Barnes Law Group, LLC, represents two heroic and committed DeKalb County teachers who are leading a lawsuit against DeKalb County Schools regarding a 2009 “freeze” in funding for a teachers’ retirement benefit known as the TSA (Tax-Sheltered Annuity) Plan. The Barnes Law Group has added a section to their website where you may stay updated on the status of the case. Go to http://www.barneslawgroup.com, and look for a special section titled, “DeKalb Teacher TSA Plan.”

The next hearing in this case is scheduled for Wednesday, August 21, 2013. At that time, the judge will hear arguments on whether to grant class-action status to this case. The hearing is open to the public; further details may be found on the Barnes Law Group website.

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30 Responses to UPDATE: TSA Lawsuit

  1. concerned citizen says:

    This will open all floodgates and should.

  2. It's time for action says:

    We finally have our day in court. We must show the DeKalb County BOE that we are serious about making this a class action suit. SHOW UP, SHOW YOU CARE about the the BOE not following their own policies. You owe it to yourself and your colleagues to make this a priority in your day and get to that courtroom on August 21, 2013. The BOE owes us this money, don’t let them get away with this by thinking someone else will fight for me.

  3. Dekalbite2 says:

    I remember when we voted to opt out of Social Security. The county pledged to put their Social Security contribution into a TSA for teachers. It was a good deal for the county since their contribution remained constant even as Social Security employer contributions went up, thus saving the county hundreds of millions over 30+ years in ever increasing Social Security contributions.

    What were Dr. Lewis and Ms. Tyson thinking when they eliminated the TSA? Obviously, they were not using any critical thinking skills to address the budget crisis. This has been the problem all along – Dr. Lewis, Ms. Tyson, Dr. Atkinson and now Mr. Thurmond prefer to use a hatchet rather than a scalpel. It’s like they have no concept of what it takes to create an environment that encourages student success and have no faith in the abilities of economically disadvantaged students to join the middle class.

    Why can’t we get competent superintendents like Emily Lembeck (Marietta City Schools) or Sam King (formerly Rockdale County Schools)? These two systems have low income students with an ever increasing rate of student achievement because they invested in the core business of the classroom which is attracting and retaining excellent teachers while providing students with reasonable classroom sizes and cutting edge science equipment and technology. Go tour their schools someday. You will be amazed at the difference. Instead we have been stuck for a decade with superintendents who are proponents of the Friends and Family plan.

  4. Could all but the silent troll click the thumbs down on this comment? Let’s turn the world upside down. No games and multiple thumbs up from different browsers. I know that trick. Come on, the sole or few of you who like this comment, grow a pair and express your dissenting views. Are you afraid to?

  5. howdy1942 says:

    I did go out to the Barnes site and did read the lawsuit. I know that this is one side of the argument, but I think the case is very strong. I’m not a lawyer, but I have read about some companies that did not make the required employer Social Security contributions and each did face charges for that action and ordered to immediately pay all back contributions. If the Dekalb County School System did promise to make such payments in lieu of Social Security and did so within the framework of a contract, then DCSS needs to take action to settle this lawsuit. Again, I”m not a lawyer, but I think that if this judge grants class action status, the DCSS could be liable for far more than just the amount of back contributions.

    I think that we had some discussion on the old Dekalb School Watch blog and there was consensus that this move to stop payments without some plan to restore them was really a poor decision. Anyway, my perspective is that if the allegations are true, then the DCSS is very vulnerable and its needs to be setting a lot of money aside. Here we go again with the lawyers! And it all could have been so easily avoided by just doing the right thing. At a minimum, the School Board should have met with the teachers and together have worked out a mutually acceptable plan to insure that our teachers were kept whole. It is apparent that this was not done.

  6. Dekalbite2 says:

    I read it in its entirely as well and agree that it appears to be a strong case. More upsetting than the money involved in this case is the idea that if written, agreed and voted upon Board policy is broken, they can just go back and retroactively change the policy and say such Board policy never existed. This begs the question as to the reason for having Board policies at all. It is the idea of breaking Board policy for the past two years and then passing a change to retroactively wipe out the Board Policy to as Barnes put it “paper over their breach”. They needed better lawyers on risen. Who advised them this would be ok – Josie Alexander, the King and Spalding
    Ayers, Southerland, Asbill lawyers? Or did they even runs this by the lawyers?

