STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE

SUPERIOR COURT DIVISION

DURHAM COUNTY 25CV000978-310

LAQUITA KOONCE, Individually,

And as Guardian Ad Litem for AMENDED COMPLAINT
K.M., A Minor
Plaintiffs,

CRAVEN COUNTY BOARD OF

EDUCATION, AND SHERRI N.
THOMAS, Principal In Her
Official And Individual
Capacities,
Defendants.

NOW COME the Plaintiffs, K.M., a minor, by and through her Guardian ad Litem

Laquita Koonce, and Laquita Koonce, Individually, by and through their undersigned counsel

of record, pursuant to N.C. Gen. Stat. § [A-1, Rule 15(a) of the North Carolina Rules of Civil

Procedure, and hereby submit this Amended Complaint and hereby allege and complain of

the Defendants as follows:

INTRODUCTORY STATEMENT OF FACTS

The incidents described herein occurred during the school day on January 26,

2023, James W. Smith Elementary School, located at 150 Koonce Town Road, Cove City,

in Craven County, North Carolina. After an art class, K.M., a second-grade disabled

student, was bullied, battered, secluded, physically restrained, and assaulted by the

school principal, Sherri N. Thomas. Once the art class ended, the disabled student did

not leave the classroom immediately, and was reportedly on her knees either under or

near a desk, when Principal Thomas responded to the disabled student's reluctance to

leave the art classroom by grabbing the child by the hood of her cloth garment and
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Electronically Filed Date: 3/21/2025 2:31 PM Durham Superior Court County Clerk of Superior Court PR
dragging the child on her knees from the art classroom, down the hall, through the

school office/reception area, into the principal's office where the camera could not see

an image; back through the school office/reception area, across the hall, down the

walkway or aisle of the cafeteria. There the camera footage shows the principal released
the child's hooded garment and allowed the child to stand so the child could request

lunch. A part of the dragging incident is captured by the school cameras. Upon

information and belief, despite the principal's unreasonable and prohibited use of force,

at no time was K.M.'s parent contacted or advised of the principal's actions by which

K.M. was bullied, battered, secluded, physically restrained, and assaulted.

Consequently, K.M. was ridiculed, frightened, and emotionally distressed, having

suffered foreseeable psychological harm from the principal's prohibited, unreasonable

use of force. The principal's unreasonable actions, including the use of force, physical

restraint, seclusion, and bullying to remove K.M. from the art class or to discipline K.M.
violates Federal, North Carolina Constitutional, statutory laws, and Craven County

Board of Education policies, which protect minor and disabled students.

Although K.M. trusted the principal and the other adults who worked at the

elementary school, no adult intervened, to halt or prevent the principal from dragging
the child by the hood of her garment while on bent knees down the halls, into and out

of the lobby, across the hall, and into the cafeteria. Plaintiff is not aware that the

principal's conduct was reported to law enforcement or Social Services by school

personnel.
PARTIES & JJURISDICTION
1. Plaintiff K.M. is a minor child, citizen, and resident of Lenior County, North

Carolina. K.M. is considered and known to be a disabled student based on medical diagnoses

and qualifies to receive appropriate special education, aids, and/or related services. At all

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times relevant to the allegations of this complaint, she was seven (7) years old.

2. K.M. is a student to whom the North Carolina Constitution, the "Policies

Governing Services for Children with Disabilities," as written by the North Carolina

Department of Public Instruction, Office of Exceptional Children Division, and local school

board policies apply.

3. Plaintiff Laquita Koonce is the mother of K.M., a citizen, and resident of Lenoir

County, North Carolina.

4. Plaintiff Laquita Koonce has been duly appointed as Guardian ad Litem for

K.M. for the purpose of bringing this action.

5. Defendant Craven County Board of Education ("Defendant Board") is a

local board of education duly organized and established pursuant to Chapter 115C of the

North Carolina General Statutes.

6. Defendant Board acts, operates, and conducts business as a local school

board, namely, Craven County Schools, pursuant to Chapter 115C of the North

Carolina General Statutes and as such, operates all of the public schools under its

authority, including, but not limited to, James W. Smith Elementary School in
Craven County, North Carolina.

7. Defendant Board, upon information and belief, has waived

governmental immunity for personal injury claims against it, including the claims
in this Complaint, by purchasing and maintaining liability insurance, pursuant to

N.C. Gen. Stat.§ 115C-42.

