Terry D.Jackson, P.C.

Trial Lawyers

tcrry(a)tcrryjacksonlaw.com

April 11, 2023

Via Federal Express Tracking No. 7718 1384 5549, Email chanccllor(w,usg.cdu
& 1st Class U.S. Mail
Dr. Sonny Perdue, Chancellor
Board of Regents of the University System of Georgia
270 Washington Street, S.W.
Atlanta, GA 30334

Via Federal Express Tracking No. 7718 1370 2911, Email wade.damron(tl)doas.ga.gov
& 1st Class U.S. Mail
Wade Damron, Director Risk Management Services Division
Georgia Department of Administrative Services
200 Piedmont Avenue SE, Suite 1220 West Tower
Atlanta, GA 30334

Via Federal Express Tracking No. 7718 1375 5742, Email ccarr(£1)law.ga.gov
& P 1 Class U.S. Mail
The Honorable Christopher M. Carr, Attorney General
State of Georgia
40 Capitol Square, S.W.
Atlanta, GA 30334

Ante Litem Notice Pursuant to the Georgia Tort Claims Act, O.C.G.A. § 50-21-26

Re: Claimant: Dave Willock, Wrongful Death

Claimant and Biological Father of Devin Alex Willock &
On Behalf of the Estate of Devin Alex Willock

Date: January 15, 2023, Approximately 2:45 a.m.

(See Exhibit 1, Incident Report)

Wrongful Death of Devin Willock on January 15, 2023,

(See Exhibit 2, Death Certificate Devin Alex Willock)

600 Edgewood Avenue, S.E.

Atlanta, GA 30312
p 404.659.2400 If 404.659.2414
www.tcrryjacksonlaw.com
Dr. Sonny Perdue, Chancellor
Wade Damron, Director Risk Management Services Division
The Honorable Christopher M. Carr, Attorney General
April 1 1, 2023
Page 2 of 10

Location: Collision on 15 January 2023

Clarke County, GA
930 Barnett Shoals Road, Athens, GA

See Exhibit I, Incident Report

Amount Demanded: $1,000,000.00 (One Million Dollars), for the Wrongful

Death of Devin Alex Willock by Dave Willock on behalf of
himself and Sharlene Willock

$1,000,000.00 (One Million Dollars), for the Claims of the

Personal Administrator of the Estate of Devin Alex Willock
by Dave Willock on behalf of the Court Appointed
Personal Administrator of The Estate of
Devin Alex Willock

Total Demand of $2,000,000.00 (Two Million Dollars)

Dear Chancellor Perdue, Mt. Damron & Atty. Gen. Carr:

My name is Terry Jackson, and along with William Stiles and M. Gino Brogdon Sr. we
represent Dave Willock. A personal administrator has not yet been appointed for Devin
Willock's Estate, but this ante litem notice is presented on its behalf too as the appointment of
the Estate's personal administrator is pending in the Clarke County Probate Court.

Devin Willock died without a spouse or children, born or in utero, and his parents Dave
and Sharlene Willock are the sole heirs of his Estate and the wrongful death claimants for his
death under Georgia law. We do not represent Sharlene Willock, but there is only one death
claim under Georgia law, one set of Estate claims, and this notice will protect her right of
recovery too.

The purpose of this letter is to perfect a required statutory ante !item notice as required by
the Georgia Tort Claims Act at O.C.G.A. § 50-21-26.

This notice of claim, ante !item notice, under O.C.G.A. § 50-21-26 states to the extent of
the claimants' knowledge and belief and as may be practicable under the circumstances-
regarding the personal injuries and resulting death of Devin Alex Willock (hereinafter "Devin")
brought by Dave Willock on his behalf and his wife for the death of Devin. This notice is also
provided on behalf of the Court Appointed Personal Administrator of the Estate of Devin Alex
Willock for the Estate's claims, for the personal administrator of that Estate who has yet to be
appointed. Mr. & Mrs. Willock are sole heirs of the Estate. Again, we do not represent Mrs.
Willock, but this ante litem notice is presented to protect the interest of both parents in the wrongful
death claim under Georgia law, and the Estate's claims.
Dr. Sonny Perdue, Chancellor
Wade Damron, Director Risk Management Services Division
The Honorable Christopher M. Carr, Attorney General
April 11, 2023
Page 3 of 10

Description of the Incident Causing Injuries:

On January 15, 2023 at approximately 2:45 a.m. Devin Willock was a backseat passenger
in a vehicle operated by Chandler Louise LeCroy. Ms. LeCroy was a W-2 employee of the
University of Georgia (hereinafter "UGA").

Ms. LeCroy was provided as a permissive driver a Ford Expedition for her use by her
supervisors/agents and/or employees of the University of Georgia Athletic Association, Inc.
(hereinafter "UGAAA"). The purpose of the UGAAA and UGA providing her the vehicle for the
weekend was to drive coaches, football recruits and players to National Championship
Celebration sites and/or recruiting sites, activities on the 131'\ 14th and 15th of January. LeCroy
was instructed to keep the vehicle the entire weekend, and to be on call that weekend to serve
coaches, recruits, and players as needed during the Championship Celebrations that weekend.

Ms. LeCroy was told and instructed by agents and employees of UGA and UGAAA prior
to January 13th that her weekend was not her own, and that she and other recruiting analysts' sole
purpose that weekend would be providing transportation to recruits and players for Celebration
and recruiting activities. LeCroy and other analysts were told that they would be driving and
entertaining recruits and players until the National Championship Celebrations and recruiting
weekend ended on Sunday, January 15, 2023 in the evening, or on Monday, January 16, 2023
when all recruits left Athens, Georgia.

Written, verbal, text and email messages will demonstrate that instruction or purpose set
by the UGAAA and UGA for the vehicle assigned to LeCroy that weekend.

