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***EFILED***DC
Date: 6/20/2018 5:27 PM
Cathelene Robinson, Clerk
DAN GASAWAY, )
)
Petitioner, )
)
v. ) Civil Action File No.: 2018-CV-306197
)
BRIAN KEMP, Georgia Secretary )
of State & Chairman of State Elections )
Board, LAUREL ELLISON, Habersham )
County Elections Supervisor, and CHRIS )
ERWIN, Republican Nominee for Georgia )
House District 28 – May 22, 2018. )
)
Respondents. )
Petitioner Dan Gasaway (“Mr. Gasaway” or “Petitioner”) respectfully files this Memorandum of
Law Supporting His Motion for Leave to Amend His Petition And to Add Parties.
INTRODUCTION
This case is about multiple county elections boards assigning voters to wrong state house
districts, thereby contaminating an election and taking a state house seat from Mr. Gasaway. The
deeper that Mr. Gasaway has dug, the more mis-assignments he has found. Mr. Gasaway seeks
leave to amend his Petition to reflect the newly-identified grounds of contest, relevant facts, and
prayers for relief that are specified in his First Amended Petition attached as Exhibit “1”.
The Court should grant Mr. Gasaway leave to amend his Petition and to add newly-
earliest stages of this action, are already aware of this action’s existence, and can be allowed
additional time to respond to the extent needed. Mr. Gasaway’s amendment is justified because
he obtained the state-wide certified voter data after his first Petition’s filing and, consequently,
could not identify the newly identified mis-districted voters until recently. Mr. Gasaway should
be permitted to amend his Petition to accurately reflect the facts of this case and the parties
involved.
STATEMENT OF FACTS
This case, filed just 14 days ago, challenges an election that was certified just 19 days
ago. The special summons has been issued, and the initially-named Defendants should soon be
Since this case’s filing on June 6, 2018, Mr. Gasaway has worked tirelessly to identify
voters that were assigned to the wrong district and who, as a result, voted in the wrong election.
Identifying these voters required obtaining certified voter data lists from the Secretary of State’s
Office, analyzing these certified data lists, and cross-referencing these lists with certified state
house district maps. Recently, Mr. Gasaway obtained a state-wide certified voter list, showing
all of the persons that voted in the May 22, 2018 General Republican Primary Election (the
“Election”). Using sophisticated GEO-mapping tools, this list was compared with state house
district maps to locate voters that may have voted in the wrong district. The voters so identified
were then examined one-by-one to determine if they were indeed assigned to the wrong state
house district.
Mr. Gasaway’s search identified many mis-assigned voters that, based upon the short
five-day filing deadline, he was unable to identify and name in his first Petition. Many of these
voters resided in counties other than Habersham County, which was the only county Mr.
2
Gasaway initially examined. Mr. Gasaway moved expeditiously to located these new voters, and
is moving expeditiously for leave from the Court to amend his Petition to reflect these new
voters and the correspondingly new parties that arguably should be added to this action.
ARGUMENT
I. Mr. Gasaway Should be Given Leave to Amend His Petition Under O.C.G.A. § 21-2-524
(g).
O.C.G.A. § 21-2-524(g) establishes that “[a]fter filing, any petition . . may be amended
with leave of the court so as to include the specification of additional grounds of contest, other
relevant facts, or prayer for further relief.” This provision within Georgia’s Election Code was
likely included due to the tight deadlines for election contest cases. An election contest must be
The Georgia Civil Practice Act and Georgia case law provides parties significant leniency
in amending their pleadings. Parties may amend pleadings as a matter of course and without
leave of court at any time before the entry of a pretrial order. O.C.G.A. § 9-11-15. Georgia
courts hold that amendments shall be freely and liberally given when justice requires. Midtown
Properties, Inc. v. George F. Richardson, Inc., 139 Ga. App. 182 (1976). Plaintiffs have even
been allowed to amend their complaints after commencement of trial. Harris v. Tutt, 306 Ga.
App. 377 (2010). Although O.C.G.A. § 21-2-524(g) uniquely governs Mr. Gasaway’s right to
amend, the Court should apply that provision in a manner consistent with the leniency ordinarily
Precluding Mr. Gasaway from amending his Petition, here, would be particularly
egregious. Mr. Gasaway has exercised the utmost diligence in prosecuting this case. Mr.
Gasaway obtained the available voter data within days of the election’s certification; Mr.
Gasaway examined this voter data immediately upon receipt; Mr. Gasaway retained counsel
3
immediately upon discovery of the systematic errors; and Mr. Gasaway filed a 28 page, 102
paragraph Petition within five days of the election’s certification. Since filing the first Petition,
Mr. Gasaway obtained the certified state-wide voter list for Election, analyzed this list, located
additional mis-assigned voters, and revised and amended his initial Petition all within 14 days.
One would be hard-pressed to identify a more diligent party than Mr. Gasaway.
grounds of contest, new relevant facts, and new prayers for relief. Through his search of the
certified voter lists, Mr. Gasaway identified many new voters who had been assigned to the
wrong district and who voted in the Election. These new voters included: (1) those that resided
in HD 28, but had been assigned to HD 32; (2) those that resided in HD 28, but had been
assigned to HD 31; (3) those that resided in HD 32, but had been assigned to 28; (4) and more
voters that had been assigned to HD 10, but resided in HD 28. Many of the voters reside in
counties other than Habersham County, which was the only county that had been initially-
As noted earlier, Georgia courts give parties significant liberty to amend their pleadings.
This principle applies equally in election contests, where courts have held that the failure to
name proper parties is an amendable defect, correctable by the parties or even upon the court’s
own motion. Brodie v. Champion, 281 Ga. 1015, (2006). O.C.G.A. § 21-2-524(g) stipulates for
courts to give parties leave to amend to include the specification of additional grounds of contest,
other relevant facts, or prayer for further relief. This is only requirement for leave to be granted.
Mr. Gasaway’s diligence has uncovered additional grounds of contest, new relevant facts, and
new prayers for relief all of which have been specified in his Amended Petition. O.C.G.A. § 21-
2-524(g) provides that leave should be granted for Mr. Gasaway to amend his Petition here.