  7. howdy1942 says:

    I’m still trying to get my arms around this issue. How many teachers do we have in the Dekalb County School System? What has been, what is, and what will be the impact of this decision on our teachers of the DCSS School Board stopping its contributions/payments into the TSA? Were these payments also stopped for everybody, to include administration? Was the original agreement made in the form of a written contract?

    During the recession, some companies did stop making any matching contributions into a 401(k), but they could not avoid making the required employer contributions into Social Security. Did this TSA replace Social Security? From reading the lawsuit, my understanding is that the teachers agreed to withdraw from the Social Security System and, in its place, to replace employee and employers contributions with employee and employer contributions into the TSA – is that correct? Had the teachers chosen to remain in the Social Security System, both the teachers and the DCSS would have been required by law to make payments into the Social Security System. Why is that not the case in what the DCSS and the teachers agreed to replace Social Security? Has there been any effort to resolve this issue short of the courtroom?

    I am very concerned about the fate of our teachers in Dekalb County. From my perspective, I believe that we ought pay our teachers and provide benefits that are comparable to other school districts in the Atlanta Metro Area. We need to stop playing any games in the classroom such as the alleged “temp” program. We need to treat our teachers with full respect in return for teaching our students and bringing them to the knowledge levels expected. We cannot effectively do that with a high teacher turnover rate, especially within the school year. In my mind, “temp” is just that – temporary. Temps are there when a teacher is out sick, tending to a family emergency, on maternity leave, or similar reason. Our teachers and students need to be our priority – period! We need to provide clean classrooms in properly maintained buildings and provide our teacher and our students with the basic tools they need. If we cannot now do that, then we need to be all about re-prioritizing the way we spend our dollars. If we must, then we need to reduce the size of our administration, especially at the top level. We need to stop buying into every glorified program that comes down the road. We may need to look at reducing the miles our students are transported and insure that they are attending the schools closes to where they reside. We surely don’t need to be paying for the gas and maintenance for those “service sedans” nor do we need to be paying for anyone to drive to/from home. Teachers and students – that should be our primary focus!

  8. teachermom says:

    Howdy, you should be concerned about the teachers. I predict that without a major shift in the working culture the exodus will continue. I have already advised several education students who are graduating to stay away. After working in my classroom (for free) for two weeks late this summer I came out and saw one of those cars in the parking lot of our school. Why is it they can get an (expensive) car and my friend cannot have the (free) courtesy of getting her kids into the feeder school??? Why did they vote on changing attendance lines but seem to be clueless about this issue?

  9. ZBS says:

    A little history in clarification to some questions raised, which information is all a matter of public record in the lawsuit filings: The School Board did not confer with the teachers about eliminating TSA funding. They just did it as a method to meet a budget shortfall. At the time they stopped the funding, the official notice that went out from Crawford Lewis to the teachers indicated that the cut would only last for one year. At the time they made the cut, nobody in the administration was aware of the existence of the Board policy that required a two-year notice before any changes in funding could be made. It wasn’t until almost a year later that the two-year notice was brought to their attention. This was around the time that the funding was supposed to be reinstated. Instead, that is when they “papered over” their breech by eliminating the policy that required the two-year notice and they never reinstated the funding. However, the two-year notice was not only contained in a Board policy, it was contained in the series of resolutions made between 1977 and 1979 whereby the Board withdrew the system from Social Security (which required a two-year notice in order to withdraw) and replaced it with the TSA in response to a concern that was raised about the possibility that funding might be withdrawn by future Boards. When the Board realized it had violated its own policy, it acknowledged that it needed to repay the funding withheld the first year, but has been operating under the assumption that ever since they eliminated the two-year notice clause, they owe nothing further. There were several assurances made that there were ongoing efforts to find funding to pay back the first year, but that has not happened.