LeCroy was told where her "vehicle" provided by UGA and UGAAA for her use that
weekend was located, where the keys or fobs to her assigned vehicle would be located, and that
she was to keep her vehicle until all recruiting and Celebration activities ended that weekend.
The instructions or purpose provided to Ms. LeCroy by UGA and UGAAA agents and
employees for her to keep the keys or fobs all weekend were standard instructions provided to
LeCroy and other recruiting analysts who drove recruits around and entertained them in Athens
during football recruiting weekends.

LeCroy and other Recruiting Analysts attended Celebrations at various sites in Athens,
and alcohol was present and provided to her by UGAAA, and other recruiting analysts and
attendees, recruits, and players who attended those UGA and UGAAA Celebration and recruiting
events. LeCroy and other analysts consumed alcohol, and drove their assigned recruits, players,
and coaching staff members to and from various Celebration/recruiting sites as the analysts were
directed to that weekend.
Dr. Sonny Perdue, Chancellor
Wade Damron, Director Risk Management Services Division
The Honorable Christopher M. Carr, Attorney General
April I I, 2023
Page 4 of 10

One of the analysts, Ms. Victoria "Tory" Bowles, was asked by a coaching staff member
for the keys to her assigned vehicle on Saturday evening January 14th, and she provided her keys
or fobs to the UGAAA staff member so he could drive the recruit around campus for the rest of
the recruiting visit. Ms. Bowles then obtained a ride with Ms. LeCroy from the recruiting site
where she left the coach and recruit assigned to Bowles for recruiting purposes that day.

Bowles and LeCroy were asked, and they agreed to accompany players and recruits to
several Athens locations to celebrate, which was their assigned purpose that weekend, before
they agreed to meet players and recruits at Toppers, an adult entertainment site in Downtown
Athens.

The Toppers club was full of UGA players including those who gave statements to
Athens police describing that the club was full of UGA players, and there were also recruits there
at the club and other sites. The Celebration for the twice National Champions continued until the
early morning hours of Sunday, January 15, 2023.

Twice champs, awesome! Go Dawgs! !

Several players approached LeCroy and Bowles before leaving the strip club and
suggested that they go to Waffle House. Devin Willock and Warren McClendon asked LeCroy
for a ride to the Waffle House, and she agreed as directed by her supervisors.

LeCroy, her passengers, and the vehicle operated by Jal en Carter and his passenger
Taniya Pierce left downtown Athens, GA at approximately 2:39 a.m. after spending several
hours drinking and celebrating the National Championship at Toppers strip club, and other
Athens locations with other UGA athletes and recruits.

Video and media accounts, including the police investigative :file, show that LeCroy and
Jalen Carter sped through downtown Athens and ultimately onto Barnett Shoals Road where they
stopped at the :first Waffle House, and were told by its personnel that they would only accept
single ticket orders. LeCroy met Carter in the parking lot as he pulled into the Waffle House
behind her, and she told him that they should go further down Barnett Shoals to a second Waffle
House where LeCroy could pay for everyone on a single ticket.

Both vehicles (LeCroy's and Carter's) were shown racing close to each other on videos
obtained by the Athens Clarke County police in its investigation.

Enroute Carter and LeCroy raced each other to their common destination at the second
Waffle House further down on Barnett Shoals Road, reaching speeds exceeding 100 mph, before
LeCroy lost control of her vehicle while racing Carter around the curve, killing Devin Willock
and herself in the process. A horrible end to a night of a historic Celebration and recruiting
weekend.
Dr. Sonny Perdue, Chancellor
Wade Damron, Director Risk Management Services Division
The Honorable Christopher M. Carr, Attorney General
April 11, 2023 .
Page 5 of 10

The collision occurred approximately six (6) minutes after leaving downtown Athens,
and less than a mile from the Waffle House, their final destination.

Ms. LeCroy'sjudgment was substantially impaired by alcohol at the time of the collision,
as she was street racing with Jalen Carter. At the time of the crash the ACM (airbag control
module) computer on LeCroy' s vehicle shows that she was traveling in excess of 104 mph in the
five seconds before the crash. The Georgia Crime Lab toxicology report shows that her blood
alcohol level was .197 (more than double the legal limit), and she and others were drinking at
Toppers, a strip club, in downtown Athens. LeCroy consumed alcohol at various UGAAA sites
and Celebration locations on January 14, 2023 before the crash-as did other attendees at those
Celebration sites. Alcohol supplied by the UGAAA caterers to attendees.

Prior to January 13, 2023 the supervisors of LeCroy had actual knowledge that she had a
history of speeding tickets, including one in the fall of 2022 where she was speeding in Morgan
County and her UGAAA supervisor was in the vehicle with her when she got the ticket. This
Morgan County super-speeder ticket was reported within the Athletic Association to supervisors
ofLeCroy and others, UGA and UGAAA supervisors knew about the ticket, and the UGAAA
police liaison or "fixer" Bryant Gantt attempted to intercede on her behalf to get the ticket
reduced in Morgan County. But, Morgan County Court personnel declined to reduce the ticket
due to LeCroy's past driving history for excessive speeding tickets.

UGA and UGAAA also admitted to the media that their agents and employees pulled or
checked LeCroy's driving records prior to January of 2023 and were aware of her history of
excessive speeding in vehicles prior to hiring her, and after hiring her. Yet LeCroy continued to
be entrusted with vehicles to carry out the purposes of UGA and the UGAAA. LeCroy was a
permissive driver of the vehicle leased by the UGAAA and UGA at the time of the crash, given
permission to drive it for purposes of attending the Celebration and recruiting activities with
recruits, players, and coaches on the 13th, 14th and 15th of January.

To be clear, UGA and UGAAA agents and employees negligently entrusted a vehicle to
LeCroy. Likewise, UGA and UGAAA agents and employees negligently hired, supervised,
trained and retained Le Croy.

