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Friday, May 28, 2010

Claim Filed By Tina D'Aversa Re: Ethics Complaint / PT 2

Dated April 15, 2010.
________________________________ LUCIAN GILLIS, Jr.,
Georgia Bar No. 295163,
Attorney for Petitioner.
GILLIS & CREASY,
Two Ravinia Drive, Suite 650, Atlanta, Georgia 30346 770-394-3127; fax 770-394-3117;
LGillis@gilliscreasy.com.
RESPONDENT AND DEFENDANTS CAN BE SERVED AS FOLLOWS:
Hon. CLINT JOHNSON
Chairman, City of Milton, Georgia Board of Ethics 13000 Deerfield Parkway, Suite 107A Milton, GA 30004
Hon. JOE LOCKWOOD
Mayor of Milton, Georgia 13000 Deerfield Parkway, Suite 107A Milton, GA 30004
NEAL J. O’BRIEN
635 Devonshire Farms Way Milton, GA 30004-4322
IN THE SUPERIOR COURT OF FULTON COUNTY STATE OF GEORGIA
TINA D’AVERSA,
Petitioner
v.
CITY OF MILTON, GEORGIA BOARD OF ETHICS,
Respondent
CITY OF MILTON, GEORGIA,
Defendant in Certiorari
Civil Action No. ___________________________

CERTIFICATE OF PAYMENT OF COSTS
This certificate shows that Tina D’Aversa, the petitioner in certiorari and the respondent in In re Tina D’Aversa (Bd. of Ethics Mar. 16, 2010) before the City of Milton, Georgia Board of Ethics, has paid all costs that have accrued on the trial and proceedings below.
Dated April 15, 2010.
_________________________________ CLINT JOHNSON,
Chairman, City of Milton Board of Ethics.
Prepared and respectfully presented by:
LUCIAN GILLIS, JR.,
Georgia Bar No. 295163,
Attorney for Petitioner.
GILLIS & CREASY,
Two Ravinia Drive, Suite 650, Atlanta, Georgia 30346 770-394-3127; fax 770-394-3117;
LGillis@gilliscreasy.com.
CERTIFICATE OF SERVICE
I have served this paper on every party by U.S. Mail, first-class postage prepaid and addressed:
PAUL B. FRICKEY, Esq. JARRARD & DAVIS, LLP
105 Pilgrim Village Drive Suite 200 Cumming, GA 30040
Mr. NEAL J. O’BRIEN
635 Devonshire Farms Way Milton, GA 30004-4322

Hon. JOE LOCKWOOD
Mayor 13000 Deerfield Parkway, Suite 107A Milton, GA 30004



Dated April 15, 2010.
________________________________ LUCIAN GILLIS, Jr.,
Georgia Bar No. 295163,
Attorney for Petitioner.
GILLIS & CREASY,
Two Ravinia Drive, Suite 650, Atlanta, Georgia 30346 770-394-3127; fax 770-394-3117;
LGillis@gilliscreasy.com.
IN THE SUPERIOR COURT OF FULTON COUNTY STATE OF GEORGIA
TINA D’AVERSA,
Petitioner
v.
CITY OF MILTON, GEORGIA BOARD OF ETHICS,
Respondent
CITY OF MILTON, GEORGIA and NEAL J. O’BRIEN,
Defendants in Certiorari
Civil Action No. ___________________________

