IN THE SUPERIOR COURT OF CHATHAM COUNTY

STATE OF GEORGIA

BACARRA MAULDIN,

Plaintiff,
Civil Action File No:
v.
JURY TRIAL DEMANDED
CHATHAM AREA TRANSIT AUTHORITY
and TABITHA ODELL,

Defendants.

PLAINTIFF’S EMERGENCY MOTION FOR PRELIMINARY INJUNCTION

COME NOW Plaintiff Bacarra Mauldin (“Plaintiff” or “Ms. Mauldin”), pursuant to

O.C.G.A. § 9-11-65, and respectfully moves this Court on an emergency basis to enter a

Preliminary Injunction against Defendant Chatham County Transit Authority (“Defendant CAT”)

to enjoin Defendant CAT from taking any measures to replace Ms. Mauldin as the Chief Executive

Officer (“CEO”) of Defendant CAT and to reinstate Ms. Mauldin to her position as CEO until

such time that a Court determines whether her termination by Defendant CAT was lawful. In

support of this motion, Plaintiff refers the Court to her Complaint for Damages and Equitable

Relief, and her Brief in Support of Motion for Emergency Preliminary Injunction, filed herewith.

This Court has authority to provide expedited relief on Plaintiff’s Emergency Motion for

Preliminary Injunction (the “Motion”). Uniform Superior Court Rule 6.7 provides that:

Upon written notice and good cause shown, the assigned judge may shorten or
waive the time requirement applicable to emergency motions, except motions for
summary judgment, or grant an immediate hearing on any matter requiring such
expedited procedure. The motion shall set forth in detail the necessity for such
expedited procedure.

1
 As set forth at length in the accompanying brief, there is a real threat of immediate and

irreparable harm to Plaintiff from Defendant CAT’s unlawful termination of her employment and

any subsequent efforts to replace her as CEO of Defendant CAT. There is good cause for this

Court to act on an expedited basis to address the threat of irreparable harm to Plaintiff.

Plaintiff has established in the contemporaneously filed documents that the equities weigh

in her favor for the entry of the emergency preliminary injunction, because there is a real threat of

irreparable harm to her if the injunction is not granted; there is no prejudice to Defendant CAT if

it is granted; Plaintiff has a likelihood of winning on the merits at trial, and an injunction would

not disserve, and in fact would serve, the public interest.

WHEREFORE Plaintiff respectfully requests that this Court enter a preliminary injunction

enjoining Defendant CAT from taking any measures to replace Plaintiff as the CEO of CAT, and

until such time that Ms. Mauldin’s claims are adjudicated on their merits, reinstate Plaintiff to her

position as CEO of Defendant CAT, so as to avoid irreparable injury to Plaintiff.

Respectfully submitted this 9th day of February, 2021.

/s/ Edward D. Buckley

Edward D. Buckley
Georgia Bar No. 092750
edbuckley@buckleybeal.com
Ashley Wilson Clark
Georgia Bar No. 771512
awilsonclark@buckleybeal.com
Rudi Julius
Georgia Bar No. 605298
rjulius@buckleybeal.com

BUCKEY BEAL, LLP

600 Peachtree Street NE
Suite 3900
Atlanta, Georgia 30308
Telephone: (404) 781-1100
Facsimile: (404) 781-1101
Counsel for Plaintiff