Devin Willock was consciously aware of LeCroy's excessive speed and an impending
collision in the moments prior to his death. The vehicle LeCroy was driving first hit the sidewalk
curbing deflating one of her tires, she then hit tree limbs, a power pole, a parking lot light pole,
more trees, and finally hit an apartment building that resulted in Devin being ejected out of the
driver's side rear window above the rear wheel well or from the rear tailgate window of the
Expedition. Devin Willock was fatally wound as a result of the head and other injuries sustained
in the crash including the injuries as he hit the vehicle components and was ejected onto the
sidewalk in the parking lot of the apartment building that the Expedition hit before it came to a
rest.
Dr. Sonny Perdue, Chancellor
Wade Damron, Director Risk Management Services Division
The Honorable Christopher M. Carr, Attorney Genera!
April 11, 2023
Page 6 of IO

The UGAAA, and their agents and employees, and Ms. LeCroy will be sued separately
from the Board of Regents, as the UGAAA has charitable immunity under State law subject to
its waiver by its purchase of insurance, and it also waives its immunity for the negligent hiring,
entrustment of a vehicle, supervision, training and retention of Ms. LeCroy. The UGAAA and
UGA do not have sovereign immunity for the conduct of Ms. LeCroy, and negligent, reckless,
wilful, wanton and consciously indifferent conduct of the agents and employees of UGA and the
UGAAA that were aware of her checkered driving history yet entrusted a vehicle to her for the
UGAAA's purposes that weekend.

LeCroy's negligent, negligent per se, wilful, wanton, reckless, deliberately indifferent,
and consciously indifferent conduct includes violations of O.C.G.A. §§ 40-6-180, 40-6-181, 40-
6-168, 40-6-390, 40-6-391, 40-6-393, and 40-6-394.

We will also seek attorneys' fees and costs under both O.C.G.A. §§ 13-6-11 and/or 9-11-
68 if this ante litem notice demand is not accepted for the tort claims act claims. Mr. Willock will
be entitled to his fees and costs upon proper service of the Rule 68 demand after suit is filed in
this matter in which there is bad faith in the underlying collision and where there is no bona fide
dispute to liability or damages under the Tort Claims Act.

This ante /item notice provided to you complies with Georgia Tort Claims Act at
O.C.G.A. S0-21-26(a){S){A-F) including:

(A) The name of the state government entity, the acts or omissions of which arc
asserted as the basis of the claim:

Board of Regents of the University System of Georgia

(B) The time of the transaction or occurrence out of which the loss arose:

January 15, 2023, at approximately 2:45 a.m.

See Exhibit I, Incident Report

(C) The place of the transaction or occurrence:

930 Barnett Shoals Road, Athens, GA

Clarke County, Georgia

See Exhibit I, Incident Report

Dr. Sonny Perdue, Chancellor
Wade Damron, Director Risk Management Services Division
The Honorable Christopher M. Carr, Attorney General
April 11, 2023
Page 7 of 10

(D) The nature of the loss suffered:

Mr. Dave Willock, individually, and on behalf of his wife seeks recovery for the wrongful
death of their son, the full value of Devin's life, as provided by O.C.G.A. §§ 51-4-1, 51-4-4, 19-
7-1 ( c) et seq. and interpreting caselaw.

Mr. Dave Willock on behalf of the Court Appointed Personal Administrator of Devin's
Estate, seeks recovery of Devin's last funeral, burial, medical expenses and his physical and mental
pain and suffering arising out of his injuries in the collision before death as provided by Georgia
law. O.C.G.A. § 51-4-5 and interpreting case law. Devin was consciously, patently aware of an
impending collision with the sidewalk, trees, poles, and apartment building and suffered conscious
shock, mental apprehension, and mental and physical pain and suffering pain prior to his death.

(E) The amount of the loss claimed:

$1,000,000.00 (one million dollars, U.S.) for the wrongful death claim of the parents as
provided by O.C.G.A. § 51-4-1, 51-4-2 et seq. See also O.C.G.A. § 50-21-29(b)(l).

$1,000,000.00 ( one million dollars, U.S.) for the claims of the Estate of Devin Willock by
the Court Appointed Personal Administrator for Devin's Estate, for all claims it is entitled to
recover in law as set out by O.C.G.A. § 51-4-5(b) including last funeral/burial, medical, and pre-
death mental and physical pain and suffering of Devin Willock. See O.C.G.A. § 50-21-29(b)(l).

Total Demand, $2,000,000.00 (two million dollars, U.S.) for the Georgia Tort Claims
Act claims of the claimants. Sec O.C.G.A. § 50-21-29(b)(l). This ante litem notice will not
include any claims against the UGAAA, Chandler LeCroy's Estate and agents and employees of
UGA and the UGAAA for claims against those individuals under 42 U.S.C. §§ 1983 et seq.
including claims for attorneys' fees, costs for LeCroy's and her supervisors' reckless, wilful,
wanton, consciously indifferent, and deliberately indifferent conduct in street racing with Jalen
Carter in her UGA and UGAAA provided vehicle while her judgment was substantially impaired
by alcohol.

Again, this ante litem notice amount shall not include resolution of any 1983 claims
against any other employee for their supervision, entrustment, training, and retention of LeCroy
showing deliberate indifference to the consequences. This ante !item notice only includes claims
against the Board of Regents as an entity. It will take more than $2,000,000 to resolve the
claimants' 1983 claims against the individual actors, and the UGAAA.

(F) The acts or omissions which caused the loss.

LeCroy's negligent, negligent per se, wilful, wanton, reckless, deliberately indifferent,
and consciously indifferent conduct includes violations of O.C.G.A. §§ 40-6-180, 40-6-181, 40-
6-168, 40-6-390, 40-6-391, 40-6-393, and 40-6-394.
Dr. Sonny Perdue, Chancellor
Wade Damron, Director Risk Management Services Division
The Honorable Christopher M. Carr, Attorney General
April 11, 2023
Page 8 of 10

The conduct of her supervisors with actual knowledge of her pattern of speeding in
vehicles, including trying to fix tickets for her so that she could continue to drive recruits,
players, family members of recruits and players, and coaches in UGAAA provided vehicles as
directed by her supervisors including at the time of this collision shows negligent entrustment,
supervision, training, hiring, and wilful, reckless, wanton, and consciously indifferent conduct to
the consequences in this matter.