4
II. Mr. Gasaway Should be Given Leave to Amend His Petition to Add Parties to This Case.
Mr. Gasaway’s search identified new wrongly-districted voters who live in Stephens
County, Banks County, Franklin County, and Jackson County. O.C.G.A. § 21-2-520 states that
“superintendents who conducted the contested primary” should be named as defendants, and
registrations”. Thus, the board of elections and registrations for Stephens County, Banks
County, Franklin County, and Jackson County (collectively, “New Parties”) should be added to
this case. Mr. Gasaway is also adding the Habersham County Board of Elections and
O.C.G.A. § 9-11-21 establishes that leave must be sought from the Court to amend
pleadings to add parties to an action. Guhl v. Tuggle, 242 Ga. 412, 414 (1978)(“parties may be
dropped or added by order of the court on motion of any party or of its own initiative at any stage
of the action and on such terms as are just.”). “Among the factors to be considered by the trial
court in determining whether to allow the amendments are whether the new part[ies] will be
prejudiced thereby and whether the movant has some excuse or justification for having failed to
name and serve the new part[ies] previously.” Ellison v. Hill, 288 Ga. App. 415, 418 (2007).
Determination of whether a party should be added to a lawsuit lies within the discretion of the
trial court, and this determination will not be disturbed on appeal absent a showing of abuse.
Here, the New Parties would not be prejudiced by being added. First, the amendment is
being made so early that there is no catch-up period. The parties named in the initial petition
were likely just served. Mr. Gasaway is willing to consent to the New Parties having additional
time to respond to the Amended Petition, if needed. Second, all the New Parties are not adverse.
The New Parties have an interest and duty aligned with Mr. Gasaway to ensure that elections are
5
fairly, accurately, and properly administered. This case seeks to achieve that result. The New
Parties could, in fact, agree with Mr. Gasaway’s findings and seek to remedy the result by
Mr. Gasaway is justified in failing to name the New Parties initially, because he did not
have the requisite state-wide certified voter data to identify all the wrongly-districted voters and,
consequently, the necessary parties to the action. Mr. Gasaway’s search of the certified state-
wide voter data showed that individuals residing in Stephens County, Banks County, Franklin
County, and Jackson County also were assigned to wrong district. As the county election boards
and registration that administered the Election, the New Parties are arguably indispensable to this
The New Parties would not be prejudiced by being added, and Mr. Gasaway is justified
in not naming them in his first Petition. Mr. Gasaway should, therefore, be allowed to add them
now.
CONCLUSION
For the foregoing reasons, Mr. Gasaway should be granted leave to file his First
Amended Petition, which is attached as Exhibit “1”, and to add the board of elections and
registrations for Habersham County, Stephens County, Banks County, Franklin County, and
6
Atlanta, Georgia 30326
(404) 541-2900 – Main
(404) 541-2905 – Facsimile
Attorneys for Petitioner Dan Gasaway
7
EXHIBIT 1
IN THE SUPERIOR COURT OF FULTON COUNTY
STATE OF GEORGIA
DAN GASAWAY, )
)
Petitioner, )
)
v. ) Civil Action File No.: 2018-cv-306197
)
BRIAN KEMP, Georgia Secretary )
of State & Chairman of State Elections )
Board, HABERSHAM COUNTY BOARD )
OF ELECTIONS AND REGISTRATION, )
LAUREL ELLISON, Habersham County )
Elections Supervisor, FRANKLIN )
COUNTY BOARD OF ELECTIONS, )
BANKS COUNTY BOARD OF )
ELECTIONS, STEPHENS COUNTY )
BOARD OF ELECTIONS, JACKSON )
COUNTY BOARD OF ELECTIONS, )
and CHRIS ERWIN, Republican Nominee )
for Georgia House District 28 – May 22, )
2018. )
)
Respondents. )
FIRST AMENDED PETITION TO CONTEST ELECTION RESULTS & REQUEST FOR NEW ELECTION
MAY 22, 2018 REPUBLICAN PARTY GENERAL PRIMARY ELECTION
GEORGIA HOUSE OF REPRESENTATIVES DISTRICT 28
______________________________________________________________________________
INTRODUCTION
(“Petition”) to contest the election results for the May 22, 2018 Republican Party General
Primary (“Election”) for Georgia House of Representatives District 28 (“HD 28”)1 pursuant to
O.C.G.A. § 21-2-520 et seq. This Petition should be granted because the respective county
1
A certified copy of the map representing Georgia House of Representatives District 28 is attached as Exhibit “A”.
boards of elections and registrations (the “Boards”)2 systematically assigned voters to incorrect
districts, causing irregularities in the Election, causing illegal votes to be cast in the Election, and
causing voters to be denied their right to vote in the Election. These irregularities and illegal
votes total at least 75 votes and the Election was decided by only 67 votes, changing and placing
in doubt the Election’s result. Thus, to uphold the democratic principles on which this nation
was built, the Election should be set aside and a new election should be ordered.
The Boards’ systematic assignment of voters to the wrong State House districts changes
and casts in doubt the Election’s result. Wrong district assignments caused voters residing in HD
10 and HD 32 to vote in the HD 28 election. These irregularities caused illegal votes to be cast
in the Election. Wrong district assignments also caused voters residing in HD 28 to vote in the
denying them their right to vote in the Election.3 Making matters worse, although not all voting
in the Election, at least 404 individuals have been identified as being assigned to the wrong
district.
Voters that should not have voted in the Election did, and voters that should have voted
resulted in at least 44 voters in HD 28 being denied their right to vote in the Election, and at least
31 individuals voting in a contest that they were ineligible for. The Election was decided by only
67 votes, and at least 75 votes were illegally cast in the Election. Georgia law is clear that it is
the number of votes, not who was voted for, that counts. Because the number of votes exceeds
2
The pertinent elections boards are the Habersham County Board of Elections and Registration, the Stephens
County Board of Elections and Registration, the Banks County Board of Elections and Registration, the Franklin
County Board of Elections and Registration, and the Jackson County Board of Elections and Registration.
3
Attached as Exhibit “B” is a map showing the wrongly-districted individuals that voted in the Election.
