1 TABLE OF CONTENTS

Table of contents……...…………………………………………………………………………………...1.
Venue and parties to the case plaintiff’s information .............................................................................. 2.
Defendants’ information ...................................................................................................................... 3.
Defendants’ information…………………………………………………………………………...4.

Statement of defendants individual and or official capacity……………………………………………5.

Statement establishing federal question jurisdiction ................................................................................ 6.
Statement of claim…………………………………………………………………………………….7.
Request for relief….………………………………………………………………………………...8.

Bill of costs…………………………..………………………………………………….…………………9.

Exhibits list …………………………………………………………………………………………….10.

Exhibit a. Amazon May 11, residency established…..………………………………….………….11.

Exhibit b. power bill….….…………………………………………………………………....12.

Exhibit c. Motions for Plaintiffs’ criminal trespassing case…………….......…13, 14, & 15.

Exhibit d. Police report May 29, 2023, arrest………………………………………………….….16, & 17.

Exhibit e. Police report August 12, 2023, arrest….…………………………………18, & 19.

Exhibit f. Entry of Dismissal case # ST-23-CR-1035 …………….……………………………………..20.

Exhibit f. Entry of dismissal case# ST-23-CR-1673……………….………………………….…….21.

Exhibit g. Statement of Fraud ……………………………………………………………….22. & 23.

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 UNITED STATES DISTRICT COURT
For the
Middle District of Georgia

Plaintiff: ) Case No. 3:24-CU-89____________

Carey Leneil Mccomas )
)
-V- )
Jury Trial: ____ YES _____ NO
Defendant(s) )
Unified Government of Athens Clarke County )
Mayor Kelly Girtz )
Athens Clarke County Police Department )
Chief of Police, Jerry Saulters )
Sargent, Jimmy King )
Officer, Caleb Cameron )
Officer, Stanley Denis )
Officer, Austin Falcon )

COMPLAINT FOR A CIVIL CASE

I. The Parties to This Complaint

THE PLAINTIFF(S)
Carey L. Mccomas
115 Beaver Ridge Dr
Winterville -Clarke County
GA 30683
762-347-8026
Cmccom13@gmail.com

THE DEFENDANT(S)

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 -DEFENDANTS-

Defendant No.1
A.C.C.U.G
Kelly Girtz
Mayor of Athens Clarke County Unified Government
Street 562 Pulaski St.
Athens- Clarke County
GA, zip 30601
Telephone# 706-613-3010
Email-Kelly.Girtz@accgov.com

Defendant No. 2
A.C.C.P.D
Jerry Saulters
Police Chief of the Athens Clarke County Police Department
Street 3035 Lexington Rd.
Athens- Clarke county
GA, zip 30605
Telephone# 762-400-7055
Email-Jerry.Saulters@accgov.com

Defendant No.3
Jimmy King
Sargent for the Athens Clarke County Police Department
Street 3035 Lexington Rd.
Athens-Clarke County
GA, zip 30605
Telephone# 762-400-7314
Email-Jimmy.King@accgov.com

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 -DEFENDANTS-

Defendant No.4
Caleb Cameron
Officer for the Athens Clarke County Police Department
Street 3035 Lexington Rd.
Athens- Clarke County
GA, zip 30605
Telephone# 762-400-7191
Email-Caleb.Cameron@accgov.com

Defendant No.5
Stanley Denis
Officer for the Athens Clarke County Police Department
Street 3035 Lexington Rd.
Athens-Clarke County
GA, zip 30605
Telephone# 762-400-7191
Email-Stanley.Denis@accgov.com

Defendant No. 6
Austin Falcon
Officer for the Athens Clarke County Police Department
Street 3035 Lexington Rd.
Athens- Clarke County
GA, zip 30605
Telephone# 762-400-7191
Email-Austin.Falcon@accgov.com

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 CAPACITAS

Comes now the plaintiff, Carey Mccomas, in propria persona, and

brings forth this action against defendant(s), The Unified
Government of Athens Clarke County herein after known as
(A.C.C.U.G), through its mayor KELLY GIRTZ in his official
capacity. The Athens Clarke County Police Department
(A.C.C.P.D), through its Chief of Police, JERRY SAULTERS, in
his official capacity. Sargent JIMMY KING in his individual and
official capacity. Officer STANLEY DENIS in his individual and
official capacity. Officer CALEB CAMERON in his individual and
official capacity. Officer AUSTIN FALCON in his official capacity.
The defendants are subject to the laws of the State of Georgia and
bound by oath to defend the rights of the people guaranteed by the
United States Constitution. The A.C.C.P.D enforces policies of the
A.C.C.U.G who are required to conform to the corporate charter
through which they render their service to the people.

AUTHORITY

The requirements for federal question jurisdiction under 28 U.S.C

1331 are satisfied. The A.C.C.U.G is liable for damages pursuant to
42 U.S.C 1983 based on its policy practice, customs, and usage
under color of state law.