    The TSA was explicitly initiated as an Alternative to Social Security, and has been called that ever since its inception. The TRS, a separate state-required pension plan for all Georgia teachers, had already been in existence for many years. The TRS, by itself, without any other retirement plans, satisfies Federal requirements for an alternative to Social Security. However, many metro Atlanta school systems have maintained and continue to maintain some kind of supplement to the TRS as part of their compensation packages for teachers in order to attract and retain good teachers. Cobb County and City of Decatur pay Social Security in addition to TRS. Gwinnett has some kind of program similar to TSA in addition to TRS. Atlanta only has TRS, but the reputation is that Atlanta pays higher salaries in lieu of an additional retirement plan. So it is very likely that teachers are leaving DeKalb to go to systems with more attractive compensation packages, including several that have a retirement plan in addition to TRS.

    The Board has been fighting the lawsuit tooth and nail with a Sutherland Asbill lead attorney flown in from Washington DC at taxpayer expense, who is assisted by several other local Sutherland Asbill attorneys. It has lost key rulings at the trial court level and at the Georgia Court of Appeals and the Georgia Supreme Court. It at least appears that their attorneys are doing everything they can to delay as long as they can, and run up legal bills for both sides.

  10. former dekalb parent says:

    Any employee at a certain pay level or position is on TRS, so any plant engineers, maintenance staff, bus drivers, etc could be part of TRS. For the lower positions, they have ERS, and it their TSA was not discontinued.

  11. dekalbite2 says:


    Are they addressing the issue of the change to the TSA (Alternative to Social Security) that took place in 2003 less than than the two year period that was agreed upon in the late 70s when the BOE withdrew its contributions to Social Security?

    This change took place during Johnny Brown’s reign and eliminated the TSA for incoming teachers until their 4th year of teaching.

    Here is the exact wording in the document. As you can see, the BOE voted on the amendment to the TSA (Alternative to Social Security) on February 12, 2003 and it was effective in a little over one year.


    (As Amended and Restated Effective as of February 12, 2003)

    THIS AMENDMENT to the DeKalb County, Georgia Board of Education Tax Sheltered Annuity Plan, as amended and restated effective as of February 12, 2003 (the “Plan”), is made this ______ day of _______________, 2004 by the DeKalb County, Georgia Board of Education, a political subdivision organized and existing under the laws of the State of Georgia (the “Board”).
    W I T N E S S E T H :
    WHEREAS, the Board sponsors and maintains the Plan for the exclusive benefit of certain of its employees and their beneficiaries and, pursuant to Section 8.3 thereof, the Board has the right to amend the Plan at any time;
    WHEREAS, the Board amended and restated the Plan in its entirety on August 11, 2003, to be effective as of February 12, 2003; and
    WHEREAS, the Board wishes to amend the Plan further at this time by revising the provisions of the Plan relating to eligibility for participation and contribution amounts for certain employees, to revise provisions relating to investment in life insurance, and for other purposes;
    NOW, THEREFORE, the Plan is hereby amended as follows, effective as specified below:
    Section 3.1 of the Plan is hereby deleted in its entirety and replaced with the following section, effective as of March 1, 2004:
    3.1 Initial Participation. Prior to July 1, 2003, an Eligible Employee shall become a Participant in the Plan, and accordingly, be eligible to receive Contributions, on the first date when he or she becomes actively employed by the Employer. With respect to a person whose Start Date as an Eligible Employee is on or after July 1, 2003, he or she shall become a Participant in the Plan, and accordingly, be eligible to receive Contributions, beginning with the first payroll payment that he or she receives for employment as an Eligible Employee after the third anniversary of his or her first Start Date as an Eligible Employee on or subsequent to July 1, 2003, regardless of whether his or her status as an Eligible Employee was continuous between his or her said Start Date and the date on which he or she becomes a Participant in the Plan….”

    Probably because Brown got away with this, Lewis and Tyson figured they could as well.