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the margin of victory in HD 28, the Election results should be thrown out and a new election
should be ordered.
PARTIES
1.
HD 28. He is a resident of HD 28, residing at 1446 Scales Creek Road, Homer, Georgia 30547.
He was also a candidate for re-election in the Election. Pursuant to O.C.G.A. § 21-2-521, he is
2.
Georgia’s Chief Elections Official.4 Pursuant to O.C.G.A. § 21-2-499, the Secretary is required
to tabulate, compute, and canvass the results of state elections. The Secretary also certifies the
superintendents that conducted the contested election, and resides at 555 Monroe St., Unit 45,
Clarkesville, GA 30523.
4
Naming the Secretary of State as the state’s chief election official in petitions contesting election results is required
under O.C.G.A. § 21-2-520. The Petitioner acknowledges that the Secretary of State is defending the security of the
ballot box, here, by investigating the issues named in this Petition to present to the State Election Board for possible
prosecution. But, for Gasaway to preserve his right to seek a new election, this Amended Petition must be filed
before the Secretary’s investigation was completed. See O.C.G.A. § 21-2-524(a)(timing for filing a petition to
contest an election).
-3-
4.
superintendents that conducted the contested election, and resides at P.O. Box 313 211 Athens
5.
superintendents that conducted the contested election, and resides at 12 West Tugalo Street,
6.
superintendents that conducted the contested election, and resides at 226 Candler Street, Homer,
Georgia 30547.
7.
superintendents that conducted the contested election, and resides at 441 Gordon Street,
Jefferson, GA 30549.
8.
Defendant Laurel Ellison (“Ms. Ellison”) is the Habersham County Elections Supervisor.
Ms. Ellison’s address is 160 Ponce De Leon Drive, Clarkesville, Georgia 30523.
9.
Defendant Chris Erwin (“Erwin”) was the candidate that opposed Dan Gasaway in the
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JURISDICTION & VENUE
10.
11.
The first Petition was timely-filed with this Court. The Secretary certified the Election
results on Friday, June, 1, 2018. The first Petition was filed on June 6, 2018, within five days of
the certification pursuant to O.C.G.A. § 21-1-524(a). This Amended Petition relates back to the
first-filed Petition.
12.
13.
An affidavit executed by the Petitioner verifying this Amended Petition is contained with
FACTUAL BACKGROUND
14.
County election officials are responsible for allocating voters to correct legislative
districts.
15
The Joint Office of Legislative and Congressional Reapportionment (the “Office”) assists
counties in allocating voters to the proper legislative district. The Office also provides maps that
-5-
16.
Here, the Habersham County Board of Elections and Registration, the Stephens County
Board of Elections and Registration, the Banks County Board of Elections and Registration, the
Franklin County Board of Elections and Registration, and the Jackson County Board of Elections
17.
The Boards were delegated the duty to assign voters the correct ballot for the legislative
18.
The Boards breached this duty, though, by assigning voters in the Election to the wrong
State House districts, causing illegal votes to be cast and disenfranchising voters.
19.
The Election was held on May 22, 2018. Erwin finished in first place in the Election
20.
The Election was certified by the Secretary of State on Friday, June 1, 2018.
21.
Katie Hartrick observed that the race for HD 10, instead of the race for HD 28, appeared
on her ballot despite her living in HD 28. Ms. Hartrick’s husband, Ryan Hartrick, also observed
that the race for HD 10, instead of the race for HD 28, appeared on his ballot despite him living
in HD 28. The Hartricks executed affidavits affirming these facts and are attached as Exhibit
“D”.
-6-
22.
Catherine Bruce Simpson Wiles observed that the race for HD 10, instead of the race for
HD 28, appeared on her ballot despite her living in HD 28. Ms. Wiles executed an affidavit
23.
Initially, using voter registration data provided from the Secretary of State’s office,
Gasaway plotted the location of voters on a map provided by the Office using Microsoft Map
Point.
24.
By plotting the locations of voters, Gasaway realized that voters with addresses in his
district were included on the list of HD 10 voters and not on the list for HD 28 voters. Gasaway
initially found at least 350 voters that had been assigned to the incorrect Georgia State House of
Representatives district.
25.
Gasaway has since retrieved certified state-wide voter data from the Secretary of State’s
26.
Gasaway used this certified voter data to definitively locate individuals that either should
have voted in the Election, but did not, or should not have voted, but did. These errors are
27
All of the Election’s affected voters reside in Habersham County, Stephens County,
-7-
28.
Using the certified list showing all the individuals voting in the May 22, 2018 General
Primary Election generated by the Secretary of State, at least 75 voters were identified that voted
in the wrong election because they were assigned to the wrong district.
29.
A list of the individuals that voted in the May 22, 2018 General Primary Election and
were assigned to the wrong district and voted in the wrong election is attached as Exhibit “F”. A
30.
Samuel R.A. Ausburn resides at 312 Sterling Meadows Court, Demorest, GA 30535-
5196, Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 28. However, Georgia voter registration records show that Samuel R.A.
Ausburn was assigned to House District 10 in error. Samuel R.A. Ausburn voted in the May 22,
31.
County. Exhibit “A” demonstrates that this address is within the boundaries of Georgia House
District 28. However, Georgia voter registration records show that Charles M. Miller was
assigned to House District 10 in error. Charles M. Miller voted in the May 22, 2018 General
Primary Election.
-8-
32.
Sarah E. Smith resides at 294 Wilson Rd, Cornelia, GA 30531-5560, Habersham County.
Exhibit “A” demonstrates that this address is within the boundaries of Georgia House District 28.
However, Georgia voter registration records show that Sarah E. Smith was assigned to House
District 10 in error. Sarah E. Smith voted in the May 22, 2018 General Primary Election.
33.
Casey Aaron Dover resides at 253 Sterling Meadows Dr, Demorest, GA 30535-5195,
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 28. However, Georgia voter registration records show that Casey Aaron
Dover was assigned to House District 10 in error. Casey Aaron Dover voted in the May 22,
34.
