70
14.
FIFTH CAUSE OF ACTION
(For a Declaratory Judgment)
[By
Rhonda McClendon, as Guardian of Gary Wayne Thompson, an incapacitated
adult Against Mark Andrew Gomez, Tina Barron, Leigh Ann Ware (formerly Leigh
Ann Robertson), James Bret Robertson, Jamie Robertson, Derwin Ware, Nathaniel
Russell, John Doe 1, John Doe 2, John Doe 3, Jane Doe 1, Jane Doe 2 and Jane Doe
3
for a Declaratory Judgment in Addition to the Relief Requested in the First, Second,
Third and Fourth Causes of Action]
14.1
In addition to, or, in the alternative to, the relief requested in the First, Second, Third
and Fourth Causes of Action by Rhonda McClendon, as Guardian of Gary Wayne
Thompson, an incapacitated adult, this action seeks a declaratory judgment, pursuant to
O.C.G.A. § 9-4-1, et seq., that Mark Andrew Gomez, Tina Barron, Leigh Ann Ware
(formerly Leigh Ann Robertson), James Bret Robertson, Jamie Robertson, Derwin Ware,
Nathaniel Russell, John Doe 1, John Doe 2, John Doe 3, Jane Doe 1, Jane Doe 2 and Jane
Doe 3 damaged Gary Wayne Thompson and breached his duty to him under the laws of the
State of Georgia by engaging in a RICO Enterprise. Additionally, while engaging in their
RICO Enterprise conduct, they further committed the actionable conduct of false swearings,
intentional misrepresentations and negligent misrepresentations.
WHEREFORE, Rhonda McClendon, as Guardian of Gary Wayne Thompson, an
incapacitated adult, requests relief and judgment against the Racketeering Lawyer/former
Guardian and Other Racketeering Defendants, jointly and severally, unless otherwise
stated. The relief requested is to cure the damages sustained as indicated in this Complaint
and to deter similar conduct of the Racketeering Lawyer/former Guardian and Other
Racketeering Defendants in the future. The requested relief is further identified as follows.