8. Defendant State Board of Education is a government entity created

pursuant to Article IX of the North Carolina Constitution, and is obligated under Section

5 of that Article to "supervise and administer the free public school system[.]"

9. Defendant Board is subject to the laws, rules, regulations and policies enacted
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by the State Board of Education, the Department of Public Instruction, the Exceptional

Children Division, and its own policies.

10. Upon information and belief, Defendant Sherri N. Thomas ("Defendant

Thomas") is a resident of Craven County, North Carolina.

11. At all relevant times, Defendant Thomas was employed by Defendant
Board as a Principal at James W. Smith Elementary School. The acts

complained of were performed by Defendant Thomas under the supervision of

Defendant Board, during the course and scope of her employment in her official

capacity.
12. Atall relevant times, Defendant Thomas was a public official under the
laws of North Carolina pursuant to N.C. Gen. Stat.§ 115C-284 et seq. and 115C-

287.1.

13. Defendant Thomas is sued in her individual and official capacities as

further alleged herein. Upon information and belief, Defendant Thomas was acting

as a public official and is not entitled to public official immunity.

14. Plaintiffs seek to recover damages from Defendant Thomas

individually and or as an agent of Defendant Board.

FACTUAL ALLEGATIONS
15. Plaintiffs adopt and incorporate by reference the allegations set forth in the

preceding paragraphs of this Complaint.

16. Upon information and belief, on January 26, 2023, with known or perceived

disabilities, K.M. was a second-grade student at JJames W. Smith Elementary School located

at 150 Koonce Town Road, Cove City, in Craven County, North Carolina.

17. School personnel knew, or should have known, she was disabled.

18. K.M. attended an art class and did not leave the classroom immediately after

the class ended.

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 19. K.M. was either under or near a desk.

20. Defendant Principal came to the classroom, grabbed K.M. by the hood of her

cloth garment, dragged K.M. to the door of the classroom on her knees, looked into the

hallway, looked both directions down the hallway, dragged K.M. on her knees from the

classroom, down the hall, through the school office/reception area, into the principal's

office where the camera could not see an image, back through the school office/reception

area, across the hall, and down the walkway of the cafeteria.

21. There the camera footage shows the principal released the child's hooded

garment and allowed the child to stand at the counter so the child could request lunch.

22. Aportion of the dragging incident is captured by the school cameras.

23. School personnel were present and witnessed the incident but did not

intervene.

24. Defendant Principal's actions were unreasonable and constituted a

prohibited use of force.

25. Defendants failed to timely inform Plaintiff of the same.

26. Defendant Principal's actions, including but not limited to, the use of force,

physical restraint, seclusion, and bullying to remove K.M. from the classroom, or to

discipline K.M., were unreasonable and violated Federal, North Carolina Constitutional,

statutory laws, and Defendant Board's policies which protect minor and disabled students.

27. Upon information and belief, Defendant Principal previously committed

abusive acts or engaged in similar conduct against students which violated Federal, North

Carolina Constitutional, statutory laws, and/or Defendant Board's policies which protect

students.

28. Upon information and belief, Defendant Board knew of Defendant Principal's

previous acts and or similar conduct.

29. Upon information and belief, Defendant Board was indifferent to Defendant
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Principal's acts.

30. Upon information and belief, Defendant Board did not report Defendant

Principal's acts to law enforcement or Social Services.

31. K.M. was ridiculed, frightened, and emotionally distressed, having suffered

foreseeable psychological harm from the principal's prohibited, unreasonable use of force.

32. K.M. suffered both physical and psychological damages as a result of this

incident.

33. Plaintiff also suffered damages as a result of this incident.

34. Defendant Principal's malicious conduct directly injured the Plaintiffs.

35. Defendant Principal's conduct was malicious in that it was done wantonly,

contrary to her duty, and was intended to be injurious to K.M.

36. Defendant Principal acted with malice when she willfully and wantonly

abused K. M. by dragging her about the school halls, administrative offices, and cafeteria,

as this unreasonable physical restraint and abusive conduct was an inappropriate

behavioral intervention, in violation of her duty, and such conduct was foreseeably

injurious to K.M. and Plaintiff.

37. Defendant Principal knew, should reasonably have known, or had access to

staff persons trained in positive behavioral interventions, supports, and other strategies, to

address K.M.'s reluctance to leave the classroom.