  12. dekalbite2 says:


    And look at the BOE minutes from 2007 BEFORE the budget crunch. Lewis and the BOE discussed the withdrawal of DeKalb from Social Security:

    January 31, 2007

    The DeKalb County Board of Education held a public budget hearing on Monday, January 31, 2007, at the Freeman Administrative Center, Building A Williamson Board Room, 3770 North Decatur Road, Decatur.

    The meeting was called to order by the Vice Chair at 6:00 p.m.

    Present at the meeting were Vice Chair Lynn Cherry Grant, Elizabeth Andrews, Thomas Bowen, Sarah Copelin-Wood, Jay Cunningham, Bebe Joyner, Jim Redovian, Zepora Roberts, and Superintendent Crawford Lewis. Chair Cassandra Anderson-Littlejohn arrived at 6:20 p.m…………

    ……..Dr. Lewis explained that this is the first meeting in the 2007-2008 budget cycle to receive comments from the public to consider in developing the 2007-2008 tentative budget. The Board will tentatively adopt the budget on April 9, a budget hearing will be held on April 18, and the final adoption of the 2007-2008 budget will be requested at the May 2007 meeting.

    Mr. Marcus Turk, Interim Chief Financial Office, stated that the input received from external stakeholders regarding programs, initiatives, and concerns will be taken into consideration when developing the budget. He opened the floor to public comment. The following five individuals addressed the Board: David Schutten, Sally Arnold, Lisa Morgan, Lila Miller, and Jackie Henry.

    A brief discussion followed regarding the system’s withdrawal from Social Security and the need to revisit the use of the substitute teacher list. Ms. Anderson-Littlejohn suggested creating a separate emergency substitute list. Mr. Bowen expressed the need to look at ways to improve teacher retention.

    David Schutten was there. Perhaps he could say what exactly what was said with regards to DCSS’s withdrawal from Social Security?

  13. Below is a link to a discussion on the old blog on this topic —

    Wednesday, March 30, 2011
    Teachers file lawsuit over DeKalb retirement plan

    The plan was established in 1979 as an additional benefit to educators and an alternative to social security. It is separate from the state retirement fund and is paid into individual employee accounts, tax sheltered until withdrawn. The contributions make up about 6 percent of each employee’s annual salary – about $20 million per year, according to attorneys who filed the suit and board members.

    The lawsuit, filed last week, accuses the board of reneging on its commitment by freezing contributions and failing to give the two-year notice beforehand, as required by board policy.

    “This is about keeping promises the board made to employees,” said attorney John Salter of the Barnes Law Group, who is representing the educators.

    School board chairman Tom Bowen said the board did not act improperly and has the right to amend its own policies. According to the suit, the board voted to waive the two-year notice in 2010, a year after the contributions were halted.

    . . .

  14. And another —

    Monday, January 23, 2012
    Budget decisions can sometimes return to haunt
    It may be time to pay that piper.

    Read this article by Ty Tagami at the AJC:
    Suit could cost DeKalb millions

  15. dekalbite2 says:

    It looks like Lewis and the BOE decided that the employees that were in PERS (Public Employee Retirement System – non teaching personnel) would be exempt from the 3 year wait period for the TSA:

    OF THE

    February 9, 2004

    Mr. Jim Landon, attorney for Jones Day, recommended that the Board approve an amendment to the Board’s Tax Sheltered Annuity Plan for selected, identified employees. He explained that the amendment is comprised of three elements. ……The second element is to include those employees who are also participants in the public school retirement system in the Board sponsored TSA from their date of hire rather than the three-year waiting period imposed by the Board in July 2003. The third element is to increase the contribution made for those employees who participate in the TSERS to 7.5% from the current 6% or 7.1% of their compensation based on their date of hire.”

  16. dekalbite2 says:

    IMO –
    This was a very lazy and “no critical thinking” decision on Lewis’s and Tyson’s part. They just looked at the TSA (Alternative to Social Security) for teachers and decided that this was an easy way to whack $20,000,000 from the budget. That way they could keep all of those non teaching Friends and Family members.

