filled out the paperwork severl weeks ago,formally accepting the case.That paperwork was returned to the District 7 unit of the Council for Superior Court Judges,which has not sent out the actual ORDER yet.Judge McClain’s secretary promised to contact them,and speed that ORDER along, so that a Rule Nisi hearing can be set, before this case gets out of control.

Now, my responses:

PLAINTIFF’S RESPONSE TO WITNESS SHANNON GOINS’ MOTION TO QUASH

1.Witness’s Motion to Quash objects to Plaintiff’s Written Depositions because it was not personally served upon her.

But Plaintiff served through statutory Certified Mail, which was delivered on Sheriff Everett, who is the Officer of the Court charged with PERSONALLY serving all subpoenas submitted to his office. Such service was perfected on September 4, 2009, more than six weeks before Witness Brock’s Motion to Quash was filed.

Indeed, the Sheriff’s Office has never refused, declined or failed to personally serve any subpoenas which Plaintiff has brought to them for service in other civil litigation, to non-party witnesses.

Why is this situation any different

2.Witness’s Motion to Quash objects to Plaintiff’s Written Depositions because it did not contain the case number.� This is a minor Scriveners’ error, and can be easily corrected.

If Mr. Palmour wants to get very picky about such errors, Plaintiff references Mr. Palmours’ own mistake in paragraph #6,below.

3.Witness’s Motion to Quash objects to Plaintiff’s Written Depositions because it failed to list a specific time by which Witness had to respond.

Yet in civil practice, the deadline for most responses is 30 days, unless otherwise specified. Service was made on September 4, 2005, making the statutory deadline October 5, 2009.

Furthermore, Plaintiff included a letter to Sheriff Everett along with each subpoena and set of questions, and encouraged him to contact Plaintiff if he had any questions.

No contact was ever initiated by Sheriff Everett, or any attorney on behalf of any employee of the Sheriff’s Department for more than one full month after service, and then, only at Plaintiff’s constant urging. See letter to Sheriff John Everett - (Exhibit 1).

Indeed, Witness’s Motion to Quash was not even filed until more than six week after Witness was served with Written Deposition Questions.

4.Witness’s Motion to Quash objects to Plaintiff’s Written Depositions because it is “Unreasonable, Overbroad, does not relate to case”.

However, questions served upon Witness are very simple, generic questions to establish context of who witness is and where they work, and what their credentials are, and the questions related to the very specific allegations by the Espy’s news article alleging Drug Agents called Plaintiff a liar.

These questions go the very heart of the law suit against the defendant Espy’s, relate to Plaintiff’s reputation. Plaintiff deserves to know if Witness Brock called her a liar, as the Espy’s article suggests.

5.Witness’s Motion to Quash objects to Plaintiff’s Written Depositions because it may require production of confidential material.

It is unbelievable that Mr. Palmour has made this claim, as NO request for production of any documents was requested.� Only a few questions related to identifying the witness and related to specific aspects of Plaintiff’s case.

6.Witness’s Motion to Quash objects to Plaintiff’s Written Depositions because it without Substantial Justification.

However, as already stressed several time above, questions relate DIRECTLY to the case at hand, including allegations by the Espy defendants that certain drug agents called Plaintiff a liar and made other slanderous comments about Plaintiff.

7.This Motion to Quash is not valid, because Mr. Palmour neglected to include all parties to the action in the Certificate of Service. (Exhibit 2).

8.This Motion to Quash is invalid for Failure to object within ten days:

Plaintiff served through statutory Certified Mail, which was delivered on Sheriff Everett, who is the Officer of the Court charged with PERSONALLY serving all subpoenas submitted to his office. Such service was perfected on September 4, 2009, more than six weeks before Witness Brock’s Motion to Quash was filed.

In neglecting to raise an objection to Plaintiff’s Written Depositions questions to Witness, attorney Albert Palmour Mr. Palmour has lost for his client the right to refuse to object to any of the discovery Plaintiff has requested, and must comply immediately.

� 9-11-45.��Subpoena for taking depositions; objections; place of examination

(a)(1)(A)�The clerk of the superior court of the county in which the action is pending or the clerk of any court of record in the county where the deposition is to be taken shall issue subpoenas for the persons sought to be deposed, upon request.

