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    Pam Touchard Supplemental Initial Disclosures

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    Cory Johnson
    This document provides supplemental initial disclosures in a case between plaintiff Pam Touchard and defendants George County Mississippi School District et al. It discloses that the plaintiff has claims for damages as outlined in the complaint. It also lists over 100 potential witnesses with discoverable information, including students, school district employees, and state education department officials. The document was respectfully submitted by the plaintiff's attorney and certifies service to counsel of record.

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    © All Rights Reserved
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    Pam Touchard Supplemental Initial Disclosures

    Uploaded by

    Cory Johnson
    86 views3 pages
    This document provides supplemental initial disclosures in a case between plaintiff Pam Touchard and defendants George County Mississippi School District et al. It discloses that the plaintiff has claims for damages as outlined in the complaint. It also lists over 100 potential witnesses with discoverable information, including students, school district employees, and state education department officials. The document was respectfully submitted by the plaintiff's attorney and certifies service to counsel of record.

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    Pam Touchard Supplemental Initial Disclosures

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    This document provides supplemental initial disclosures in a case between plaintiff Pam Touchard and defendants George County Mississippi School District et al. It discloses that the plaintiff has claims for damages as outlined in the complaint. It also lists over 100 potential witnesses with discoverable information, including students, school district employees, and state education department officials. The document was respectfully submitted by the plaintiff's attorney and certifies service to counsel of record.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    86 views3 pages

    Pam Touchard Supplemental Initial Disclosures

    Uploaded by

    Cory Johnson
    This document provides supplemental initial disclosures in a case between plaintiff Pam Touchard and defendants George County Mississippi School District et al. It discloses that the plaintiff has claims for damages as outlined in the complaint. It also lists over 100 potential witnesses with discoverable information, including students, school district employees, and state education department officials. The document was respectfully submitted by the plaintiff's attorney and certifies service to counsel of record.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    of 3

    Case 1:21-cv-00168-TBM-RPM Document 33-1 Filed 12/09/22 Page 1 of 3

    IN THE UNITED STATES DISTRICT COURT


    FOR THE SOUTHERN DISTRICT OF MISSISSIPPI
    SOUTHERN DIVISION

    PAM TOUCHARD PLAINTIFF

    V. CAUSE: 1:21 cv 168-TBM-RPM

    GEORGE COUNTY, MISSISSIPPI SCHOOL DISTRICT, et.al. DEFENDANTS

    PLAINTIFF PAM TOUCHARD SUPPLEMENTAL INITIAL DISCLOSURES

    COMES NOW the Plaintiff Pam Touchard and provides these supplements to those initial
    disclosures filed previously, as follows:

    1. Plaintiff has claims for DAMAGES as set forth in the Complaint, as well as other claims that
    may be discovered during the course of this cause which the laws hold the Defendants liable
    and responsible in an amount to be determined by a jury. Further disclosure will be
    supplemented upon further receipt and development of the case.

    2. Names of persons now know to Plaintiff with discoverable information. Discovery is ongoing
    and other persons may become discoverable and possible witnesses:

    a. Pam Touchard
    b. Bayleigh Loving – student that took tests for others
    c. Dr. Jo Ann Malone – MS State Department of Education Asst. State Superintendent
    d. Brian McGarity – MS State Dept. of Education Safe and Orderly Schools Director
    e. Barkley Henderson – George County School Board member
    f. Wendell Fallon – George County School Board member
    g. Derrick Gentry – George County School Board member
    h. Jessie Ludgood – George County School Board member
    i. Mike Steede – Geroge County School Board member
    j. Allison Jordan – Food Service personnel, George County School District
    k. Becky Howell – Secretary, George County School District
    l. Brenda Denmark – Payroll, George County School District
    m. Natasha Henderson – Business Officer, George County School District
    Case 1:21-cv-00168-TBM-RPM Document 33-1 Filed 12/09/22 Page 2 of 3

    n. Debra Joiner – Principal, George County School District


    o. Joshua Nobles – Technician, George County School District
    p. Lanitra Rice – Counselor, George County School District
    q. Tanya Beech – Federal Programs, George County School District
    r. Pam McClendon – MS Association of Educators
    s. Jennifer Mathis – Test Administrator, George County School District
    t. Wanda Dunnam – Teacher, George County School District
    u. Kiley Hughes – Asst. Superintendent, George County School District
    v. Susan Moore – Secretary, George County School District
    w. Leona O’Neal – Teacher, George County School District
    x. Wade Whitney – Teacher, George County School District
    y. Phyllis McDonald – Teacher, George County School District
    z. Jennifer Mathis – Asst. Principal, George County School District
    aa. Stephanie Long – Cheer Sponsor, Teacher, George County School District
    bb. June Josey – Payroll Clerk, George County School District
    cc. Lonnie Mathis - – Teacher, George County School District
    dd. Sidney Taylor – Teacher, George County School District
    ee. Maria Clanton – Teacher, George County School District
    ff. Mikey Howard – Teacher, George County School District
    gg. Megan Mason – Teacher, George County School District
    hh. Billie Tillery - Teacher, George County School District
    ii. Leslie Shivers – Auditor for the Geroge County School District
    jj. Jeff Mathis – CTE Director, George County School District
    kk. Matt Caldwell – Athletic Director, George County School District
    ll. Kristin Davis – Teacher, George County School District
    mm. Dr. Paula Vanderford – Chief Accountability Officer, MS Dept. of Education
    nn. Pam Loving – Parent of Baleigh Loving
    oo. Al Hilman – Chief SRO
    pp. Chelynn Crawford – mother who took test home for her daughter Carly

    RESPECTFULLY SUBMITTED, this the 8th day of November, 2022.

    Pam Touchard
    By: /s/ Bobby Moak
    Bobby Moak MSB 9915

    Law Office of Bobby Moak, P.C.


    P. O. Box 242
    Bogue Chitto, MS 39629
    [email protected]
    601-734-2566
    Cell: 601-668-4194
    Case 1:21-cv-00168-TBM-RPM Document 33-1 Filed 12/09/22 Page 3 of 3

    CERTIFICATE OF SERVICE

    This is to certify that I have served via electronic mail a true and correct copy of the above and
    foregoing document to all counsel of record.

    This the 8th day of November, 2022.

    /s/ Bobby Moak


    Bobby Moak

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