We have presented claims against the Board of Regents waiving its immunity under
Georgia law and the Tort Claims Act that are presently known, and that may be discovered as
additional evidence is revealed in discovery by the plaintiff claimants' counsel as discovery
proceeds once suit is filed.

42 U.S.C. §§ 1981, 1983 ct seq. claims against individual employee &

Claims Against the Athletic Association

Ms. LeCroy acted recklessly, wilfully, wantonly, with conscious and deliberate
indifference to the consequences while operating a vehicle while impaired by alcohol, a blood
alcohol level of .197 at her death due to her leaving the strip club less than 10 minutes earlier.

As the State's attorneys know, the § 1983 claims against individual employees are not
subject to ante litem notice requirements.

The claims against LeCroy and her supervisors, individually, for the § 1983 claims are
not included in the amount claimed for the Tort Claims Act claims in this notice that are capped
at $2,000,000 as set out above: It will take substantially more than $2,000,000 to settle the §
1983 claims against the individual actors for their reckless, deliberately indifferent conduct
resulting in the death of Devin Willock. The death and Estate claims against the individual actors
can be resolved by the DOAS, but it will be for more than the Tort Claims Act caps against the
Board of Regents as a state agency.

The state has $30,000,000.00 in coverage for vehicles owned, hired, etc. by it for use by
it or its agents and employees including but not limited to the policies identified at Exhibit 3,
Policy Summary. The State of course has a $3,000,000 self-retention tort fund for its vehicles
too, as provided by the DOAS.

The 42 U.S.C. § 1983 et seq. claims for an impaired driver, street racing, is reckless,
wilful, wanton and deliberately indifferent conduct for which there is no cap or limitation in law.
The same is true of her supervisors who knew of her pattern of poor driving and "partying" but
provided her a vehicle for the UGAAA's purposes the weekend of January 13, 2023 to entertain
and transport recruits, their families, and players.
Dr. Sonny Perdue, Chancellor
Wade Damron, Director Risk Management Services Division
The Honorable Christopher M. Carr, Attorney General
April 11, 2023
Page 9 of 10

Supervisors providing keys, etc. to recruiting assistants for the purpose of entertaining
players and recruits over the Championship weekend is clear, but UGA denying those facts in the
media after the events is poor form at best. Public comments by the UGA Athletic Director,
supervisors and administrators diminishing their role in this incident and blaming LeCroy does
not lead the way, and it is less than expected. Admit your mistakes, take your medicine, and
move on as best you can in the wake of this tragedy-that is truth and leadership.

The UGAAA is liable separate and distinct from Ms. LeCroy, the other individual actors,
and the Board of Regents. The UGAAA's charitable immunity is waived as provided by law and
its negligence in entrusting, permitting LeCroy to operate its vehicle that weekend, and
negligently supervising her use and training her for the UGAAA's purpose to entertain and
transport players and recruits the Celebration weekend is conduct for which it is liable.

Conclusion

Mr. Willock believes, and the evidence shows that this incident is a clear liability,
horrific damages collision resulting in the death of Devin Willock.

The value of the death and Estate claims easily exceed $30,000,000.00 but unfortunately,
we are cabined by the damages caps in the Georgia Tort Claims Act for claims against the Board
of Regents, limiting damages against the Board of Regents to $2,000,000 for this incident. This
ante litem notice will only extinguish the Tort Claims Act Claims against the Board of Regents.

This notice will not release the 42 U.S.C. § 1983 et seq. claims against Ms. LeCroy and
her supervisors for their negligent hiring, supervision, entrustment, training and retention claims
showing reckless, deliberate indifference in this matter unless there is a negotiated release for the
claims against her Estate and the supervisors responsible for LeCroy's use of the vehicle. Nor
will this notice extinguish any claims against the UGAAA as a nonprofit entity separate from the
Board of Regents.

LeCroy and other "recruiting analysts" or young, attractive women were used to entertain
and drive recruits and players around Athens in rented luxury SUVs as she was directed, the
purpose provided her during the Championship weekend Celebrations. That purpose or
direction given to the analysts may have served the UGAAA's purposes for the Celebration and
recruiting activities that weekend, but serving that purpose did not end well for the Willock
family or the LeCroy and Bowles families. LeCroy, Bowles and others were simply following
the purpose of the UGAAA that weekend as stated to them.

It is fortunate that neither Carter, his passenger, or other UGA students on their way
home from or to the same Waffle House were not killed during this alcohol fueled street race to a
Waffle House to feed a group of hungry players and recruits. This case is one that merits the full
$2,000,000 damages resolution under the Tort Claims Act, without dispute, for the claims
presented against the Board of Regents only. See O.C.G.A. § 50-21-29(b).
Dr. Sonny Perdue, Chancellor
Wade Damron, Director Risk Management Services Division
The Honorable Christopher M. Carr, Attorney General
April 11, 2023
Page 10 of 10

We look forward to your response accepting this ante litem notice demand as set out in
the Georgia Tort Claims Act.

Again, so it is clear, this ante litem notice does not include nor shall it act as a release of
any 42 U.S.C. §§ 1981, 1983 et seq. claims against LeCroy and other individuals in their
individual capacities, only the Board of Regents will be given a release.

This notice, if accepted, will not release any claims against the UGAAA by Mr. Willock
or the Estate either. It is a separate entity and a separate demand on it will resolve claims against
it.

If you have any questions about this ante litem notice, do not hesitate to contact me.