    Ms. Tyson’s entire budget was just whacking off the TSA or eliminating 200 paraprofessionals or letting 300 teaching positions lay vacant as those hundreds of teachers left DeKalb. This was an easy way to balance the budget, but not easy on kids. Their achievement suffered terribly:

    Look closely at her budget the BOE adopted and you can see why student achievement has declined precipitously:

    Meanwhile the BOE applauded her for no one losing their jobs. How about students losing their opportunities? Not one word was said by Ms. Tyson or the BOE about students’ needs.

    When Ms. Tyson eliminated those 300+ teachers by not filling their positions as they left, she might as well have let 300+ teachers go as far as students are concerned. If a 3rd grader advances to 3 teachers rather than 4 teachers because Ms. Tyson has not filled the position of that 4th grade teacher who left, he can be in a class of 34 versus 24. What difference if he needs some special attention. It does not matter to that 4th grader if the loss of a teacher is due to letting her go versus not filling her position. Either way he is sitting in an enormous class with little individual attention. The outcome is the same no matter the intentions. Outcome based decisions for students did not play a part in Ms. Tyson’s 2010-11 or 2011-12 budgets.

  17. And – once again, we remind you ‘who’ was the right arm leader during this horrible, short-sighted, ridiculous, harmful budget cut — and who as interim leader, continued the suspension of the cutting of these retirement contributions — Ramona.


  18. Dekalbite2 says:

    Ms. Tyson as Chief of Staff/Chief Strategy Officer is Mr. Thurmond’s only direct report besides his Executive Assistant. It must be tempting to rely on her since she has been the superintendent and is politically connected. However, she increased class sizes to unmanageable numbers and ran a deficit budget (although the 2011-12 budget was presented as surplus, it was shown to be a deficit budget by Atkinson and forced draconian cuts to the classroom and tax increase for taxpayers to balance it). Most importantly, the student achievemenet rate declined precipitously during Ms. Tyson’s time as superintendent.

    Look at the Organizational chart to see that Ms. Tyson (Chief of Staff/Chief Strategy Officer) is Mr. Thurmond’s most trusted advisor:

    Click to access organizational-chart.pdf

    Mr. Thurmond needs to look at the data. The data says Ms. Tyson was not successful in the financial and academic management of DeKalb Schools. Data, data, data – outcomes need to drive DeKalb, but it is still all about relationships rather than competence.

  19. Dekalbite2 says:

    Looking at the Organizational Chart, it appears that Mr. Thurmond and Ms. Tyson, Chief of Staff, are working in tandem:

    Click to access organizational-chart.pdf

    Taxpayers/parents need to ask themselves how Ms. Tyson’s increase in class sizes and decrease in numbers of teachers worked out for students during her tenure. The data shows a sharp decrease in student achievement.

  20. ZBS says:

    Concerning the three-year waiting period for new hires that was imposed in 2003, that is a thorny legal issue and apparently not addressed in the current lawsuit. There appears to be no authority allowing the Board to have imposed that, but then again, there may not be any authority saying they couldn’t. Looking at it from a contract analysis, it might be hard to argue that new hires were having their contract breached, because they were first entering into a contract and agreeing at the beginning to the three-year waiting period. Certainly, anyone who was hired after 2003, expecting the TSA to kick in on commencement of their fourth year and all years subsequent, only to find it suspended at the commencement of their fourth or subsequent years would be included in the current class, because they had a contractual expectation that it would begin in their fourth year, and it didn’t. Just as other teachers hired before 2003, who also had a contractual expectation that the TSA would continue.

    Concerning an earlier comment about some private companies cutting back on their 401(k) contributions as cost-cutting measures, if they can do it legally and still attract and retain good employees with good morale, more power to them. The issue with the TSA is that the funding was not terminated legally, and it has greatly affected employee morale and the ability to retain good employees.

  21. bettyandveronica1 says:

    I am telling you folks as sure as the sun comes up tomorrow…Tyson is being groomed. It started at the state board hearings.

