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ELECTRONICALLY FILED
6/8/2018 12:44 PM
01-CV-2018-902316.00
CIRCUIT COURT OF
JEFFERSON COUNTY, ALABAMA
ANNE-MARIE ADAMS, CLERK

IN THE CIRCUIT COURT OF JEFFERSON COUNTY


STATE OF ALABAMA

THE CITY OF ADAMSVILLE, )


ALABAMA, ON ITS BEHALF AND ON )
BEHALF OF ITS ELECTED ) Civil Action No.:
OFFICIALS AND EMPLOYEES, )
) CV-
Plaintiff, )
)
vs. )
)
TAMMI TAYLOR, and XYZ, being )
those persons who are responsible )
or who have participated in the acts )
complained of herein whose identity )
will be added when ascertained, )
)
Defendant. )

COMPLAINT

COME NOW, the Plaintiffs, and respectfully shows unto the Court as follows:

PARTIES

1. The City of Adamsville (City) is a duly incorporated municipality located in

Jefferson County, Alabama. The City has an elected City Council and Mayor and

employs individuals to carry out its lawful municipal purposes.

2. Tammi Taylor (Taylor) is over the age of nineteen (19) and a resident of

Adamsville, Alabama.

3. XYZ are those persons who are responsible or who have participated in

the acts complained of herein.

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4. This litigation is brought by the City on its own behalf and on behalf of its

elected officials and employees.

FACTS

1. Taylor has been a frequent critic of Adamsville for some years and as will

be set out herein, her conduct has grown increasingly disruptive, threatening and

harassing.

2. Sometime in early 2009, Taylor complained to the City Council of

Adamsville relating to speeding tickets given to her and her son. Specifically,

requesting the Mayor to do away with the tickets. The Mayor, Pam Palmer, refused.

3. Several months later, Taylor attending another Council meeting

demanding a sign on her street stating “Slow. Children Playing.”; however, since there

are already two (2) signs on her street, this request was refused.

4. Sometime thereafter, Taylor attends yet another Council meeting and

demands a stop sign on her street and one (1) was placed at her request.

5. Once again, Taylor attended another Council meeting and claimed that

there was garbage being thrown all over her yard and displayed on Facebook that the

City’s Public Works employees were ripping open bags and strewing the garbage in her

yard. Unbeknownst to Taylor, there were cameras on the garbage trucks and when

reviewed there was no depiction of any kind on the day Taylor claimed the City

employees threw garbage on her yard of any such thing. As a result, Mayor Palmer

informed her that the allegations were untrue and requested that she not post such

untruth on Facebook.

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6. During the election cycle for 2016, Taylor attempted to fill out the proper

paperwork to run for Mayor; however, as she failed to fill out an Economic Interest

statement, which is an absolute requirement. As a result, the Alabama Secretary of

State would not place her name on the ballot. Importantly, Taylor had been provided all

the necessary documents as well as an election handbook which clearly set out all

required filings to be properly placed on a ballot. Taylor, however, despite her failure to

comply blames the City.

7. In August, 2016, Mayor Palmer ran into Taylor and Taylor told the Mayor

that she was a Christian and that she loved the Mayor. The Mayor responded that, “No,

you don’t, you hate me.”, to which Taylor replied “Yes, I do.” This conversation took

place at Dan’s Printing in Adamsville.

Once outside Dan’s, Taylor reiterated to the Mayor that “I really do hate

you.”, explaining that the first time she met the Mayor at City Hall she asked the Mayor

to “fix” a ticket and the Mayor refused.

8. Taylor also uses social media to harass, intimidate and threaten. An

example from the summer of 2016 is the following post by her on her Facebook page:

“Our tax dollars are paying the public servant officials to


do absolutely nothing besides con, manipulate, lie, steal,
withhold info, all while collecting our tax dollars.”
(Emphasis supplied)

9. Sometime in late 2016, the City blocked Taylor from commenting or

posting on the City’s Facebook page due to the inciteful, harassing and belligerent

nature of her posts. As a result, in December, 2016, a day before the annual

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Adamsville Christmas Parade, Taylor either came to or called City Hall, was angry, and

demanded that Pam McPherson, a City employee, place Taylor back on the Facebook

page. The Mayor was at her place of business at the time and Taylor called her there

and demanded that she be allowed access to the City’s Facebook page. At some point,

according to the Mayor, Taylor stated “I ought to blow that bitch off that float”. This was

in reference to the Mayor riding on a float the next day in the parade.

A police report was filed concerning this incident. The threat was taken

seriously by the City to the extent that special needs individuals were not allowed to ride

on a special float and a sniper rode with the Mayor. The concern was also heightened

by Taylor posting on her Facebook page a few days before this incident about her

owning guns and having an assault weapon.