38. Defendant Principal had exclusive care, custody, and control of the minor

during the school day when the severe and discriminatory actions occurred.

39. Upon information and belief, Defendant Principal is the person responsible

for distributing bullying prevention material to staff, students, and parents annually under

N. G. Gen. Stat. 115C-407.16, known as the "Policy against bullying or harassing

behavior."
40. Yet, in direct violation of N.C. Gen. Stat. 115C-407.15, Article 29C, the
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School Violence Prevention Law, Defendant Principal directly engaged in bullying,

harassing behavior, seclusion, and isolation tactics, and the improper physical restraint of

the seven-year-old child, which caused the child to experience needless pain, suffering,

emotional distress, and embarrassment.

41. Instead of utilizing positive behavioral interventions, support, or other

strategies, to address K.M.'s reluctance to leave the classroom, Defendant Principal

maliciously and intentionally decided to drag the student on bent knees throughout the

school, where her conduct amounted to a form of corporal punishment, or the intentional

infliction of physical pain upon K.M.'s body and mental torment, as recorded by school

video cameras.

42. Defendants' conduct, acts, and or omissions described herein were in

direct contravention of the antidiscrimination provisions meant to protect students

with disabling conditions that are set out in the "Individuals with Disabilities
Education Act" (IDEA), U.S.C. 1400(d); 34 CFR 300.1; Section 504 of
the Rehabilitation Act of 1973 (Section 504), 29 U.S.C. 794, and its
implementing regulation, at 34 C.F.R. Part 104; (Section 504 prohibits
discrimination on the basis of disability in programs and activities that receive
Federal financial assistance from the U. S. Department of Education); Title IT of
the Americans with Disabilities Act (Title II), 42 U.S.C. §§ 12131 et seq.,
and its implementing regulation, at 28 C.F.R. Part 35; (Title II prohibits
discrimination in public accommodations and educational programs); "Policies

Governing Services for Children with Disabilities" written for the State
Board of Education, by the North Carolina Department of Public
Instruction (NC DPI), Office of Exceptional Children Division; Article
9, N.C. Gen. Stat § 115C-106.1, et seq., Education of Children With
Disabilities, and Defendant Board's policies.
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 43. In pertinent part, the Policies Governing Services for Children
with Disabilities written by the North Carolina Department of Public
Instruction (NC DPI), Office of Exceptional Children Division state:

The goal of the State is to provide appropriate educational opportunity

to all children with disabilities who reside in North Carolina" and... "(a)
To ensure that all children with disabilities, ages three through 21, have
available to them a free appropriate public education that emphasizes
special education and related services designed to meet their unique
needs and prepares them for further education, employment, and
independent living; (b) To ensure that the rights of children with
disabilities and their parents are protected.

44. Administered by the NC DPI, the cornerstone of the IDEA is that each

eligible student with a disability receives a free appropriate public education (FAPE)
that provides special education, related services, supplementary aids and services, and

program modifications or supports for school personnel, designed to meet the

student's unique needs and prepares the student for future education, employment,

and independent living.

45. Sadly, the malicious conduct of Defendant Principal described above

was intimidating, threatening, coercive, and discriminatory; as the conduct directly

violated the educational rights of K.M. The educational rights of Plaintiff are

secured by the laws and regulations which protect the Minor Plaintiffs right to a

free appropriate education in the least restrictive environment.

46. Defendant Principal's malicious and corrupt conduct caused the

disabled Minor Plaintiff to suffer physical pain, anxiety, mental and severe

emotional distress, and embarrassment. Ms. Koonce experienced emotional

distress, anxiety, and embarrassment as well when she learned about the horrific

acts of Defendant Principal and incurred medical expenses and other damages.

47. Upon information and belief, it is unlikely Defendant Principal would

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have dragged a non-disabled, Caucasian seven-year-old child on bent knees from

the classroom by the hoodie, down the hall, into her office, the administrative office

and the cafeteria.

48. Defendant Principal's deliberate stroll throughout the building while

dragging the child on bent knees showed her actions were intended to be prejudicial
and injurious. Defendant Principal's injurious conduct ignored appropriate

interventions and the rights of Plaintiffs.

49. Consequently, unlike the positive way Minor Plaintiff felt about school
before this traumatic incident, thereafter she displayed negative reactions toward

attending school and reluctancy when Plaintiff informed her it was time for school.