Alice Cates Dover resides at 253 Sterling Meadows Dr, Demorest, GA 30535-5195,
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 28. However, Georgia voter registration records show that Alice Cates
Dover was assigned to House District 10 in error. Alice Cates Dover voted in the May 22, 2018
35.
Katie Joy Hartrick resides at 620 Elderberry Ct, Demorest, GA 30535-5374, Habersham
County. Exhibit “A” demonstrates that this address is within the boundaries of Georgia House
District 28. However, Georgia voter registration records show that Katie Joy Hartrick was
assigned to House District 10 in error. Katie Joy Hartrick voted in the May 22, 2018 General
Primary Election.
-9-
36.
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 28. However, Georgia voter registration records show that Ryan
Nicholas Hartrick was assigned to House District 10 in error. Ryan Nicholas Hartrick voted in
37.
Barbara Harper King resides at 321 Sterling Meadows Ct, Demorest, GA 30535-5196,
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 28. However, Georgia voter registration records show that Barbara
Harper King was assigned to House District 10 in error. Barbara Harper King voted in the May
38.
Kevin Nelson King resides at 321 Sterling Meadows Ct, Demorest, GA 30535-5196,
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 28. However, Georgia voter registration records show that Kevin Nelson
King was assigned to House District 10 in error. Kevin Nelson King voted in the May 22, 2018
39.
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 28. However, Georgia voter registration records show that Dustin
-10-
Thomas Mealor was assigned to House District 10 in error. Dustin Thomas Mealor voted in the
40.
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 28. However, Georgia voter registration records show that Hope Green
Mealor was assigned to House District 10 in error. Hope Green Mealor voted in the May 22,
41.
Owen E. Cantrell resides at 4988 Highway 197 S., Mount Airy, GA 30563-2442,
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 28. However, Georgia voter registration records show that Owen E.
Cantrell was assigned to House District 10 in error. Owen E. Cantrell voted in the May 22, 2018
42.
Richard Allen Smith resides at 294 Wilson Rd, Cornelia, GA 30531-5560, Habersham
County. Exhibit “A” demonstrates that this address is within the boundaries of Georgia House
District 28. However, Georgia voter registration records show that Richard Allen Smith was
assigned to House District 10 in error. Richard Allen Smith voted in the May 22, 2018 General
Primary Election.
43.
Jana Celeste Ward resides at 436 Ansley Rd, Demorest, GA 30535-5101, Habersham
County. Exhibit “A” demonstrates that this address is within the boundaries of Georgia House
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District 28. However, Georgia voter registration records show that Jana Celeste Ward was
assigned to House District 10 in error. Jana Celeste Ward voted in the May 22, 2018 General
Primary Election.
44.
County. Exhibit “A” demonstrates that this address is within the boundaries of Georgia House
District 28. However, Georgia voter registration records show that Doris E. Wilson was
assigned to House District 10 in error. Doris E. Wilson voted in the May 22, 2018 General
Primary Election.
45.
Donna S. Cantrell resides at 4988 Highway 197 S., Mount Airy, GA 30563-2442,
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 28. However, Georgia voter registration records show that Kenneth
Eugene Brooksher was assigned to House District 10 in error. Donna S. Cantrell voted in the
46.
Sheri Laine Allen resides at 472 Linwood Dr, Demorest, GA 30535-5373, Habersham
County. Exhibit “A” demonstrates that this address is within the boundaries of Georgia House
District 28. However, Georgia voter registration records show that Sheri Laine Allen was
assigned to House District 10 in error. Sheri Laine Allen voted in the May 22, 2018 General
Primary Election.
-12-
47.
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 28. However, Georgia voter registration records show that Kale Brandon
Allen was assigned to House District 10 in error. Kale Brandon Allen voted in the May 22, 2018
48.
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 28. However, Georgia voter registration records show that Justin Wayne
Andersen was assigned to House District 10 in error. Justin Wayne Andersen voted in the May
49.
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 28. However, Georgia voter registration records show that Carol Susan
Arrington was assigned to House District 10 in error. Carol Susan Arrington voted in the May
50.
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 28. However, Georgia voter registration records show that Brian L.
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Ausburn was assigned to House District 10 in error. Brian L. Ausburn voted in the May 22,
51.
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 28. However, Georgia voter registration records show that Kelly L.
Ausburn was assigned to House District 10 in error. Kelly L. Ausburn voted in the May 22,
52.
Billy Lewis Barnhill resides at 378 Sterling Meadows Ct, Demorest, GA 30535-5196,
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 28. However, Georgia voter registration records show that Billy Lewis
Barnhill was assigned to House District 10 in error. Billy Lewis Barnhill voted in the May 22,
53.
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 28. However, Georgia voter registration records show that Kellie
Carpenter Gosnell was assigned to House District 10 in error. Kellie Carpenter Gosnell voted in
54.
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
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Georgia House District 28. However, Georgia voter registration records show that Benjamen
Jock Gosnell was assigned to House District 10 in error. Benjamen Jock Gosnell voted in the
55.
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 28. However, Georgia voter registration records show that Sharon
Dianna Harris was assigned to House District 10 in error. Sharon Dianna Harris voted in the
56.
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 28. However, Georgia voter registration records show that Marvin
Russell Harris was assigned to House District 10 in error. Marvin Russell Harris voted in the
57.
Joey Dale Mcclellon resides at 104 Wilson Rd, Cornelia, GA 30531-5538, Habersham
County. Exhibit “A” demonstrates that this address is within the boundaries of Georgia House
District 28. However, Georgia voter registration records show that Joey Dale Mcclellon was
assigned to House District 10 in error. Joey Dale Mcclellon voted in the May 22, 2018 General
Primary Election.
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58.
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 28. However, Georgia voter registration records show that Kimberly
Leah Mikowski was assigned to House District 10 in error. Kimberly Leah Mikowski voted in
59.
Lyndell Rose Pollack resides at 378 Sterling Meadows Ct, Demorest, GA 30535-5196,
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 28. However, Georgia voter registration records show that Lyndell Rose
Pollack was assigned to House District 10 in error. Lyndell Rose Pollack voted in the May 22,
60.