9. On February 6, 2017, Taylor had referred to the Mayor as a limp noodle.

On or about February 6, 2017, after the Mayor had been out of town for a few days,

there was a package at her home from Walmart containing angel hair pasta.

10. In January of 2018, Taylor posted on her Facebook a message which

included that Mayor Palmer is “VILE”, “DISGUSTING” and “UNFIT” and that “The mayor

is off her rocker if she thinks she can run our city as if she is Hitler. #thisisnotnorthkorea

#pamkimjongun”

11. Taylor also posted around this time that Mayor Palmer is a “snake” and a

“rat” and stated:

“You and nobody else can ever change my mind about


how vile and disgusting Pam Palmer is. Quite frankly,
you are wasting your time and breath trying to convince

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me otherwise.”

12. On January 25th of this year, Taylor posted:

… “Oh yeah! And get called a ‘FAKE B*$@!’ by the


mayor of Adamsville vile and vicious crony Rottweiler
Darby Adams.”

13. Taylor has included in a post that “This post right here proves how

crooked and untrustworthy Pam Palmer and Janna Gardner is.” Ms. Gardner is the City

Clerk.

14. Throughout this year, Taylor has posted false statements about the landfill

in Adamsville, which is regulated by a duly established and lawful solid waste authority,

to include disseminating false information about funds allegedly received by the City

and blaming the City for activities over which it has no control.

Taylor went so far as to post the following:

“I believe the main issue is not the volume Big Sky was
bringing in…but how they violated community zoning
laws to bring it in under our nose. It is all underhanded
and wrong. The people were not notified.”

Taylor further posting:

“I would say the problem is our corrupt city as well as


CITIZENS WHO KNEW WHAT WAS GOING ON AND
NEVER BLEW THE WHISTLE.”

15. On February 16th of this year, in connection with a public record request

Taylor made, the following was posted by her:

“From the looks of it all … there is definitely corruption.


We must continue to band together and hold these
criminals accountable for their actions.” (Emphasis
supplied)

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16. On February 17th of this year, Taylor posted that “Dealing with the open

corruption in Adamsville is work in itself.”

17. On February 19th of this year, Taylor posted the following:

“The same city officials who cheated them (referring to


City workers) out of their hard-earned coins … are the
same crooks running the City along with the shady
business that you see as a joke!”

The following post being in response to a comment from another

individual.

18. In one post on February 20th of this year, Taylor boasted that “We

FBI…SECRET SERVICE moms always get to the bottom of it.”

19. On March 2nd of this year, Taylor, in a post about an Adamsville Police

Officer’s injury, included the following:

“ROMANS 13:4 FOR HE IS GOD’S SERVANT FOR


YOUR GOOD IF YOU DO WRONG BE AFRAID, FOR
HE DOES NOT BARE THE SWORD IN VAIN FOR HE
IS THE SERVANT OF GOD AND AVENGER WHO
CARRIES OUT GOD’S WRATH ON THE
WRONGDOERS.”

20. On March 6th of this year, due to continual phone calling to City Hall by

Taylor, at least ten (10) calls from 10:30 AM to 4:00 PM, a police report was made.

Taylor would call and speak with either Pam McPherson, Amanda Morrow or Jennifer

Jones or Janna Gardner or would leave messages. All calls were harassing and

Taylor’s tone was belligerent and threatening. When Ms. Jones spoke with Taylor she

was so shaken by how aggressive and belligerent Taylor was that it affected her work

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performance for the rest of the day. This constant calling interferes with the City

employees to properly carry out their responsibilities.

21. On March 7th of this year, Taylor posted an article entitled “Political

Nepotism is Making Leaps and Bounds”, referring to the Mayor of New York and his

wife serving as an unpaid intern. According to Taylor:

“The unprecedented, unsalaried and, by all accounts


unofficial advisory post is also on full display at the City
of Adamsville…”

22. On March 10th of this year, Taylor posted the following:

“The Mayor & City Clerk get angry with you (the tax
paying citizen) ask them basic questions to hold and
keep them accountable. That is the true character/result
of a tyrannical government for running amuck.”

23. On March 11th of this year, in response to a post about the human waste

being sent to the landfill, Taylor suggested the following:

“Tell them to take it to the Mayor’s home. Let her get a


whiff of it since they think it’s so beneficial to have it in
our community.”

24. On or about March 11th of this year, again discussing the human waste

going to the landfill, Taylor posted in part the following:

“…THEY ARE ALL LYING!!! I look forward to the day to


have them all in prison for all the wrong and stress they
have brought onto our community and neighboring
communities. Everybody it is my mission and fulltime
job to see that every crooked person involved will pay
with PRISON TIME!