50. The Minor Plaintiff required medical treatment, psychological

evaluation, and additional reassurance from Plaintiff.

51. Upon information and belief, under the pretense of helping Plaintiffs,

agents and employees of Defendant Board obtained Ms. Koonce's written

permission to release the video recording of the Defendant Principal dragging her

daughter by the hooded garment through the school. However, the Board

employees and/or agents did not provide a copy of the records obtained or the

identity of the recipient(s) to whom the employees sent the video recording and
records under the Family Educational Rights and Privacy Act (FERPA).
52. Upon information and belief, Defendant Board continued to violate
Minor Plaintiffs rights by failing to provide services to which she is entitled subject

to the laws, rules, regulations and policies enacted North Carolina Constitution,

State law, the State Board of Education, the Department of Public Instruction, the

Exceptional Children Division, and its own policies.

Public Official Liability
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 53. Plaintiffs adopt and incorporate by reference the allegations set forth in

the preceding paragraphs of this Complaint.

54. Public officials may be liable for negligence if their actions were

"corrupt or malicious, or that [they] acted outside of or beyond the scope of [their]
duties." Smith v. Hefner, 235 N.C. 1, 7 (1952); see also Grad v. Kaasa, 312 N.C.

310,313, 312 S.E.2d 888, 890 (1984) ("A defendant acts with malice when he

wantonly does that which a man of reasonable intelligence would know to be

contrary to his duty and which he intends to be prejudicial or injurious to another.")

55. Defendant Principal owed Plaintiffs a duty of care to ensure the safety and

well-being of K.M. and students, to protect them from harm, and to take reasonable

measures to prevent foreseeable risks.

56. Defendant Principal breached her duty of care and directly caused the

Plaintiffs to suffer harm and damages.

57. As the principal and public official, Defendant Thomas' intentional

reprehensible, malicious conduct as described herein, with the assault, battery, and
unreasonable use of force is contrary to State and Federal law, policies, and rules.

58. Assuch, Defendant Principal's liability as a public official is imputed to

Defendant Board.

59. The injuries suffered by Minor Plaintiff are the result of Defendant Principal's

acts which were malicious, corrupt, in bad faith and, in part, outside and beyond the scope

of her duties and authority as a public official and school principal.

60. Defendant Board is directly liable for Defendant Thomas' intentional

and/or negligent acts or omissions.

61. Alternatively, Defendant Board is vicariously liable for Defendant Thomas'

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conduct under the legal doctrine of respondeat superior.

62. Asadirect and proximate result of Defendants' conduct, Plaintiffs are

entitled to recover damages in excess of Twenty-Five Thousand Dollars

($25,000.00).
FIRST CLAIM FOR RELIEF
(Assault)
63. Plaintiffs adopt and incorporate by reference the allegations set forth in

the preceding paragraphs of this Complaint.

64. Defendant Thomas, by an intentional act or display of force and

violence threatened K.M. with imminent bodily injury by grabbing for her clothing.

65. That grabbing caused K.M. to have a reasonable apprehension that

harmful and or offensive contact with her person was imminent.

66. Defendant Principal's intentional and/or negligent acts or omissions

were malicious in that they were done wantonly, contrary to her duty, and intended

to be injurious to K.M.

67. Asa a direct and proximate result of Defendants' conduct, Plaintiffs are

entitled to recover damages in excess of Twenty-Five Thousand Dollars

($25,000.00).
SECOND CLAIM FOR RELIEF
(Battery)
68. Plaintiffs adopt and incorporate by reference the allegations set forth in

the preceding paragraphs of this Complaint.

69. Defendant Principal intentionally caused bodily contact with K.M.

70. Such bodily contact offended a reasonable sense of personal dignity and

or caused physical pain or injury.

71. Such bodily contact occurred without Plaintiffs' consent.

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 72. Defendant Principal's intentional and/or negligent acts or omissions

were malicious in that they were done wantonly, contrary to her duty, and intended

to be injurious to K.M.

73. Asa direct and proximate result of Defendants' conduct, Plaintiffs are
entitled to recover damages in excess of Twenty-Five Thousand Dollars

($25,000.00).
THIRD CLAIM FOR RELIEF
(Negligence)
74. Plaintiffs adopt and incorporate by reference the allegations set forth in

the preceding paragraphs of this Complaint.