(2)�The person to whom the subpoena is directed may, within ten days after the service thereof or on or before the time specified in the subpoena for compliance, if such time is less than ten days after service, serve upon the attorney designated in the subpoena written objection to inspection or copying of any or all of the designated materials. If objection is made, the party serving the subpoena shall not be entitled to inspect and copy the materials except pursuant to an order of the court from which the subpoena was issued. The party serving the subpoena may, if objection has been made, move, upon notice to the deponent, for an order at any time before or during the taking of the deposition, provided that nothing in this Code section shall be construed as requiring the issuance of a subpoena to compel a party to attend and give his deposition or produce documents at the taking of his deposition where a notice of deposition under Code Section 9-11-30 has been given or a request under Code Section 9-11-34 has been served, such notice or request to a party being enforceable by motion under Code Section 9-11-37.

In KENNESTONE HOSPITAL, INC. v. HOPSON., 273 Ga. 145, 538 S.E.2.d 742 (2000), the court stresses the consequences of a party refusing to comply with proper discovery. �In their decision, the high court wrote:

“DISCOVERY PROCEDURES

The Georgia Civil Practice Act provides for the discovery of “any matter, not privileged, which is relevant to the subject matter involved in the pending action.” [2] A party’s failure to object to a discovery request within the time required generally will result in a waiver of the right to object…. [3] The issue in this appeal is whether the general rule should apply to requests under OCGA 9-11-34 (c) to nonparties for the production of documents that are protected by the psychiatrist-patient privilege.”

Furthermore, in Kennestone, the high court concluded:

“Paragraph (c) (1) of OCGA 9-11-34 sets out the procedure for obtaining discovery and gives the nonparty or any party the right to object; paragraph (c) (2) applies the code section specifically to discovery against a nonparty who is a practitioner of the healing arts, hospital, or health care facility. The party desiring discovery must serve all parties with the request, and the nonparty or any party may file an objection with the court. If an objection is filed, the nonparty shall not furnish the requested materials until further order of the court and the party seeking the discovery may file a motion to compel discovery. “If no objection is filed within ten days of the request, the nonparty to whom the request is directed shall promptly comply.” [5].

14.Conflict of Interest-Albert Palmour has been a major person of interest in a long running, organized crime investigation. His name is redacted in GBI Vernon Keenan’s JQC complaint against Defendant Graham, as the Summerville attorney in SAC J.R. (Rusty) Grant’s report (Exhibit 3, paragraph 2).

Like attorney Chris Corbin, Albert Palmour has been the subject of Plaintiff’s articles as well, in her March 24, 2008� article – “Major Chattooga County Drug Indictments”an

d her March 27, 2008 article – “New Twist on Chattooga County Indictments?” (Exhibit 4).

Albert Palmour’s name is also redacted as being the individual who approached Chattooga County Narcotics Squad Commander, Mike Howard, (one of the witnesses Plaintiff is attempting to depose through written depositions), and threatened Commander Howard on behalf of Defendant Graham, because Howard was investigating valid leads about drug activity engaged in by both Palmour and Defendant Graham. See SAC Rsuty Grant’s report, (Exhibit 3, paragraph 3).

However, even more strikingly conflicting is the fact that on Wednesday, March 26, 2008, the day after he was arraigned in the Rome Division of Northern District of Georgia, Federal Court, federal drug defendant Michael Leon Smith, (Northern District of Georgia Criminal Indictment 04:07-CR020-RLV-WEJ), a criminal client of Albert Palmour’s, contacted PLAINTIFF, and begged her to help him come in to the feds, to become a federal witness.� The condition was that the federal government would have to help him arrange to get a new lawyer, and protect his family.

The reason for Mr. Smith’s insistence at a new lawyer, was because he had been working with Albert Palmour, who was the head of a Continuing Criminal Enterprise, and that CCE included significant ties to various components of the Mexican Mafia.

Mr. Smith confided many aspects of his own criminal activity, and told Plaintiff that he would be able to link Defendant Graham, a cousin of his, and Albert Palmour and many others in organized crime.

