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ONCE UPON A TIME IN THE LAND OF SAVANNAH OR HOW NOT TO FILE A LAWSUIT I have been trying to figure out

t the time line of the initial events in this fiasco. I think I have a better grasp on it now and would like to share it with everyone. It seems screwy at best imagine that! I do apologize for this lengthy post, but I hope you find it worth reading. 05/27/10 Jackson's letter to Paula Deen contains nothing but praise for Ms. Paula & Uncle Bubba. This letter has been deemed by many, in their opinion, as Jackson's First Demand Letter. [See: Facebook Photo Library of Who Is Lisa T. Jackson?] One of the things that amazes me about this letter is that Jackson wants to have Uncle Bubba speak at the events she wants to spearhead. I thought, according to Jackson's allegations in her three Complaints, that she thought of Uncle Bubba as a racial-spewing-hate-filled-sexist-violently-drunken brute. Did she have a sudden mood swing or was she just being manipulative to get what she wanted, i.e., CEO of a new division of the Deen Empire? 08/19/10 Jackson's official resignation date from Uncle Bubba's [Jackson Depo. at Page 72; Lines 22-24] 10/08/10 Jackson?] EEOC Complaint filed by Jackson. [See: Facebook Photo Library of Who Is Lisa T.

11/24/10 Date is approximate based on Deen & Co.'s attorney who goes on to state that Jackson's attorney, ... came over to the undersigned's office to tell Patty Paul a partner of this law firm that if Ms. Jackson's demand of $1,000,000.00 was not paid, he and Ms. Jackson would be going to the press with reportedly derogatory information regarding Ms. Deen and her family within three (3) weeks. [See: Facebook Photo Library of Who Is Lisa T. Jackson?] [NOTE This would mean that Jackson either made an oral demand and/or a written demand we have not seen to Deen & Co. approximately three months after quitting and approximately six weeks after filing her EEOC Charge for $1 million thus giving Deen & Co. ample time to have received her EEOC Charge. IMO, this means Jackson and her attorney were already making threats to expose her allegations concerning derogatory information to the public from the very beginning. Thus, again IMO, money has been her motive from the get-go versus her public implications of being a sacrificial lamb of the people.] 12/00/10 Jackson and Sumerlin move to Atlanta, Georgia probably driving Jackson's Mercedes. [Jackson Depo. at Page 209; Lines 18-21 & Sumerlin Depo. at Page 124; Lines 9-11] 02/11/11 EEOC Pre-Determination Letter Jennifer Bessick, EEOC Investigator, opines, Uncle Bubba's appears to have provided a non-discriminatory reason for it's actions. Jackson is given until February 23, 2011 to provide evidence to support her claims and refute Uncle Bubba's claims. If no evidence is given than it would be recommended that Jackson's Charge be dismissed as no cause and she will receive a Dismissal and Notice of Rights in the mail. After receiving a Notice Jackson will have ninety (90) days to file in FEDERAL COURT. [See: Facebook Photo Library of Who Is Lisa T. Jackson?] 02/23/11 Deadline for Jackson to respond to EEOC. [NOTE: At this time, it is unknown if Jackson ever responded.]