75. Defendant Thomas owed K.M. and other students a general duty of

reasonable care, to ensure the safety and well-being of students and to protect

students from harm and to take reasonable measures to prevent foreseeable risks,

and those enumerated under other N.C. Statutes, including but not limited to N.C.

§ 115C-407.15.

76. Defendant Thomas breached this duty.

77. Plaintiffs were harmed as a direct and proximate result of Defendant

Thomas' breach.

78. Such harm was foreseeable.

79. Defendant Thomas was negligent in that she failed to utilize the

appropriate behavioral response and interventions to avoid injuring K.M.

80. Defendant Principal's intentional and/or negligent acts or omissions

were malicious in that they were done wantonly, contrary to her duty, reckless,

and/or intended to be injurious to K.M.

81. Asa a direct and proximate result of Defendants' conduct, Plaintiffs are

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entitled to recover damages in excess of Twenty-Five Thousand Dollars

($25,000.00).
FOURTH & FIFTH CLAIMS FOR RELIEF
(Negligent Supervision & Retention)
82. Plaintiffs adopt and incorporate by reference the allegations set forth in

the preceding paragraphs of this Complaint.

83. Defendant Principal committed a negligent and/or wrongful act by

dragging the seven-year-old, disabled, Minor Plaintiff throughout the school on her
knees.

84. Among the legal duties of care owed to Plaintiffs, the Board owed
Plaintiffs a legal duty of care, to:

a. Meet the individualized needs, including any behavioral needs,

of students with disabilities such as K.M..,

b. Exercise due care in the supervision of its employees, and

c. Protect all of its students, including KM.

85. At all times and places alleged herein, Defendant Board had the

authority to terminate, discipline, and otherwise control the behavior of Defendant

Principal but refused and failed to take appropriate remedial and corrective action
to protect K.M.

86. Upon information and belief, Defendant Principal had a reputation for

engaging in similar conduct with children under her supervision and control.

87. Defendant Principal was incompetent in that she was either improperly

trained, based on her past actions with student, her disposition, or other ways.
88. Upon information and belief, Defendant Board breached its duties as it:

a. Was deliberately indifferent to Defendant Principal's malicious conduct

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 and or failed to supervise the activities of Defendant Principal,

b. Allowed and ratified Defendant Principal's malicious use of an

unreasonable physical restraint, dragging, assault and battery

that traumatized and injured the disabled child,

c. Knew, or should have known of, Defendant Principal's assault

and battery of the Minor Plaintiff and previous similar conduct

and incompetence,

d. Failed to report such illegal acts and or violations to the proper

authorities,
e. Violated Plaintiffs' rights under the Family Educational Rights

and Privacy Act (FERPA),

f. Violated Plaintiffs' rights under North Carolina Constitutional,

statutory laws, and Defendant Board's policies which protect

Plaintiff and other minor and disabled students, and

g. In other such ways which will be determined during discovery in

this matter.

89. Defendants' actions proximately caused Plaintiffs' injuries and the

Board is directly liable for its own and Defendant Thomas' intentional and/or

negligent acts or omissions.

90. Defendant Board is liable for the negligent hiring, supervision, training and

retention of Defendant Principal.

91. Alternatively, Defendant Board is vicariously liable for Defendant

Thomas' conduct under the legal doctrine of respondeat superior.

92. The injuries suffered by Minor Plaintiff are the result of Defendant

Principal's acts which were intentionally harmful, malicious, corrupt, in bad faith
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and, in part, outside and beyond the scope of her duties and authority as a public

official and school principal.

93. Plaintiffs were harmed as a direct and proximate result of Defendant

Principal's incompetence and Defendants' intentional and/or negligent acts or

omissions.

94. Such harm was foreseeable.

95. Asadirect and proximate result of Defendant Principal's incompetence

and Defendants' intentional and/or negligent acts or omissions, Plaintiffs are

entitled to recover damages in excess of Twenty-Five Thousand Dollars

($25,000.00).
SIXTH CLAIM FOR RELIEF
(Negligent Infliction of Emotional Distress)
96. Plaintiffs adopt and incorporate by reference the allegations set forth in

the preceding paragraphs of this Complaint.

97. Defendants had a duty to protect Plaintiffs from harm.

98. Plaintiffs suffered severe emotional distress in that K.M. was diagnosed

with, upon information and belief, Post-Traumatic Stress Disorder, Anxiety, and
exacerbation of symptoms associated with her pre-existing conditions.