TDJ/klh

cc: Ron Boyter (Via Email rboJ1ter(!!}law.ga.go1,~

Scott Bailey (Via Email SBailev@/111[/jJOwellhailev.com)
Mike Raeber (Via Email n1raeber(a),11go.edu)
Will Lawler (Via Email wfowler@l,11ga.edu)
William E. Stiles (Via Email sti!es@westifeslaw.com)
M. Gino Brogdon (Via Email wginob@.gmail.com)

Enclosures: Exhibit 1, Incident Report

Exhibit 2, Willock Death Certificate
Exhibit 3, Insurance Policy Summary
EXHIBIT 1
 Page 1 of 3
Agency Case Number Agency NCIC No. County Date Rec. by DOT
202301150041 0290100 CLARKE 1/17/2023

Date
1/15/2023
I
Estimated Crash
Time
02:45
Date
111512023
Dispatch
cl
I
Total Number of
Vehicles
2
-I
Injuries
I
Fatalities
2
I
2
Inside City Of
Athens

Road of At Its Intersection STROUD RD

BARNETT SHOALS RD Osuppl. To Original?
Occurence With
0Miles D North D East
Not At Its
Intersection But 0Feet D South D West Of D Private Property?
Latitude (Y)
(Fonnat:
33.932028
00 00000
Longitude (X)
(Form at)
-83.347726
00 00000
□ Hit And Run?

IY'.J Driver lt:_J Driver

Unit#
□ Ped
LAST NAME
LECROY
FIRST
CHANDLER
MIDDLE
LOUISE
Unit#
□ Ped
LAST NAME FIRST MIDDLE

1 □ Bike Address 1083 S YOW MILL RD

2 □ Bike Address
GZ] Susp At Fault D Susp At Fault
City State Zip DOB City State Zip DOB
TOCCOA GA 30577 6/8/1998
Driver's License No Class State Country Driver's License No Class State Country
058721565 CLASS C GA UNITED STATES
Insurance Co. Policy No.
SELF INSURED
I Telephone No.
7062991572
Insurance Co. Policy No.
10124132CA
I Telephone No.
SELF INSURED STATE AUTO INSURANCE CO
Year Make Model Year Make Model
2021 FORD EXPEDITION 2017 FORD TRANSIT VAN T150
VIN Vehicle Color VIN Vehicle Color
VEHICLE Black NM0LS7E78H 1300216 Wt1ite
Tag# State County Year Tag# State County Year
FP118517 IL 2023 CTG1185 GA POLK 2023
Trailer Tag # State County Year Trailer Tag # State County Year

D Same as Driver Owner's Last Name First Middle D Same as Driver Owner's Last Name First Middle
EAN HOLDING Superior Air Managem Inc
Address Address
1424 N BELT ST 230 FLOYD DR
City State Zip City State Zip
BELLEVILLE IL ATHENS GA 30607

□
62226
Removed By· BARRETT'S TOWING D Request GZ] List Removed By: DRIVER Request Oust
Alcohol Test:
No

First Harmful Event:

!Type:
INot Tested
!
Results:
None Given
!
Most Harmful Event:
Drug Test:
No
!Type: I Results·
Operator/Ped Cond:
Alcohol Test:
No

First Harmful Event:

!Type:
INot Tested
1
Results:
None Given

Most Harmful Event:

!Drug Test:
No

Operator/Ped Cond:
!Results:

Curb Tree Unknown Motor Vehicle In Motion Tree Not Drinking

; uperator Factors: Exceeding Speed Limit, Other Operator Factors: No Contributing Factors

Vehicle Factors: No Contributing Factors Roadway Factors: No Contributing Factors Vehicle Factors· No Contributing Factors Roadway Factors: No Contributing Factors

Direction of Travel: Vehicle Maneuver: Non-Motor Maneuver: Direction of Travel· Vehicle Maneuver: Non-Motor Maneuver:
South Negotiating A Curve North Parked

Vehicle Class: Vehicle Type: Vision Obscured: Vehicle Class: Vehicle Type: Vision Obscured:
Privately Owned Sports Utility Vehicle {SUV) Not Obscured Privately Owned Passenger Car Not Obscured

Number of Occupants· Area of Initial Contact: Damage to Vehicle· Number of Occupants: Area of Initial Contact: Damage to Vehicle-
4 Front End Disabling Damage Front End Minor Damage

Road Composition: Road Character· Road Composition: Road Character:

Black Top Straight on Grade Black Top S\raigh! and Level

Number of Lanes: 5 Posted Speed: 40 Work Zone: None Number of Lanes· Posted Speed: Work Zone· None

Traffic Control: Lanes Device Inoperative: D Yes GZ] No Traffic Control: No Control Present Device Inoperative: D Yes GZ] No
Citation Information: Citation Information:
Citation# O.C.GA § Citation# O.C.GA§
Citation# O.C.GA § Citation# O.C.GA§
Citation# O.C.GA § Citation# O.C.GA§
COMMERCIAL MOTOR VEHICLES ONLY COMMERCIAL MOTOR VEHICLES ONLY
Carrier Name Carrier Name
Address City State Zip Address City State Zip

U.S. D.O.T. # No. of Axles G.V.W.R U.S. D.0.T. # No. of Axles G.V.W.R

Cargo Body Type Vehicle Config. D Interstate Fed. Reportable Cargo Body Type Vehicle Config. D Interstate Fed. Reportable
D Intrastate 0Yes □ No 01ntrastate 0Yes 0No

C.DL? 0Yes □ No
C.D.L. Suspended? 0Yes □ No C.D.L.? 0Yes □ No
C.D.L. Suspended? OYes 0No

Vehicle Placarded? 0Yes □ No

Hazardous Materials? 0Yes □ No
Vehicle Placarded? 0Yes □ No Hazardous Materials? OYes ONo

Hazmat Released? 0Yes No

If YES: Name or 4 Digit Number from Diamond or Box:
□ Hazmat Released? 0Yes No
If YES: Name or 4 Digit Number from Diamond or Box:
□
One Digit Number from Bottom of Diamond. One Digit Number from Bottom of Diamond:
[ 7 Ran Off Road [ 7 Down Hill Runaway I 7 Cargo Loss or Shift I l Separation of Units I 7 Ran Off Road f 7 Down HIii Runaway f l Cargo Loss or Shift I I Separation of Units
CDO 1-52J 107117)
Exhibit 1 - Page 1 of 3
 P ag e 2 of 3