County. Exhibit “A” demonstrates that this address is within the boundaries of Georgia House
District 28. However, Georgia voter registration records show that Marianne J. Smith was
assigned to House District 10 in error. Marianne J. Smith voted in the May 22, 2018 General
Primary Election.
61.
David Terrell Squires resides at 400 Sterling Meadows Ct, Demorest, GA 30535-5197,
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 28. However, Georgia voter registration records show that David Terrell
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Squires was assigned to House District 10 in error. David Terrell Squires voted in the May 22,
62.
Cathy June Squires resides at 400 Sterling Meadows Ct, Demorest, GA 30535-5197,
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 28. However, Georgia voter registration records show that Cathy June
Squires was assigned to House District 10 in error. Cathy June Squires voted in the May 22,
63.
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 28. However, Georgia voter registration records show that Ladonna S.
Canup was assigned to House District 10 in error. Ladonna S. Canup voted in the May 22, 2018
64.
James G. Hamilton, Jr. resides at 4898 Highway 197 S., Mount Airy, GA 30563-2442,
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 28. However, Georgia voter registration records show that James G.
Hamilton, Jr. was assigned to House District 10 in error. James G. Hamilton, Jr. voted in the
65.
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
-17-
Georgia House District 28. However, Georgia voter registration records show that George
Chandler Dean was assigned to House District 10 in error. George Chandler Dean voted in the
66.
County. Exhibit “A” demonstrates that this address is within the boundaries of Georgia House
District 28. However, Georgia voter registration records show that Lisa J. Dean was assigned to
House District 10 in error. Lisa J. Dean voted in the May 22, 2018 General Primary Election.
67.
County. Exhibit “A” demonstrates that this address is within the boundaries of Georgia House
District 28. However, Georgia voter registration records show that Helen M. Decker was
assigned to House District 10 in error. Helen M. Decker voted in the May 22, 2018 General
Primary Election.
68.
County. Exhibit “A” demonstrates that this address is within the boundaries of Georgia House
District 28. However, Georgia voter registration records show that Clarence C. Decker was
assigned to House District 10 in error. Clarence C. Decker voted in the May 22, 2018 General
Primary Election.
69.
County. Exhibit “A” demonstrates that this address is within the boundaries of Georgia House
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District 28. However, Georgia voter registration records show that Patricia G. Bower was
assigned to House District 10 in error. Patricia G. Bower voted in the May 22, 2018 General
Primary Election.
70.
Pamela C. Hamilton resides at 4898 Highway 197 S., Mount Airy, GA 30563, 2442,
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 28. However, Georgia voter registration records show that Pamela C.
Hamilton was assigned to House District 10 in error. Pamela C. Hamilton voted in the May 22,
71.
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 10. However, Georgia voter registration records show that Robert B.
Hilton was assigned to House District 28 in error. Robert B. Hilton voted in the May 22, 2018
72.
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 10. However, Georgia voter registration records show that Debra E.
Wood was assigned to House District 28 in error. Debra E. Wood voted in the May 22, 2018
-19-
73.
David Allen Wood resides at 1350 Hollywood Church Rd, Clarkesville, GA 30523-3928,
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 10. However, Georgia voter registration records show that David Allen
Wood was assigned to House District 28 in error. David Allen Wood voted in the May 22, 2018
74.
Betty Jane May resides at 1273 Hollywood Church Rd, Clarkesville, GA 30523-3919,
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 10. However, Georgia voter registration records show that Betty Jane
May was assigned to House District 28 in error. Betty Jane May voted in the May 22, 2018
75.
John Butler, Jr. resides at 615 W. Glade Creek Rd., Clarkesville, GA 30523-4318,
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 10. However, Georgia voter registration records show that John Butler,
Jr. was assigned to House District 28 in error. John Butler, Jr. voted in the May 22, 2018
76.
3949, Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 10. However, Georgia voter registration records show that Marcus W.
-20-
Pickelsimer was assigned to House District 28 in error. Marcus W. Pickelsimer voted in the May
77.
30523, Habersham County. Exhibit “A” demonstrates that this address is within the boundaries
of Georgia House District 10. However, Georgia voter registration records show that
Christopher Nathaniel Woods was assigned to House District 28 in error. Christopher Nathaniel
78.
Thomas Hayne Cooper resides at 770 Hollywood Church Rd, Clarkesville, GA 30523-
3979, Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 10. However, Georgia voter registration records show that Thomas
Hayne Cooper was assigned to House District 28 in error. Thomas Hayne Cooper voted in the
79.
Margaret Helen Pollard resides at 155 Hollywood Church Rd, Clarkesville, GA 30523-
3914, Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 10. However, Georgia voter registration records show that Margaret
Helen Pollard was assigned to House District 28 in error. Margaret Helen Pollard voted in the
80.
Joshua Neil Jones resides at 231 Dry Fls, Clarkesville, GA 30523-3395, Habersham
County. Exhibit “A” demonstrates that this address is within the boundaries of Georgia House
-21-
District 10. However, Georgia voter registration records show that Joshua Neil Jones was
assigned to House District 28 in error. Joshua Neil Jones voted in the May 22, 2018 General
Primary Election.
81.
County. Exhibit “A” demonstrates that this address is within the boundaries of Georgia House
District 10. However, Georgia voter registration records show that Angela A. Young was
assigned to House District 28 in error. Angela A. Young voted in the May 22, 2018 General
Primary Election.
82.
James William Webb resides at 101 Tomahawk Dr, Clarkesville, GA 30523, Habersham
County. Exhibit “A” demonstrates that this address is within the boundaries of Georgia House
District 10. However, Georgia voter registration records show that James William Webb was
assigned to House District 28 in error. James William Webb voted in the May 22, 2018 General
Primary Election.
83.
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 10. However, Georgia voter registration records show that Karen
Holbrook Webb was assigned to House District 28 in error. Karen Holbrook Webb voted in the
-22-
84.
James C. Ferraro, Jr. resides at 212 Rockford Far, Rd., Clarkesville, 30523-8619,
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 10. However, Georgia voter registration records show that James C.
Ferraro, Jr. was assigned to House District 28 in error. James C. Ferraro, Jr. voted in the May
85.