01/31/12 Jackson's written Demand Letter for $1.25 million which also threatens to go to the New York Times. This letter has been construed by many as extortion or blackmail metaphorically speaking of course, in their opinions. [See: Facebook Photo Library of Who Is Lisa T. Jackson?] 02/06/12 Deadline for Deen & Co. to pay $1.25 million which Jackson will quietly accept. Again, how can Jackson publicly assert she is the voice for people who can't speak for themselves? This reminds me of song lyrics by Pink Floyd Money, it's a gas! Grab that cash with both hands and make a stash. [See: Facebook Photo Library of Who Is Lisa T. Jackson?] 03/05/12 Jackson's initial Complaint is filed with the Superior (State Court) in Chatham County, Savanna, Georgia. [Federal Court Docket #6, Exhibit 1]. According to Judge Moore in his Order [Federal Court Docket #36 dated 08/23/10 See: Below listed link.] In her initial Complaint Jackson specifically states her case is one for damages and injunctive relief arising out of personal injuries caused and perpetuated by Defendants in violation of Ms. Jackson's right under Georgia law. No where in this initial Complaint does Jackson mention her rights were violated under Federal law as she did in her EEOC Complaint and she does not bring ... any claim that she was discriminated against on the basis of her race, color, religion, sex or national origin. [For Initial Complaint entitled Original Lawsuit See: Facebook Photo Library of Who Is Lisa T. Jackson?] [NOTE: A person has the right to elect their remedy in that they can bring a lawsuit in State or Federal Court. It depends how you set forth the law and allegations in your complaint. Normally, electing which Court to file in when you can do either/or is a legal strategy. Jackson had obviously already filed her EEOC Complaint which alleged that her claims arose out of Federal Law, but had neither requested nor received her Notice of Right to Sue. Given the time line above, we can begin to assume why she filed in State Court versus Federal Court.] 03/08/12 As promised by Jackson? New York Times, Dining & Wine Section - What We Are Reading - The Village Voice: Paula Deen is back in the deep fryer. A lawsuit by a former manager at Uncle Bubba's Seafood and Oyster House, which Ms. Deen and her brother Bubba own, says the two used racial slurs at the restaurant and banned black employees from using the front entrance and a whites-only restroom. Ms. Deen's lawyer denies that. Patrick Ferrell [See: http://dinersjournal.blog.nytimes.com/2012/03/08what-were-reading-388/ and http://blogs.villagevoice.com/forkintheroad/2012/03/paula_deen_is_i.php@more ] 04/12/12 Notice of Appearance of Billips [Federal Court Docket #6, Exhibit 12] first filed in State Court proceedings. [Reviewed on PACER] Guess Jackson's first attorney needed a helping hand out of the pan and into the fire, IMO. 04/20/12 In State Court Jackson filed her Amended Complaint [Federal Court Docket #6, Exhibit 11] thirty-six days later. In the Amended Complaint Jackson was now stating that her claims arose .. under the Constitution and laws of the State of Georgia and the laws of the United States and claimed negligent failure to prevent sexual and racial harassment, gross negligence and negligence per se, intentional infliction of emotional distress, assault, battery, hostile work environment and racial discrimination in violation of the Civil Rights Act of 1866 (Yes, you read that correctly 1866), disparate treatment based on race in violation of the Civil Rights Act of 1866 (Um, yep there it is again), ratification and breach of contract. [See: Court's Order at link provided below.]

[NOTE: It is my understanding that there is currently no consensus that the Civil Rights Act of 1866 was meant to confer any legal benefits to white people.] 05/17/12 Deen & Company remove the case from State Court to Federal Court based on the fact that Jackson was now claiming Deen & Company had violated Federal laws as well. [Reviewed on PACER] 05/24/2012 Deen & Co. file their Answer [Federal Court Docket #12] and do put forth an argument that Jackson's sexual harassment claims should be dismissed because she failed to file an EEOC Charge under Title VII of the Civil Rights Act of 1964; that a Notice of Right to Sue had not been received; and that Jackson was barred from obtaining relief from employment actions that occurred more than 180 days prior to the EEOC Charge that was filed. [Reviewed on PACER] 06/13/12 Jackson's files a Motion to Remand to State Court. [Federal Court Docket #21]. Basically, this is a document wherein Jackson claims that her lawsuit should be heard in State Court, and NOT Federal Court. Deen & Company respond (basically) by pointing out that Jackson had used language and plead violations of law in her Amended Complaint that gave the Federal Court jurisdiction over the case. [Reviewed on PACER.] 08/03/12 Notice of Appearance of Billips for Federal Court. [Federal Court Docket #34]. Interestingly, this document is dated July 3, 2012, but not recorded as having been filed until August 3, 2012. [Reviewed on PACER] 08/10/12 Jackson is issued a Notice of Right to Sue by the EEOC. [See: Facebook Photo Library of Who Is Lisa T. Jackson?] Almost two years after filing with the EEOC and she suddenly feels the need to request her Notice of Right to Sue? 08/14/12 Interestingly, Deen & Co. file a Litigant's Bill of Rights (Standard Court requirement?) that basically states they neither want a mediation conference to attempt to settle nor do they want a binding or non-binding arbitration meeting to resolve this matter. In other words Paula Deen wants her day in Court! This also reminds me of the lyrics to the same song by Pink Floyd but this time from Paula's side, Money. Well, get back! I'm all right jack[son] keep your hands off of my stack! 08/16/12 Jackson's attorney receives the Notice of Right to Sue. [See: Facebook Photo Library of Who Is Lisa T. Jackson?] 08/23/12 Order by The Honorable William T. Moore, Jr. [Federal Court Docket #36 and See: Link below to Court's Order.] This where it get's very interesting, IMO. Judge Moore states that a defendant has 30 days to remove the initial complaint after service has been affected on all defendants. However, if an amended complaint is filed, the defendant then has 30 days from that date to remove to Federal Court, which Deen & Co. did. Judge Moore found that Jackson's initial Complaint left the distinct impression that it was drafted to specifically avoid Federal Court and that Jackson had gone out of her way to emphasize that her claims were based only on Georgia law. Because of this finding, Deen & Co. were not obligated to remove the initial Complaint to Federal Court within thirty days.