-----
C O L LI S IO N F IE L D S

NARRATIVE

V1 was traveling southbound on Barnett Shoals Road prior to Stroud Road. V1 failed to negotiate a left curve, resulting in the vehicle striking a curb with its front passenger tire and leaving the
roadway on the west shoulder. While on the west shoulder, V1 struck a GA Power Pole and another utility pole cutting them in half. The vehicle continued south on the shoulder where it struck a
tree with its rear passenger quarter panel and caused it to begin rotating clockwise where it struck another tree with its driver's side. This caused the vehicle to rotate counter-clockwise prior to
achieving final rest against an apartment building located at 930 Barnett Shoals Road. 01 was transported to PARMC where she was pronounced deceased. The front passenger of the vehicle
sustained a laceration in the middle of his head. The passenger was transported via ambulance to Piedmont Athens Regional for said injuries. The passenger in the rear driver's side of the vehicle
was ejected from th
.... Auto-Generated by Import Service from Additional Remarks ....
e vehicle. The rear driver-side passenger died at the scene of the collision. The passenger on the rear right side of the vehicle sustained multiple internal injuries and a concussion in the collision.
The passenger was transported to Piedmont Athens Regional via ambulance for said injuries. V2 was a parked vehicle facing northbound in the parking lot of 930 Barnett Shoals Road in front of
apartment 1310. The vehicle was struck in the D pillar on top of the vehicle. The owner of the vehicle was notified and given a case card and information on how to receive the report. The
investigation is ongoing. On 1/15/2023 at approximately 02:45 I was dispatched to Barnett Shoals Rd and Stroud Rd in reference to an accident with injuries. When I arrived on scene, I saw a
large power pole cut in half and wiring laid across the road. A witness was standing on the left-hand side of the road yelling to me that the vehicle was at the bottom of the hill. I located a vehicle
against an apartment building. When I got to the vehicle, I saw a male laying facedown on the sidewalk who was deceased. A female was sitting next to the vehicle with lacerations to her face. I
advised her not to move until help arrived and asked her if there was anyone else in the vehicle. She told me there was still someone in the driver's seat. Other officers on scene attempted to locate
a pulse on the female driver. A male was standing on the sidewalk at the top of the hill in a white sweatshirt with blood on it and a noticeable laceration the forehead but otherwise alert. I asked him
if he was in the vehicle and he told me he was and there were three other people in the car with him. I positively identified him as Warren Mcclendon. Mcclendon told me he and his friends who he
named as Chandler and Devin but could not remember the third passenger's name were all leaving downtown and heading to Waffle House. He advised that he was in the front passenger seat and
did not know what happened. Mcclendon told me he looked down at his phone for a moment before the crash occurred. He could not recall how fast the vehicle was traveling. Traffic was notified
and responded to the scene. This concluded my involvement in the investigation. On January 15th 2023 at approximately 0245 officers were dispatched to Barnett Shoals and Stroud Road for a
possible motor vehicle accident. I arrived on scene and block some of Barnett Shoals due to power lines being down. Once to the crash I observed a male identified as Devin Willock outside of the
vehicle laying on the sidewalk face down. Willock appeared to have been ejected from the vehicle. A female was laying beside him with EMS. I assisted in placing a neck brace on the female and
then loading her into an ambulance. The female identified as Victoria Bowles was taken to the hospital. Once Bowles was loaded I went back to the crash site and observed the fire department
conducting CPR on a female identified as Chandler Lecroy. Lecroy was loaded into the ambulance and I drove it to Piedmont. CPR was continued by myself and staff until the doctor pronounced
Lecroy deceased. I returned to the scene of the crash to help with holding the scene for traffic to conduct their investigation. After traffic unit gathered their information I help load Willock into the
corners van. This was my involvement of the incident. My axon was on during this investigation. I arrived on scene and witnessed the fire department providing life saving aid to a female. She was
laying next to the vehicle. I assisted EMS with getting her onto a backboard and then onto a stretcher. I escorted the EMS truck to PARMC. I assisted EMS with transporting the female into the
hospital. I returned to the hospital and obtained the phone numbers for Victoria Bowels and Warren Mcclendon. I was informed that Bowels had a fractured spine, fractured ribs, a lacerated kidney
and a concussion. Mcclendon had a small laceration to his head. My time on scene was recorded on AXON.

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PROPERTY DAMAGE INFORMATION

(;1)01-:i2J(t17/17)
Exhibit 1 - Page 2 of 3
 Page 3 of 3
Damage Other Than Vehicle: Owner:

WITNESS INFORMATION

Name (Last, First) Address City State Zip Code Telephone Number

OCCUPANT INFORMATION

Name (Last, First): LECROY, CHANDLER Address: 1083 S YOW MILL RD TOCCOA, GA 30577

Age: Sex: Unit# Position: Safety Eq: Ejected: Extricated: Air Bag: Injury: Taken for Treatment:
24 Female 1 Front Seat-Left Side Lap and Shoulder Belt Used Not Ejected Yes Deployed Multiple Fatal Injury (K) Yes

Injured Taken To: By: EMS Notified Time: EMS Arrival Time: Hospital Arrival Time:
Piedmont Athens Regional Ambulance 01/15/2023 02:48 01/15/2023 02:54 01/15/2023 03:28
Name (Last, First): MCCLENDON, WARREN Address: 246 WILLOW POND WY BRUNSWICK, GA 31525

Age: Sex: Unit# Position: Safety Eq: Ejected: Extricated: Air Bag: Injury: Taken for Treatment:
2 21 Male 1 Front Seat-Right Side Lap and Shoulder Belt Used Not Ejected No Deployed Multiple S~~pecte.d Minor or Yes