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 10. However, Georgia voter registration records show that Keith D.
Ivester was assigned to House District 28 in error. Keith D. Ivester voted in the May 22, 2018
86.
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 10. However, Georgia voter registration records show that Darryl
Wayne Garrett was assigned to House District 28 in error. Darryl Wayne Garrett voted in the
87.
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 10. However, Georgia voter registration records show that Patricia
-23-
Stephens Garrett was assigned to House District 28 in error. Patricia Stephens Garrett voted in
88.
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 10. However, Georgia voter registration records show that Renee Hand
Morris was assigned to House District 28 in error. Renee Hand Morris voted in the May 22,
89.
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 10. However, Georgia voter registration records show that Sheila M.
Ferraro was assigned to House District 28 in error. Sheila M. Ferraro voted in the May 22, 2018
90.
David B. Franklin resides at 298 Grey Fox Trl, Clarkesville, GA 30523-3975, Habersham
County. Exhibit “A” demonstrates that this address is within the boundaries of Georgia House
District 10. However, Georgia voter registration records show that David B. Franklin was
assigned to House District 28 in error. David B. Franklin voted in the May 22, 2018 General
Primary Election.
91.
Tina Michelle Franklin resides at 298 Grey Fox Trl, Clarkesville, GA 30523-3975,
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
-24-
Georgia House District 10. However, Georgia voter registration records show that Tina Michelle
Franklin was assigned to House District 28 in error. Tina Michelle Franklin voted in the May
92.
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 10. However, Georgia voter registration records show that Donald N.
Gaultney was assigned to House District 28 in error. Donald N. Gaultney voted in the May 22,
93.
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 10. However, Georgia voter registration records show that Chester T.
Gragg was assigned to House District 28 in error. Chester T. Gragg voted in the May 22, 2018
94.
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 10. However, Georgia voter registration records show that Denise W.
Ivester was assigned to House District 28 in error. Denise W. Ivester voted in the May 22, 2018
-25-
95.
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 10. However, Georgia voter registration records show that Catherine B.
Simpson Wiles was assigned to House District 28 in error. Catherine B. Simpson Wiles voted in
96.
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 10. However, Georgia voter registration records show that Holly O.
Sparrow was assigned to House District 28 in error. Holly O. Sparrow voted in the May 22,
97.
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 10. However, Georgia voter registration records show that Michael D.
Wiles was assigned to House District 28 in error. Michael D. Wiles voted in the May 22, 2018
98.
Angela Simmons Butler resides at 615 W Glade Creek Rd, Clarkesville, GA 30523-4318,
Habersham County. Exhibit “A” demonstrates that this address is within the boundaries of
Georgia House District 10. However, Georgia voter registration records show that Angela
-26-
Simmons Butler was assigned to House District 28 in error. Angela Simmons Butler voted in the
99.
Vicki L. Glaze resides at 125 Akins Bridge Road, Eastanollee, GA 30538-1412, Franklin
County. Exhibit “A” demonstrates that this address is within the boundaries of Georgia House
District 28. However, Georgia voter registration records show that Angela Simmons Butler was
assigned to House District 32 in error. Angela Simmons Butler voted in the May 22, 2018
100.
Ben R. Glaze resides at 125 Akins Bridge Road, Eastanollee, GA 30538-1412, Franklin
County. Exhibit “A” demonstrates that this address is within the boundaries of Georgia House
District 28. However, Georgia voter registration records show that Ben R. Glaze was assigned to
House District 32 in error. Ben R. Glaze voted in the May 22, 2018 General Primary Election.
101.
Amory L. Hall resides at 130 Ellison Street, Maysville, GA 30558-1905, Jackson County.
Exhibit “A” demonstrates that this address is within the boundaries of Georgia House District 28.
However, Georgia voter registration records show that Amory L. Hall was assigned to House
District 31 in error. Amory L. Hall voted in the May 22, 2018 General Primary Election.
-27-
Voters Assigned to HD 32 that Live in HD 28
102.
County. Exhibit “A” demonstrates that this address is within the boundaries of Georgia House
District 28. However, Georgia voter registration records show that Susan E. Herremans was
assigned to House District 32 in error. Susan E. Herremans voted in the May 22, 2018 General
Primary Election.
103.
Stephens County. Exhibit “A” demonstrates that this address is within the boundaries of Georgia
House District 28. However, Georgia voter registration records show that Frank J. Herremans
was assigned to House District 32 in error. Frank J. Herremans voted in the May 22, 2018
104.
Jean L. Herron resides at 640 Griffin Road, Martin, GA 30557-2955, Stephens County.
Exhibit “A” demonstrates that this address is within the boundaries of Georgia House District 28.
However, Georgia voter registration records show that Jean L. Herron was assigned to House
District 32 in error. Jean L. Herron voted in the May 22, 2018 General Primary Election.
LEGAL ANALYSIS
105.
O.C.G.A. § 21-2-520 et seq. permits candidates to contest the result of primary elections
in Georgia.
-28-
106.
O.C.G.A. § 21-2-522 establishes that elections may be contested on one or more of the
following grounds:
(2) When the defendant is ineligible for the nomination or office in dispute;
(3) When illegal votes have been received or legal votes rejected at the polls sufficient to
(4) For any error in counting the votes or declaring the result of the primary or election,
(5) For any other cause which shows that another was the person legally nominated,
107.
O.C.G.A. § 21-2-527 establishes that a court has the power to declare an election invalid
108.
The Boards systematically assigned voters to the wrong State House districts.
109.
28 election. These irregularities caused illegal votes to be cast in the Election. Wrong district
assignments also caused voters residing in HD 28 to vote in the HD 10, 31, and HD 32 elections.
-29-
These irregularities disenfranchised HD 28 voters by denying them their right to vote in the
Election.
110.
31, and HD 32 as voters in these districts could not vote for their correct State House races.
Voters in these districts were forced to vote for the wrong candidates because they did not have
111.
Voters in HD 28, many of whom have stated that they would vote for Mr. Gasaway,
112.
Voters in districts other than HD 28 improperly voted in HD 28, directly effecting the
113.