They just don’t treat people like they way they have
been treating us. Wring [sic], heartless and selfish led
by greed and love of money. PURE SICK!”

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“Yes this corruption runs DEEP! #DState”

25. On March 13th of this year, Taylor included in a post that the untruth that

John Cameron, the City’s former Public Works Director, was fired from this position and

that he lived in a house on property owned by the Mayor.

26. On March 14th of this year, Taylor posted that State Representative Juan

Dalynn Givan laughed “in our face when she was contacted” about the landfill issue and

therefore Taylor falsely posted:

“I figured out later that our Mayor, Pam Palmer,


campaigned for Givan and is a friend of our Mayor…so
figures why Givan laughed at us and said that not doing
anything.”

27. On March 19th of this year, Taylor posted that the Mayor and City Clerk

allowed a City Councilman to “ROB us of our PUBLIC FUNDS.”

28. Over the last several months, on numerous occasions, the Mayor has

been followed by a white van. On one occasion the Mayor was able to see the tag and

it matches the tag is registered to Taylor.

On one (1) occasion, when the Mayor was followed home, a person in the

vehicle stopped and informed the Mayor that she was going a little fast down the road

and that he was watching her. Behind the white vehicle was a pick-up truck and the

person in that vehicle slowed down and yelled at the Mayor “We have our eyes on you.”

29. On March 26th of this year, Taylor went to City Hall and asked Pam

McPherson if “Darby” was a City employee. Ms. McPherson responded she did not

think so and Taylor then asked Ms. Gardner who responded “No”, although will help out

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the City sometimes if needed. Taylor responded “I have videoed her driving a city car at

7:52 AM”; however, the individual Taylor thought was Darby was someone else who is a

City employee and was driving her own car to work. In addition, Taylor has posted that

she was following Darby while Darby was driving a City car, which is false.

30. After a recent Council Meeting attended by Taylor, she parked her vehicle

next to the Mayor’s and left a bag with feces next to the Mayor’s vehicle.

31. Taylor has followed a City Councilman demanding that he tell her what

happened during an Executive Session or demanding information.

32. Due to the constant harassment of the City employees, either through the

telephone or Taylor coming to City Hall, new locks and cameras have been added as

well as bulletproof glass at Pam McPherson’s window.

33. Recently, Taylor called City Hall and asked Pam McPherson in an

intimidating manner if she was afraid of her. Ms. McPherson was startled and is afraid.

34. Recently, Taylor is now representing she is acting with the City in

connection with her perceived issues with the landfill when she has no authority or

permission to represent, suggest or imply that she is acting on behalf of the City or its

elected officials.

35. The acts and conduct of Taylor alleged above is pervasive and continuing

in nature.

36. The acts and conduct of Taylor alleged above are intimidating, vengeful,

menacing, threatening and engaged in with the intent to harass or alarm.

37. Taylor’s statements as set out above amount to defamation regardless of

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the Plaintiffs’ status as public officials in that they are false and are intentionally made

with knowledge of their falsity and lack of truth and with a purposeful disregard of the

same. Moreover, the communications by Taylor are harassing and are made with the

intent to provoke.

38. The City and its employees have no adequate remedy at law due to the

continuing nature and pattern of Taylor’s conduct as alleged above.

39. There has been and will continue to be irreparable harm to the City, its

elected officials and employees if Taylor is not enjoined from the conduct and

communications set out above. The City does not have an adequate remedy at law as

due to the continuing nature and pattern of Taylor’s conduct and unless enjoined, Taylor

will continue to engage in the same unabated.

WHEREFORE, PREMISES CONSIDERED, the City respectfully prays that as

follows:

1. That the Court, after a hearing, enter a Preliminary Injunction enjoining the

Defendants and any individual, firm, partnership or corporation participating or acting in

concert with them from any or all of the following:

a. From contacting any employee or elected official of the City at City

Hall by telephone or by any forms of written communication.

b. From intentionally following any employee or elected official of the

City or directing anyone to do so by means of any vehicle.

c. Being present at City Hall unless with permission from the Mayor or

City Clerk and only with the City first arranging for adequate

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security.

d. From publishing in any manner or form any intentionally false,

fraudulent or defamatory statements about the City, its elected

officials or employees.

2. That the Court enter any other further or different relief to which the

Plaintiffs are entitled.

/s James S. Ward
JAMES S. WARD
Attorney for Plaintiffs

OF COUNSEL:
WARD & COOPER, LLC
2100 Southbridge Parkway, Suite 580
Birmingham, AL 35209
(205) 871-5404

DEFENDANT TO BE SERVED BY: SPECIAL PROCESS SERVER


Tammi Taylor
928 Longview Circle
Adamsville, Alabama 35005

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