Judge Moore further analyzes Jackson's argument concerning moving the case back to State Court and in a footnote, he writes, The Court is not persuaded by any argument that the initial complaint was intended to allege a federal claim. For this to be the case, Plaintiff's complaint would be ineptly drafted at best or deceptively misleading at worst. The Court, however, will give Plaintiff the benefit of the doubt, avoiding any implication of either ineptitude or deception on Plaintiff's part. He also states, The absurdity of Plaintiff's argument comes into clearer focus when reviewing the amended complaint. Also, Judge Moore states, So, to now say that the initial complaint was removable because Defendants incorrectly identified the state claim as Title VII claims, which have never been part of this case simply defies logic and borders on the ludicrous. Jackson's Motion to Remand was DENIED and the case stayed in Federal Court. Basically, IMO and in a nutshell the Judge was telling Jackson, Nice try but I ain't buyin' no bridges in Arizona! . 11/09/12 Jackson files a Motion to Amend/Correct her Amended Complaint, stating she wants to add claims for which she filed an EEOC Charge and has received a Notice of Right to Sue. (Nice timing, right? Or did somebody finally crack open the book on Federal Procedures? Maybe that was Silla's job?) 11/27/12 Judge Moore enters an order that states, in part, The Court GRANTS plaintiff Lisa T. Jackson's unopposed motion as supplemented, to file her Second Amended Complaint. [NOTE: I have no idea why Deen & Co.'s attorney did not oppose the filing of the Second Amended Complaint. Maybe it's a matter of law? Strategy? Mistake?] 12/18/12 Deen & Co. file a Motion to Dismiss Certain Counts of Plaintiff's Second Amended Complaint and Motion to Strike Race-Based Allegations. [NOTE: Reviewed on PACER. This is a very long read, and if everybody wants it I will upload it.] As far as I can determine, the Court has made no ruling on the Motion to Dismiss. But I'm also going cross-eyed from looking at the Federal Court's Docket. Perhaps somebody who is using PACER could help me out and verify whether the Court has ruled on this matter? My opinion on this? I believe the Jackson and her first attorney were certain that Ms. Paula was going to a) fold as soon as she became aware that Jackson filed her EEOC Charge and failing that; b) that Deen & Co. would fold before the initial Complaint was filed. First rule of War Never under estimate your opponent. I also believe they were blinded by dollars signs and betting that Ms. Paula would be so frightened of public exposure that this case would NEVER go to trial. Guess maybe one could say that somebody was counting their chickens before they hatched? LINK TO COURT'S ORDER: Should follow this page just look down at choices below. As a disclaimer, this document cites where I found information to form my own opinion. I encourage everyone that is interested to read for themselves, decide from themselves and opine for themselves. I would also humbly suggest that each of us respect others' opinions whether we agree or not. Also, I will put it out there I will VERY STRONGLY defend The Honorable William T. Moore, Jr. He, above all parties in this case, should receive your utmost respect.