On that afternoon, as Plaintiff kept Federal defendant Michael Leon Smith on one phone, she used a second phone and contacted Narcotics Squad Commander Mike Howard, who contacted DEA Agent Frank Ledford, and IRS-CID Agent John Schmarkey, each of whom had been responsible for investigating and indicting Smith, several of his relatives, and several members of the Mexican Mafia.

Arrangements were made, all within legal boundaries, new counsel was secured for Mr. Smith, and he was able to detail significant structure of several organized crime organizations.� In fact, his testimony was so significant, that when he was sentenced, Judge Robert L. Vining, thanked Smith for his efforts, which had brought down significant strongholds of Mexican Mafia drug trade.

This has brought a significant burden to Albert Palmour’s own CCE, and as the walls have started collapsing in his organization, Albert Palmour has become violent.

Even the weekend after Mr. Smith’s federal arrest, while he was awaiting arraignment, Albert Palmour sent two members of the Mexican Mafia to see Smith’s wife, Stephanie Smith, and threaten her should her husband talk once he was released. This incident frightened Mr. Smith for his family’s safety, and angered him enough to contact me the day after he was released.

Then, last winter, an individual who, as the manager of a Rome, Georgia finance company, had been laundering drug trade money for Palmour and a Chattooga County used car dealer, was called to task by his home office, for discrepancies and odd transactions.

Albert Palmour and the car dealer kidnapped the finance company manager, held him over night, bound him, terrorized him, and threatened his and his family’s lives should the finance company manager talk or not cover for Palmour and the used car dealer’s drug activity and money laundering.

As in Mr. Smith’s situation, this only caused the victim to become enraged at the thought of Palmour and his partner hurting his family, and so he contacted a Rome attorney, and they went to the FBI.

That is still an open case.

Plaintiff learned about the kidnapping event from someone involved in the situation.

But this Honorable Court needs to understand the nature and scope of the CCE which has ultimately been controlled by Defendant Cook, his daughter, Defendant Graham, and Mr. Palmour in these last few years.

Mr. Palmour is dangerous, and his only reason for becoming involved in the Written Deposition issues with members of the Chattooga County Sheriff’s Office, is to protect the interest of the Cook-Graham-Palmour CCE.

Wherefore, Plaintiff requests that Witness Shannon Brock’ Motion to Quash be denied, and that witness Brock be compelled to answer the Plaintiff’s questions.

Respectfully submitted this 26^th day of October, 2009.

Teresa Watson

PLAINTIFF’S RESPONSE TO WITNESS EDDIE STROUP’S, et al, RESPONSE TO PLAINTIFF’S MOTION TO COMPEL

1.Witness’s Eddie Stroup, et al’s, Response to Plaintiff’s Motion to Compel objects to Plaintiff’s Written Deposition questions because the subpoena failed to list a specific time by which Witness had to respond.

Yet in civil practice, the deadline for most responses is 30 days, unless otherwise specified. Service was made on September 4, 2005, making the statutory deadline October 5, 2009.

Furthermore, Plaintiff included a letter to Sheriff Everett along with each subpoena and set of questions, and encouraged him to contact Plaintiff if he had any questions.

No contact was ever initiated by Sheriff Everett, or any attorney on behalf of any employee of the Sheriff’s Department for more than one full month after service, and then, only at Plaintiff’s constant urging. See letter to Sheriff John Everett - (Exhibit 1).

Indeed, Witness’s Response was not even filed until more than six week after Witness was served with Written Deposition Questions.

2.Witness’s Eddie Stroup, et al’s, Response to Plaintiff’s Motion to Compel objects to Plaintiff’s Written Deposition questions because the subpoenas failed to list a specific officer of the court to whom witnesses could answer questions to.

Yet responding Chattooga County attorney is an officer of the court, as is each of the witnesses to whom written deposition questions were served, as is their boss, Chattooga County Sheriff John Everett.

Since Chattooga County attorney Chris Corbin not only demanded of each witness that they refuse to answer, he also then filed this response, when he could easily have taken the answers by each witness.

