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JEFFERSON CIRCUIT COURT DIVISION ____________ JUDGE _______________________

THOMAS D ARMISTEAD 1400 Rufer Ave. Louisville, KY 40204 VS. COMPLAINT DAVID JONES, JR. 1012 Alta Circle Louisville, KY 40205 *********



Comes the Plaintiff, THOMAS D ARMISTEAD, in person, and by counsel, and for his cause of action states as follows: 1. That on or about November 6, 2012, the Defendant, David Jones, Jr. was elected to serve on the Jefferson County Board of Education. 2. That the Plaintiff, Thomas D Armistead, is a concerned citizen and voter in District 2 of the Jefferson County Board of Education, the district won by the Defendant, David Jones, Jr. 3. That pursuant to KRS 160.180 section 2(g) attached hereto as Exhibit 1, the Defendant, David Jones, Jr. is ineligible to serve because of the following: a. Health Teacher, this is a company bought about a month ago by JCPS from Kosair Charities that provides on-line health service for parents of JCPS students. The

products are still provided by a company owned by Chrysalis Ventures in which Defendant has an active financial interest.

b. Straighterline, a company that provides on line educational services which will provide college degrees in support of the 55,000 degrees program endorsed by JCPS; and with Staighterline now affiliated with Jefferson Community and Technical College c. Humana. Major shareholder, on the Board, etc., provides health insurance for all 270,000 plus state employees, including JCPS employees; which provides millions of dollars of profit for Humana and David Jones, Jr. d. David Jones Jr. admitted for publication that eight companies of Chrysalis Ventures has in the past or will in the future provide products and/or services to students and parents for JCPS. e. Main Street Realty, Inc. names David Jones as its Director. Main Street Realty is the owner of 345 lots in the Brentwood Oldham Farms development worth $77,000.00 each, or a total of approximately $25,565,000. Land values remain high and desirable in Oldham County because of their school system being the best. If you buy and build in Brentwood, you know exactly what school you are going to. Defendant has twenty five million reasons to be against changing the current student assignment plan so higher socio-economic home buyers with school age children will continue to buy and build homes in Oldham County. 4. That the Jefferson Circuit Court has exclusive jurisdiction of Defendants eligibility.

Wherefore Plaintiff, THOMAS D ARMISTEAD, demands that the Defendant, DAVID JONES, JR., be declared ineligible to serve as a member of the Jefferson County Board of Education, and the office be declared vacant, his costs herein expended, attorney fees where allowed by law and all other relief to which he may appear entitled.

___________________________ TEDDY B. GORDON Attorney for Plaintiff 807 W. Market Street Louisville, KY 40202 (502) 585-3534

Plaintiff, Thomas D. Armistead, states that he has read the allegations of the foregoing Complaint and the statements contained herein are true and correct as he verily believes.

____________________________ THOMAS D. ARMISTEAD SUBSCRIBED AND SWORN to before me by Thomas D. Armistead, Plaintiff, on this 8th day of November, 2012. My commission expires:______________________________________.

___________________________________ NOTARY PUBLIC, State at Large, KY