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 STATEMENT OF CLAIM

The above-mentioned officers have violated 18 U.S.C 241 and 18

U.S.C 242. The A.C.C.P.D through its sworn officers conspired to
and did deprive the Plaintiff of his property, shown in exhibits (a) &
(b) without due process under the color of law, by enforcing a city
ban policy pursuant to O.C.G.A 16 - 7 - 21, which states only a
verified authorized representative of the owner, the owner, or
occupant has the authority to allege a trespass violation. The actions
of the A.C.C.P.D on May 15, 2023, fully intended to deprive the
plaintiff of his property without due process. The officers failed to
satisfy the particulars concerning verification of the authorized
agent of the owner pursuant to O.C.G.A 16 - 7 - 21. The A.C.C.P.D
is obligated to provide equal protection of the law. Had the officers
conducted a simple investigation, to verify some basic necessary
elements of O.C.G.A 16 - 7 - 21, the facts and fictions would have
become known. Officers stated on the record that the plaintiff was a
homeless trespasser. Said statement was and is currently a
defamation of the plaintiff’s character. It is a matter of fact that the
plaintiff and his family was forced from their home at 150 Pinecrest
Lodge Road, by the A.C.C.P.D, who handed the plaintiffs home and
possessions over to a man named (CLARENCE DAKE), who had
no interest in, or authority over the property, in fact CLARENCE
DAKE is a criminal who was out on parole after a 10 year prison
stent for armed robbery, which makes him the property of the state.
The A.C.C.P.D never properly identified CLARENCE DAKE. The
plaintiff being banned from his home caused him on two occasions
to be falsely imprisoned, and mis labeled as a trespasser. The
Plaintiff appearing pro se filed motions to dismiss the trespassing
charges, exhibit (c). Said motions relied upon the same evidence
offered to the A.C.C.P.D by the plaintiff on May 15, 2023, to
Officers Stanley Denis, Caleb Cameron, and Sargent Jimmy King

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before they banished him. Evidence that he offered them once more
on May 29, 2023, then again to Officer Austin Falcon on August 12,
2023. To clarify, Caleb Cameron, Stanley Denis and Jimmy King
participated in the initial unlawful banishment of the Plaintiff on
May 15, 2023, then on May 29, 2023, exhibit (d). Stanley Denis and
Caleb Cameron arrested the Plaintiff for trespassing “after the
unconstitutional notice was given”. Exhibit (e) shows Then on
August 12, 2023, Austin Falcon arrested the plaintiff for trespassing.
Again, the Plaintiffs’ proofs were ignored when Sargent Jimmy
King arrived on scene. Once again King gave orders that exceeded
his authority, and did not adhere to the Law O.C.G.A. 16 - 7 – 21 as
stated previously. Officer Falcon had the opportunity to honor his
oath, Falcon viewed the Plaintiffs evidence but ignored it and
proceeded with the arrest. However, Falcon did mention the
Plaintiffs proof in his police report. Based on the motions filed by
the Plaintiff in response to the trespassing allegations the charges
were subsequently dismissed by the City Prosecutors on October 3,
2023, exhibit(f). Thus, the A.C.C.P.D nor CLARENCE DAKE had
the authority to ban the plaintiff. It was on May 2, 2024, that the
fraudulent activities of CLARENCE DAKE were stated in the
Magistrate Court of Athens Clarke County, State of Georgia, in civil
action MC-01-CV-DP-24-550, exhibit (g). The afore-mentioned
officers through the A.C.C.P.D who receiving orders from the
A.C.C.U.G, are in violation of their oaths to defend the Constitution,
and the A.C.C.U.G through its policies are in violation of the
corporate charter through which it exists.

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 RELIEF

The plaintiff is suing the defendants for $745,500.00 in

compensatory damages, and asks the court to consider punitive
damages for the officers’ actions which exceeded their jurisdiction,
causing the plaintiffs loss of his 4th, 5th, 6th, and 14th, amendment
rights, and for the tortuous act of intentional infliction of emotional
distress caused by the armed takeover of his real and personal
property, for kidnapping, false imprisonment, theft and the
defamation of his character.

Carey Mccomas,

Pro Se Litigant

Phone# 762-347-8026

115 Beaver Ridge Drive,

Winterville GA, 30683

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 BILL OF COSTS

$1,800.00 per month x 24

$1250 legal fees per frivolous trespassing case x2

For time and money spent on fixing the problems caused by the A.C.C.P.D:
Homelessness, Job loss, Viewable defamation of character that has affected the
Plaintiffs ability to conduct business efficiently, for the restriction of the Plaintiffs
movements.

$1000 per day for seven hundred days, which is the amount of time that will
have potentially lapsed since the unconstitutional banishment of the Plaintiff on May
15, 2023, up to the date of the decision in this case. It is impossible to know the
extent of the Plaintiffs’ losses. Time cannot be regained. Before the A.C.C.P.D did
what they did, the Plaintiff had a home that was paid for, a good-paying job, and a
business that was growing daily. The people that are supposed to serve and protect
the rights of the people arrested the Plaintiff in front of his family, having no idea
who the man was that called them. Any reasonable person could see that Clarence
Dake was not a property manager. In Gates v. The City of Atlanta the Jury awarded
Mr. Gates $150,000.00 for falsely arresting him for trespassing. He was waiting for
his children in a parking lot. The officers had no authority to arrest Gates. The
difference between the Gates case and this case is that Gates was only arrested one
time, and did not lose his home. The total has been thoroughly assessed. The people
deserve thorough and equal protection of the law. Arrogance and ignorance are
unacceptable.

____________________________________________________________

Total- $745,500.00

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 Exhibits

Exhibits a. & b. are proof of occupation.

a. Receipt from Amazon May 11, 2023

b. Receipt from Georgia Power May 15, 2023

c. Plaintiffs’ motions to dismiss trespassing charges.

Exhibits d. & e. are the police reports regarding the plaintiffs’ arrest.

d. Police report for arrest on May 29, 2023

e. Police report for arrest on August 12, 2023

f. Entry of dismissal

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