99. Plaintiffs were harmed as a direct and proximate result of Defendants'

intentional and/or negligent acts or omissions.

100. Such harm was foreseeable.

101. As a direct and proximate result of Defendants' intentional and/or

negligent acts or omissions, Plaintiffs are entitled to recover damages in excess of

Twenty-Five Thousand Dollars ($25,000.00).

SEVENTH CLAIM FOR RELIEF
(Intentional Infliction of Emotional Distress)
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 102. Plaintiffs adopt and incorporate by reference the allegations set forth in

the preceding paragraphs of this Complaint.

103. Defendants engaged in extreme and outrageous conduct.

104. Defendants' conduct was intended to cause or recklessly indifferent to the

likelihood it would cause severe emotional distress to Plaintiffs.

105. Defendants' conduct in fact caused severe emotional distress to Plaintiffs.

106. Plaintiffs were harmed as a direct and proximate result of Defendants'

intentional and/or negligent acts or omissions.

107. Such harm was foreseeable.

108. As a direct and proximate result of Defendants' intentional and/or

negligent acts or omissions, Plaintiffs are entitled to recover damages in excess of

Twenty-Five Thousand Dollars ($25,000.00).

EIGHT CLAIM FOR RELIEF
(Violation of the North Carolina Constitution)
109. Plaintiffs adopt and incorporate by reference the allegations set forth in

the preceding paragraphs of this Complaint.

110. Article I, Section 15 states "the people have a right to the privilege of education,

and it is the duty of the State to guard and maintain that right." Article IX, Section 2

addresses the duty of the state and local government to provide a uniform system of free

public schools "...wherein equal opportunities shall be provided for all students."

111. Under Article I, Section 19, "no person shall be denied the equal protection of

the laws; nor shall any person be subjected to discrimination by the State because of race,

color, religion, or national origin."

112. These constitutional rights are also codified under N.C. Gen. Stat. § 115C-1.

113. Defendants owed K.M. an open and safe environment for educational services
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under these regulations.

114. The disabled Minor Plaintiff was denied her right to an equal educational

opportunity due to the physical and mental abuse she experienced as a result of Defendant

Principal's harassing and bullying conduct, unreasonable use of physical restraints,

seclusion, isolation, and embarrassment to which the seven-year-old was maliciously and

deliberately subjected.

115. Defendants had substantial control over the negative environment.

116. The educational environment was severe and discriminatory.

117. Defendant Board knew, or in the exercise of due care, should have known of,

Defendant Principal's previous malicious actions, assault and battery of the Minor Plaintiff,

and hostile environment she created.

118. Defendant Board continued to violate Minor Plaintiffs rights by failing

to provide services to which she is entitled subject to the laws, rules, regulations and

policies enacted North Carolina Constitution, State law, the State Board of

Education, the Department of Public Instruction, the Exceptional Children Division,

and its own policies.

119. Plaintiffs were harmed as a direct and proximate result of Defendants'

violations.

120. Such harm was foreseeable and preventable.

121. As a direct and proximate result of Defendants' intentional and/or

negligent acts or omissions, Plaintiffs are entitled to recover damages in excess of

Twenty-Five Thousand Dollars ($25,000.00).

PRAYER FOR RELIEF

WHEREFORE, Plaintiffs respectfully pray that Plaintiffs have and recover of

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Defendants Craven County Board of Education, Sherri Thomas, in her official and

individual capacities, jointly and severally, as follows:

1. Compensatory damages for Minor Plaintiff, KM, in an amount in excess

of twenty-five thousand dollars ($25,000.00);

2. Compensatory damages for Plaintiff Laquita Koonce, the natural

parent and legal guardian of the minor, in an amount in excess of twenty-five

thousand dollars ($25,000.00);

3. The costs of this action, including interest and reasonable attorneys'

fees, tothe extent provided by law;

4. Trial by jury on all issues so triable; and

5. Such other and further relief as the Court deems just and proper.

This the 21st day of March, 2025.

COUCH & ASSOCIATES, PC

Attorneys for Plaintiff

By: Ch
Finesse G. Couch (NC Bar No. 12634)
C. A. Couch (NC Bar No. 31464)
Post Office Box 1527
Durham, NC 27702
Telephone: (919) 688-8786
Facsimile: (919) 683-6394
couch@couchandassociates.com
couchlawi1@gmail.com

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