Injured Taken To: By: EMS Notified Time: EMS Arrival Time: Hospital Arrival Time:
Piedmont Athens Regional Ambulance 01/15/2023 02:48 01/15/2023 02:54 01/15/2023 03:28
Name (Last, First): WILLOCK, DEVIN Address: 325 WILLOW ST, 127 ATHENS, GA 30601

Age: Sex: Unit# Position: Safety Eq: Ejected: Extricated: Air Bag: Injury: Taken for Treatment:
3 20 Male Rear Seat-Left Side None Used Totally Ejected No Deployed Multiple Fatal Injury (K) No

Injured Taken To: By: EMS Notified Time: EMS Arrival Time: Hospital Arrival Time:

Name (Last, First): BOWLES, VICTORIA Address: 105 PRINCETON MILL RD ATHENS, GA 30606

Age: Sex: Unit# Position: Safety Eq: Ejected: Extricated: Air Bag: Injury: Taken for Treatment:
4 26 Female 1 Rear Seat-Right Side None Used Not Ejected No Deployed Multiple S~7pecte.d Minor or Yes

Injured Taken To: By: EMS Notified Time: EMS Arrival Time: Hospital Arrival Time:
Piedmont Athens Regional Ambulance 01/15/2023 02:48 01/15/2023 02:54 01/15/2023 03:28
Name (Last, First): Address:

Age: Sex: Unit# Position: Safety Eq: Ejected: Extricated: Air Bag: Injury: Taken for Treatment:
5 2 Front Seat-Left Side

Injured Taken To: By: EMS Arrival Time: Hospital Arrival Time:

Photos Taken: □ Yes [Z]No By: Officer Note: If collision resulted In a fatality, please send prompt notification to the
GDOT Crash Reporting Unit via either email at GeorglaFARS@dot.ga.gov or Fax at
(404) 635-2963,
Report By: Agency: Report Date: Checked By: Date Checked:

TROTTER, JAMES Athens-Clarke County Police Department 01/15/2023 00:00 Butt, John 1/15/2023

CllOT-;;ZJ (t171t 7) [Ptintvrl: 11tw202J I 88<d7<>UI \/ 1//. Exhibit·1111111,/P1age11,3'l,·(jfR~(///f/\f, l ,,r. 935 l nitcd ,..,,, S/;, 11/1111/11, (,'. f ./1/3/6-15911
EXHIBIT 2
 GEORGIA DEATH CERTIFICATE
State Fila Number 2023GA000003663
1. DECEDENrS LEGAL FULL NAME (First, Middle, Last) 11 a. IF FEMALE, ENTER LAST NAME AT BIRTH 12. SEX I2a. DATE OF DEATH (Mo., Day, Year)
DEVIN ALEX WILLOCK MALE ACTUAL DATE OF DEATH 01/15/2023
3. SOCIAL SECURITY NUMBER
r•· AGE
(Years} I 4b. UNDER 1 YEAR
Mos. Days
4c. UNDER 1 DAY
Hours I Mins.
I 5. DATE OF BIRTH (Mo., Day, Year)

OZ/2~/2.002
056-92-1821
6. BIRTHPLACE
20
I I I I . .
I7a. RESIDENCE· STATE I7b. COUNTY I7c. CITY, TOWN
NEW YORK NEW JERSEY BERGEN NEW MILFORD
7d. STREET AND NUMBER I 7e. ZIP CODE 171. INSIDE CITY LIMITS? 18. ARMED FORCES?
757 HOLLY STREET 07646 UNKNOWN NO
Ba USUAL OCCUPATION I8b, KIND OF INDUSTRY OR BUSINESS
NONE STUDENT
9. MARITAL STATUS · 1 10. SPOUSE NAME 111. FATHER'S FULL NAME (First, Middle, Last)

NEVER MARRIED DAVE ALEXANDER WILLOCK

12. MOTHER'S MAIDEN NAME (First, Middle, Lasl) I13a. INFORMANT'S NAME (Firsl, Middle, Lasl) I13b. RELATIONSHIP TO DECEDENT

SHARLENE MICHELLE JOHN SHARLENE WILLOCK MOTHER

13c. MAILING ADDRESS
-
114. DECEDENT'S EDUCATION
757 HOLLY STREET NEW MILFORD NEW JERSEY 07646 SOME COLLEGE CREDIT LEADING TO A BACHELOR'S DEGREE
15. ORIGIN OF DECEDENT(Spa11ish/Hlspanio/LaUno} 116. DECEDENT'S RACE /W/Jila, Black, American Indian, etc.) (Specify}
NO, NOT SPANISH/HISPANIC/LATINO BLACK OR AFRICAN-AMERICAN
17a. IF DEATH OCCURRED IN HOSPITAL I17b. IF DEATH OCCURRED OTHER THAN HOSPITAL (Specify)
SCENE
18. HOSPITAL OR OTHER INSTITUTION NAME (If not In either give street and 110.) 119. CITY, TOWN or LOCATION OF DEATH 120. COUNTY OF DEATH
BARNETT SHOALS RD AT STROUD DRIVE ATHENS CLARKE
21. METHOD OF DISPOSITION (specify) 122. PLACE OF DISPOSITION 123. DISPOSITION DATE (Mo., Day, Year)
BURIAL MAPLE GROVE PARK CEMETERY 535 HUDSON STREET HACKENSACK NEW JERSEY 01/27/2023
07601
24a. EMBALMER"$ NAME I24b. EMBALMER LICENSE NO. 125, FUNERAL HOME NAME
CHARLES MENENDEZ 2892 JACKSON MC'IJHORTER FUNERAL HOME
25a. FUNERAL HOME ADDRESS
1253 WEST BROAD STREET ATHENS GEORGIA 30606 I

26a. SIGNATURE OF FUNERAL DIRECTOR I26b. FUN. DIR. LICENSE NO AMENDMENTS

SHANNA D JACKSON 4502

27. DATE PRONOUNCED DEAD (Mo., Day, Year) 128. HOUR PRONOUNCED DEAD
01/15/2023 04:40 AM
29a. PRONOUNCER'S NAME I29b. LICENSE NUMBER I29c. DATE SIGNED
SONNY WILSON 01/24/2023
30. TIME OF DEATH
- - 31. WAS CASE REFERRED TO MEDICAL EXAMINER
04:40 AM YES
32. Part I. Enter Iha chain or ovents-d!soosos, Injuries. or compflcallons thot d\reclly cousod tho dealh. DO NOT onler torm!nal events such as cardiac arrest. Approximate Interval between onset and death
respl,atory a11est, Or vennlcuter f1b1illaUon wllhoul showing the otlology. 00 NO'r ABBREVIATE.