At least 404 misassignments have been found, and at least 75 voters voted in the wrong
election.
114.
115.
At least 75 votes resulted from irregularities, when only 67 votes decided the Election.
These 75 votes are sufficient to change or place in doubt the result. Thus, the Election should be
-30-
Count II: Illegal Votes Cast in the Election
116.
The Boards systematically assigned voters to the wrong state house districts.
117.
28 election. These irregularities caused illegal votes to be cast in the Election. Wrong district
assignments also caused voters residing in HD 28 to vote in the HD 10, 31, and HD 32 elections.
These irregularities disenfranchised HD 28 voters by denying them their right to vote in the
118.
Thus, voters in HD 10, HD 28, HD 31, and HD 32 voted in the wrong election. These
119.
At least 404 misassignments have been found, and at least 75 voters voted in the wrong
120.
121.
At least 75 illegal votes were received, when only 67 votes decided the Election. These
illegal votes are sufficient to change or place in doubt the Election’s result. Thus, the Election
-31-
(a) The May 22, 2018 Republican Party General Primary Election for Georgia House
of Representatives District 28 be set aside and voided and a new election ordered;
(b) The Court order Habersham County Board of Elections and Registration, the
Stephens County Board of Elections and Registration, the Banks County Board of Elections and
Registration, the Franklin County Board of Elections and Registration, and the Jackson County
Board of Elections and Registration to correct the voter rolls by allocating voters to their correct
legislative districts;
(c) The Court award Gasaway reasonable attorneys’ fees, litigation expenses, and
other costs incurred by filing this Petition as permitted under O.C.G.A. § 21-2-529;
(d) The Court award Gasaway such other, further, and different relief as the Court
Jake Evans
Georgia Bar No. 797018
Russell Rogers
Georgia Bar No. 002278
THOMPSON HINE LLP
3560 Lenox Road, Suite 1600
Atlanta, Georgia 30326
(404) 541-2900 – Main
(404) 541-2905 – Facsimile
Attorneys for Petitioner Dan Gasaway
-32-
CERTIFICATE OF SERVICE FOR STATE ELECTION BOARD
This is to certify that on this date, pursuant to O.C.G.A. § 21-2-524(b), this Petition was
served on the Chairman of the State Election Board, Brian Kemp, by certified mail.
Jake Evans
Georgia Bar No. 797018
Russell Rogers
Georgia Bar No. 002278
THOMPSON HINE LLP
3560 Lenox Road, Suite 1600
Atlanta, Georgia 30326
(404) 541-2900 – Main
(404) 541-2905 – Facsimile
Attorneys for Petitioner Dan Gasaway
EXHIBIT A
EXHIBIT B
Errors By House District
010 (41)
R
RAAB
BUUN
N
028 (31)
031 (1)
032 (2)
008
010
010
028
028 010
010
028
028
028 028
028 028010
010
010
010
028
028
028
028
028 028
028 028
028
028
028
028
028
028
028
028
028028
028
028
028
028
028
H
HAAB
BEER
RSSH
HAAM
M
010
010
010010
010
010
010 010
010
010
010 S
S TT E
EPPH
HEEN
NSS
010
010
010
010
010
010
010
010
010
010
010
010
010
010 010
010
010
010
028
028
032
032
028
028
028
028
028
027
032
FF R
RAAN
NKK LL II N
N
B
BAAN
NKKS
S
031
031
031
M
MAAD
D II S
SOON
N
JJ A
ACCK
KSSO
ONN
EXHIBIT C
EXHIBIT “D”
House District 10 Voters that should be in House District 28
FIRST NAME MIDDLE NAME LAST NAME ADDRESS CITY STATE ZIP
Robert B. Hilton 1424 W Glade Creek Rd Clarkesville GA 30523-4314
Debra E. Wood 1350 Hollywood Church Rd Clarkesville GA 30523-3928
David Allen Wood 1350 Hollywood Church Rd Clarkesville GA 30523-3928
Betty Jane May 1273 Hollywood Church Rd Clarkesville GA 30523-3919
Lisa Michele Pickelsimer 845 Hollywood Church Rd Clarkesville GA 30523-3949
Marcus W. Pickelsimer 845 Hollywood Church Rd Clarkesville GA 30523-3949
Christopher Nathaniel Woods 840 Hollywood Church Rd Clarkesville GA 30523
Thomas Hayne Cooper 770 Hollywood Church Rd Clarkesville GA 30523-3979
Margaret Helen Pollard 155 Hollywood Church Rd Clarkesville GA 30523-3914
Joshua Neil Jones 231 Dry Fls Clarkesville GA 30523-3395
Angela A. Young 188 Dry Fls Clarkesville GA 30523-3338
James William Webb 101 Tomahawk Dr Clarkesville GA 30523
Karen Holbrook Webb 101 Tomahawk Dr Clarkesville GA 30523
Ronald Lamar Carroll 126 Jasmine Trl Clarkesville GA 30523
Keith D. Ivester 3517 Hollywood Hwy Clarkesville GA 30523-4871
Darryl Wayne Garrett 3151 Hollywood Hwy Clarkesville GA 30523-4812
Patricia Stephens Garrett 3151 Hollywood Hwy Clarkesville GA 30523-4812
Renee Hand Morris 3045 Hollywood Hwy Clarkesville GA 30523-4869
Flora Argen Hicks 2497 Hollywood Hwy Clarkesville GA 30523-4864
David B. Franklin 298 Grey Fox Trl Clarkesville GA 30523-3975
Tina Michelle Franklin 298 Grey Fox Trl Clarkesville GA 30523-3975
Angela Simmons Butler 615 W Glade Creek Rd Clarkesville GA 30523-4318
EXHIBIT E
EXHIBIT F
Dan Gasaway v. Brian Kemp et al.