CERTIORARI BOND IN CIVIL CASE
Know all persons and parties by these presents:
Tina D’Aversa, as principal, and Lucian Gillis, Jr., LLC, a limited liability company existing and in good standing under Georgia law, as surety, are held and bound to the City of Milton, Georgia in the amount of $100, as sufficient to cover the sum sought to be recovered as an award in the City of Milton Board of Ethics, together with all future costs, to the payment of which to be made. We, the above principal and surety, bind ourselves, and our respective successors in interest, assigns, heirs, executors, and administrators, jointly and severally. To this obligation we set our hands and seals this 12th day of April, 2010.
On March 16, 2010, in an action pending in the City of Milton Board of Ethics, styled In re Tina D’Aversa (Bd. of Ethics Mar. 16, 2010), a decision was rendered against Tina D’Aversa. Tina D’Aversa has filed or will file a petition for writ of certiorari in the Superior Court of Fulton County.
Therefore, the condition of this obligation is that if Tina D’Aversa prosecutes her petition and pays any sum sought to be recovered as an award in the City of Milton Board of Ethics, and any damages under O.C.G.A. § 5-4-18, together with all future costs, if the writ is dismissed or otherwise disposed of adversely to her in the superior court or in the Ethics Board, or such costs as the superior court may award against her, or if the decision is vacated or the writ otherwise disposed of favorably to her, then this obligation will be void. Otherwise, this obligation remains in full force.
________________________________ TINA D’AVERSA,
Principal.
_________________________________ LUCIAN GILLIS, JR., LLC.,
Surety.
POWER OF ATTORNEY
The undersigned sole member of Lucian Gillis, Jr., LLC states under oath that the above Lucian Gillis Jr. is an agent and attorney-in-fact of Lucian Gillis, Jr., LLC, a limited liability company existing and in good standing under Georgia law. He has full authority to file and execute the bond and obligation stated above, in the name and under the seal of the above limited liability company. The undersigned knows the seal of the above limited liability company; the seal was affixed by authority of the sole member; and he signed his name hereto by like authority.
_____________________________ LUCIAN GILLIS Jr.,
Sole member..
IN THE SUPERIOR COURT OF FULTON COUNTY STATE OF GEORGIA
TINA D’AVERSA,
Petitioner
v.
CITY OF MILTON, GEORGIA BOARD OF ETHICS,
Respondent
CITY OF MILTON, GEORGIA,
Defendant in Certiorari
Civil Action No. ___________________________

APPROVAL OF CERTIORARI BOND BY MAJORITY OF BOARD MEMBERS
The above bond has been presented and its form, amount, and security has been found acceptable to the chairman and the City of Milton Board of Ethics. The bond is therefore approved.
Dated .
_________________________________ CLINT JOHNSON,
Chairman, City of Milton Board of Ethics.
Prepared and respectfully presented by:
LUCIAN GILLIS Jr.,
Georgia Bar No. 295163,
Attorney for Petitioner.
GILLIS & CREASY,
Two Ravinia Drive, Suite 650, Atlanta, Georgia 30346 770-394-3127; fax 770-394-3117;
LGillis@gilliscreasy.com.
CERTIFICATE OF SERVICE
I have served this paper on every party by U.S. Mail, first-class postage prepaid and addressed:
PAUL B. FRICKEY, Esq. JARRARD & DAVIS, LLP
105 Pilgrim Village Drive Suite 200 Cumming, GA 30040

Mr. NEAL J. O’BRIEN
635 Devonshire Farms Way Milton, GA 30004-4322

Hon. JOE LOCKWOOD
Mayor 13000 Deerfield Parkway, Suite 107A Milton, GA 30004



Dated April 15, 2010.
________________________________ LUCIAN GILLIS, Jr.,
Georgia Bar No. 295163,
Attorney for Petitioner.
GILLIS & CREASY,
Two Ravinia Drive, Suite 650, Atlanta, Georgia 30346 770-394-3127; fax 770-394-3117;
LGillis@gilliscreasy.com.
IN THE SUPERIOR COURT OF FULTON COUNTY STATE OF GEORGIA
TINA D’AVERSA,
Petitioner
v.
CITY OF MILTON, GEORGIA BOARD OF ETHICS,
Respondent
CITY OF MILTON, GEORGIA and NEAL J. O’BRIEN,
Defendants in Certiorari
Civil Action No. 2010CV184381

SANCTION OF PETITION FOR WRIT OF CERTIORARI
The petition in this matter has been presented, with a certificate of costs and a bond, all in proper and sufficient form. The bond has been found acceptable and approved according to law. The petition is therefore sanctioned. This Court directs the clerk to issue the writ of certiorari according to law.
Done at Atlanta, Georgia, this day of , 2010.
_______________________________
Judge, Superior Court of Fulton County.
Prepared and respectfully presented by:
LUCIAN GILLIS Jr.,
Georgia Bar No. 295163,
Attorney for Petitioner.
GILLIS & CREASY,
Two Ravinia Drive, Suite 650, Atlanta, Georgia 30346 770-394-3127; fax 770-394-3117;
LGillis@gilliscreasy.com.
CERTIFICATE OF SERVICE
I have served this paper on every party by U.S. Mail, first-class postage prepaid and addressed:
PAUL B. FRICKEY, Esq. JARRARD & DAVIS, LLP
105 Pilgrim Village Drive Suite 200 Cumming, GA 30040

Mr. NEAL J. O’BRIEN
635 Devonshire Farms Way Milton, GA 30004-4322

Hon. JOE LOCKWOOD
Mayor 13000 Deerfield Parkway, Suite 107A Milton, GA 30004
Dated April 15, 2010.

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