BLUNT FORCE TRAUMA TO HEAD, NECK AND TORSO IMMEDIATE

IMMEDIATE CAUSE (Final A.
disease or condition resulting in Due to, or as a consequence of
death)
B. -

Due to, or as a consequence of

c.
Due 10, or as a consoquonce of '
D.
Part II. Enter significant conditions contrlbuling to death but not related to cause 33. WAS AUTOPSY PERFORMED? 34. WERE AUTOPSY FINDINGS AVAILABLE TO
given In Part 1A. If temete, indlcafa ii pregnant or birth occurred within 90 days of death. COMPLETE THE CAUSE OF DEATH?

NO

35. TOBACCO USE CONTRIBUTED TO DEATH 136. IF FEMALE (rango 10-54) PREGNANT 37. ACCIDENT, SUICIDE, HOMICIDE, UNDETERMINED (Specify)
NO NOT APPLICABLE ACCIDENT
38. DATE OF INJURY"(Mo., Day, Year) 139. TIME OF INJURY 140. PLACE OF INJURY (Home, Farm, Street, Factory, Office, Etc.) (Specify) I41. INJURY AT WORK? (Yes or No)
01/15/2023 02:45 AM STREET NO
42. LOCATION OF INJURY (Street, Apartment Number, City or Town, Slate, Zip, County)

BARNETT SHOALS RD ANO STROUD DRIVE ATHENS GEORGIA 30605 CLARKE

43. DESCRIBE HOW INJURY OCCURRED 144. IF TRANSPORTATION INJURY
PASSENGER IN SINGLE VEHICLE ACCIDENT YES
45. To lhe best of my knowledge dealh occurred at the time, date and place 46. On the basis or examination and/or Investigation, in my opinion death occurred at the lime, date
and duo lo tho cause(s) slated. Medical Certifier (Name, Tille, License No.) and place and due lo the causo(s) stated. Modical Examiner/Coroner (Name, Tille, License No.)

/S/ SONNY WILSON CORONER

45a. DATE SIGNED (Mo., Day, Year) I45b. HOUR OF DEATH

· •11 46a. DATE SIGNED (Mo., Day, Year) _J 46b. HOUR OF DEATH
01/24/2023
47. NAME, ADDRESS, AND ZIP CODE OF PERSON COMPLETING CAUSE OF DEATH
--· ---- ·-··~- .04:~0 AM
-•----•--·
SONNY WILSON 3195 ATLANTA HWY ATHENS GA 30606 ATHENS GEORGIA 30606
48.REGISTRAR 149. DATE FILED~ REGISTRAR (Mo., Day, Year}
(Slgnalure) /5/ CHRISTOPHER JP HARRISON
"-
01/26/2023
Form 3903 (Rev. 04/2012), GEORGIA DEPARTMENT OF PUBLIC HEAL TH

Exhibit 2 - Page 1 of 2
TH IS IS TO CERTIFY THATT HIS IS A TRUE REPRODUCT ION OF TH E OHIGINAL RECORD ON flLE WITH THE STATE OFFICE OF VITAL RECORDS,
GEO RGIA DEPARTMEN T OF PUBLIC HEALTH . THIS CER TIFIED COPY IS ISSUED UNDER THE AUTH ORllY OF CHAPTER 31-10, CODE OF GEORGIA
AND 511-1-3 DPH RULES AND REGULATIONS.

STATE REGISTRAR AND CUSTODIAN MAR ·21 2023

GEORGIA STATE OFFICE OF VITAL RECORDS DATE ISSUED:---------'------~'---

Any reproductton of thls document is prohibited by statute, Do not accept unless embossed with ~ raised seal.
VOID IF ALTERED OR COPIED

Exhibit 2 - Page 2 of 2
EXHIBIT 3
Willock Schedule of Coverage

DOAS July to June

Fiscal Year Coverage

Insurer ..
Type Policy No Be_&in Date End Date Limits Notes
Safety National Casualty Company Auto CA 6676373 7/1/22 7 /1/23 2,000,000 Commercial Auto
Safety National Casualty Company Excess/Auto XPE4067128 7/1/22 7 /1/23 3,000,000 Excess above auto
Lloyd's Ambridge Policy Excess/Auto PK1037222 7 /1/22 7 /1/23 5,000,000 Brit Global Specialty USA Policy, Behind Safety National
Allied World Assurance Excess/Auto 0310-2272 7/1/22 7 /1/23 10,000,000 Renewal of 0310-2272, Behind Lloyd's $Sm
Westchester-A Chubb Company Excess/Auto G72530457 002 7/1/22 7 /1/23 10,000,000 Renewal of 0310-2272, Behind Lloyd's $Sm
Navigators Specialty Insurance Policy Excess/Boat HO22LIA00325101 7/1/22 7 /1/23 9,000,000 Actual Marine Policy
Travelers Property Casualty Boat ZOH31N2934922ND 7 /1/22 7 /1/23 1,000,000 Boat Collision & Crew Indemnity
Water Quality Insurance Syndicate Boat Pollution 56-82341 7/1/22 7 /1/23 5,000,000 Vessel Polution liability
New York Marine & Gen Insurance Company Boat ML2022MEE00416 7/1/22 7/1/23 1,000,000 Marine Employer's liability

Exhibit 3 - Page 1 of 1