Civil Action No. 2018-cv-306197
Fulton County Superior Court
Assigned to 32 should be 28 (2)
COUNTY CORRECT
ASSIGNED COUNTY
OF
RESIDENCE
FRANKLIN STEPHENS GLAZE BEN RICHARD 125 AKINS EASTANOLLEE
BRIDGE
RD
FRANKLIN STEPHENS GLAZE VICKI L 125 AKINS EASTANOLLEE
BRIDGE
RD
30535-
HABERSHAM HABERSHAM ALLEN SHERI LAINE 472 LINWOOD DR DEMOREST 5373
30535-
HABERSHAM HABERSHAM ANDERSEN JUSTIN WAYNE 435 LINWOOD DR DEMOREST 5369
30535-
HABERSHAM HABERSHAM ARRINGTON CAROL SUSAN 375 LINWOOD DR DEMOREST 5371
STERLING
MEADOWS 30535-
HABERSHAM HABERSHAM AUSBURN BRIAN L 312 CT DEMOREST 5196
STERLING
MEADOWS 30535-
HABERSHAM HABERSHAM AUSBURN KELLY L 312 CT DEMOREST 5196
STERLING
RYAN MEADOWS 30535-
HABERSHAM HABERSHAM AUSBURN SAMUEL ALEXANDER 312 CT DEMOREST 5196
STERLING
MEADOWS 30535-
HABERSHAM HABERSHAM BARNHILL BILLY LEWIS 378 CT DEMOREST 5196
HABERSHAM HABERSHAM BOWER PATRICIA G 564 MIDDLETON CLARKESVILLE 30523-
Dan Gasaway v. Brian Kemp et al.
Civil Action No. 2018-cv-306197
Fulton County Superior Court
PL 3368
HIGHWAY 30563-
HABERSHAM HABERSHAM CANTRELL OWEN E 4988 197 S MOUNT AIRY 2442
HIGHWAY 30563-
HABERSHAM HABERSHAM CANTRELL DONNA S 4988 197 S MOUNT AIRY 2442
TURNERVILLE
HABERSHAM HABERSHAM CANUP LADONNA SHARETT 254 CORNER CLARKESVILLE 30523
MIDDLETON 30523-
HABERSHAM HABERSHAM DEAN GEORGE CHANDLER 115 PL CLARKESVILLE 3317
MIDDLETON 30523-
HABERSHAM HABERSHAM DEAN LISA J 115 PL CLARKESVILLE 3317
30523-
HABERSHAM HABERSHAM DECKER HELEN M 139 MIDLAND DR CLARKESVILLE 3389
30523-
HABERSHAM HABERSHAM DECKER CLARENCE C JR 139 MIDLAND DR CLARKESVILLE 3389
STERLING
MEADOWS 30535-
HABERSHAM HABERSHAM DOVER CASEY AARON 253 CT DEMOREST 5195
STERLING
MEADOWS 30535-
HABERSHAM HABERSHAM DOVER ALICE CATES 253 CT DEMOREST 5195
30535-
HABERSHAM HABERSHAM GOSNELL KELLIE CARPENTER 299 ANSLEY RD DEMOREST 5104
30535-
HABERSHAM HABERSHAM GOSNELL BENJAMEN JOCK 299 ANSLEY RD DEMOREST 5104
HIGHWAY 30563-
HABERSHAM HABERSHAM HAMILTON JAMES G JR 4898 197 S MOUNT AIRY 2442
HIGHWAY 30563-
HABERSHAM HABERSHAM HAMILTON PAMELA C 4898 197 S MOUNT AIRY 2442
CHENOCETAH 30531-
HABERSHAM HABERSHAM HARRIS SHARON DIANNA 220 DR CORNELIA 3805
CHENOCETAH 30531-
HABERSHAM HABERSHAM HARRIS MARVIN RUSSELL 220 DR CORNELIA 3805
Dan Gasaway v. Brian Kemp et al.
Civil Action No. 2018-cv-306197
Fulton County Superior Court
ELDERBERRY 30535-
HABERSHAM HABERSHAM HARTRICK KATIE JOY 620 CT DEMOREST 5374
ELDERBERRY 30535-
HABERSHAM HABERSHAM HARTRICK RYAN NICHOLAS 620 CT DEMOREST 5374
STERLING
MEADOWS 30535-
HABERSHAM HABERSHAM KING BARBARA HARPER 321 CT DEMOREST 5196
STERLING
MEADOWS 30535-
HABERSHAM HABERSHAM KING KEVIN NELSON 321 CT DEMOREST 5196
30531-
HABERSHAM HABERSHAM MCCLELLON JOEY DALE 104 WILSON RD CORNELIA 5538
CHENOCETAH 30531-
HABERSHAM HABERSHAM MEALOR DUSTIN THOMAS 408 DR CORNELIA 3854
CHENOCETAH 30531-
HABERSHAM HABERSHAM MEALOR HOPE GREEN 408 DR CORNELIA 3854
30535-
HABERSHAM HABERSHAM MIKOWSKI KIMBERLY LEAH 393 LINWOOD DR DEMOREST 5371
CHENOCETAH 30531-
HABERSHAM HABERSHAM MILLER CHARLES M 386 DR CORNELIA 3807
STERLING
MEADOWS 30535-
HABERSHAM HABERSHAM POLLACK LYNDELL ROSE 378 CT DEMOREST 5196
30531-
HABERSHAM HABERSHAM SMITH MARIANNE J 420 WILSON RD CORNELIA 5935
30531-
HABERSHAM HABERSHAM SMITH RICHARD ALLEN 294 WILSON RD CORNELIA 5560
30531-
HABERSHAM HABERSHAM SMITH SARAH E 294 WILSON RD CORNELIA 5560
STERLING
MEADOWS 30535-
HABERSHAM HABERSHAM SQUIRES DAVID TERRELL 400 CT DEMOREST 5197
HABERSHAM HABERSHAM SQUIRES CATHY JUNE 400 STERLING DEMOREST 30535-
Dan Gasaway v. Brian Kemp et al.
Civil Action No. 2018-cv-306197
Fulton County Superior Court
MEADOWS 5197
CT
30535-
HABERSHAM HABERSHAM WARD JANA CELESTE 436 ANSLEY RD DEMOREST 5101
30531-
HABERSHAM HABERSHAM WILSON DORIS E 349 WILSON RD CORNELIA 5567
30535-
HABERSHAM HABERSHAM ALLEN Kale Brian 472 LINWOOD DR DEMOREST 5373