Furthermore, as iterated in her letter to Sheriff Everett, the subpoena form did not conform to what was specifically needed, Plaintiff discussed this with Chattooga County Clerk of Court, Sam L. Cordle, who instructed Plaintiff to make due with the form. See Letter to Sheriff John Everett, (Exhibit 1).

3.Witness Eddie Stroup, et al’s, Response to Plaintiff’s Motion to Compel objects because the subpoenas were not served personally on each witness.

But Plaintiff served through statutory Certified Mail, which was delivered on Sheriff Everett, who is the Officer of the Court charged with PERSONALLY serving all subpoenas submitted to his office. Such service was perfected on September 4, 2009, more than six weeks before Witness Brock’s Motion to Quash was filed.

Indeed, the Sheriff’s Office has never refused, declined or failed to personally serve any subpoenas which Plaintiff has brought to them for service in other civil litigation, to non-party witnesses.

Why is this situation any different?

4.Witness’s Eddie Stroup, et al’s, Response to Plaintiff’s Motion to Compel objects to Plaintiff’s Written Deposition questions because they are without substantial justification.

However, questions served upon Witness are very simple, generic questions to establish context of who each witness is and where they work, and what their credentials are, or, the questions related to the very specific allegations by the Espy’s news article alleging Drug Agents called Plaintiff a liar.

These questions go the very heart of the law suit against the defendant Espy’s, relate to Plaintiff’s reputation. Plaintiff deserves to know if Witness Brock called her a liar, as the Espy’s article suggests.

6.Witness’s Eddie Stroup, et al’s, Response to Plaintiff’s Motion to Compel �should be denied for Failure to object within ten days:(Editor’s Note – We have omitted the content which is cited above with regard to this issue).

7.During the week of August 3, 2009, two of these witnesses, Mark Schrader and Brian Tucker, were called to testify in the court case filed by Defendant Bobby Lee Cook and others, AGAINST Plaintiff, and Chattooga County Chris Corbin never objected.Testimony included case and investigation testimony, but not a peep was heard from Chattooga County attorney Chris Corbin.

Now, simple questions related directly to the issues in this law suit, and whether or not any of the drug agents or investigators ever called Plaintiff a liar, or accused her of lying, as alleged in the Espy Defendant’s August 6, 2009 article about the August 3, 2009 case - are suddenly off limits.

Plaintiff wants to know why there is a double standard being played out here.

8.Last Tuesday, October 20, 2009 Plaintiff began getting phone calls from persons identifying themselves as friends and or family members of Chattooga County Sheriff’s Office agents and investigators who had been served with Written Deposition questions by Plaintiff.

These persons told Plaintiff that their friends/family members had wanted to answer the Written Deposition questions, but had been threatened by Chattooga County attorney Chris Corbin.

According to these individuals, Chris Corbin threatened the witnesses that if they attempted to answer these questions with another attorney or officer of the court, that Chris Corbin, on behalf of Chattooga County, would sue them under “Rule 11” and take everything these witnesses owned, including their homes.

Plaintiff tried to assure these callers that Chris Corbin could not do that.� Plaintiff explained to each of the callers that:

1. First of all, a “Rule 11″ is a FEDERAL Civil Practice Rule, and cannot be applied in Superior Courts of Georgia.

2. Secondly, sanctions for it and the corresponding Georgia Code, 9-15-14, usually applies to parties involved in the case, Plaintiffs and Defendants, and not for obeying the law and responding to discovery.

3. Thirdly, the sanctions under 9-15-14 are generally applied to the attorneys of the offending parties, and even then, are rarely granted.

Plaintiff then contacted a member of the judiciary in Georgia, who responded through a third party, instructing Plaintiff to contact the GBI immediately, which Plaintiff did.

Wherefore, Plaintiff requests this Honorable Court to grant her Motion to Compel, and have these brave men and women answer the written deposition questions as most of them want to do.

Plaintiff further requests this Honorable Court to order a formal investigation into these allegations of threats and intimidation of the eight Chattooga County Sheriff’s Office witnesses, by Chattooga County Chris Corbin.

Respectfully submitted this �26th day of October, 2009.

Teresa Watson