  22. Dekalbite2 says:

    Tyson ran what turned out to be a budget deficit, eliminated hundreds of teaching positions, and increased class sizes to unprecedented levels. Most importantly, she brought a new low to DeKalb students’ rate of achievement. This is the facts. They can’t change her record.

  23. Dekalbite2 says:


    Even DeKalb says the TSA was set up as an alternative to Social Security:

    Board TSA
    The DeKalb County Board of Education elected to opt out of Social Security in 1978. As an alternative to Social Security, the Board of Education established the “Board TSA” for the School System’s employees. The Board of Education provides contributions into an account for each eligible employee (thus the name “Board” TSA). The employee is not allowed to make contributions into their Board TSA account. The employee is allowed to select the investments in which he/she desires to place the funds.

    The Board TSA is collectively considered an institutional investor. There are no fund fees or expenses charged to the employees’ account for investment products offered within the Board TSA. This is a significant and very important difference from the Optional TSA program in which all companies charge investment and expense fees on their products.”


  24. Dekalbite2 says:

    The real downside for teachers is that their Social Security benefits will actually be “penalized” if they collect a pension for a school system that does not pay into Social Security. For example, a teacher who works for 20 years in jobs (teaching or otherwise) that require her to pay into Social Security and then come work for DeKalb and ends up retiring from DeKalb will find herself “penalized” when she goes to collect Social Security due to the Windfall Provision (see lik below). This happened to me and I am collecting considerably less Social Security (around 40%) because I retired from DeKalb even though I paid into Social Security for 15 years, most of them at the top rate when I was in the business world. The Board TSA (also called the Alternative to Social Securiy) offset this to a large extent, but now teachers not only do not get the Board TSA, in addition they will not get the Social Security benefits they would have if they never worked for DeKalb. If they retire from DeKalb , they will incur a penalty on their Social Security benefits – a penalty reserved for anyone who retires from a system that does not contribute to Social Security. This is a catch 22 for teachers, many of whom have come from other systems or jobs where they paid into Social Security.

    Teachers near retirement in DeKalb who have a considerable investment in Social Security contributions need to read this very carefully (this link has a Calculator that will let you know the penalty you will see in your Social Security payout).

    And BTW there is a worse penalty for your heirs as well since a substantial amount Social Security benefits (sometimes all of them) will not pass to your spouse if you retire from DeKalb. And this can affect you as well since trying to collect your spouses benefits if he/she dies will be problematic (those are greatly reduced as well) if you retire from DeKalb (or any system that does not pay into Social Security). I have a friend who retired from APS and cannot get any Social Security spousal benefits even those she is a widow because she has a pension from a system that does not pay into Social Security.

    The financial penalties for teachers is grave not just because DCSS suspended the TSA but because their Social Security benefits and any of their families will be penalized for the rest of their lives. Other metro school systems do not have these negative compensation concerns. How can DCSS be competitive with other metro school systems – well – the simple answer is we can’t.

  25. Consider this document on the “Compensations and Classification” page on the DCSS website. It is current. Scroll down to the bottom of this document. Again, this is supposed to be up-to-date.


  26. This is the page I meant to send you to in my post above:

    Click to access rewards-package.pdf

  27. ZBS says:

    Apparently, the PSERS alone is not a legally sufficient alternative to Social Security as the TRS is. So the Board had to retain funding for the TSA for the employees on PSERS in order to comply with Federal law. That is not necessary for employees on TRS. The fact that TRS alone is an adequate alternative for Social Security is not the issue in the lawsuit. The issue is that TSA funding could not be reduced or eliminated without a two-year notice, regardless of the fact that TRS remains.

  28. concerned citizen says:

    Ramona has more than had enough time to mess with the school system. She is utterly nutty. We MUST get her out of here! BettyandVeronica – I believe you know what you are talking about, but I need to ask “who” and “why” and” for what”?

  29. Fred in DeKalb says:

    @Dekalbite2, thanks for sharing the current organization chart. When you have the time, I’d appreciate you sharing your opinion regarding the positions you believe aren’t needed to effectively support to school district.

    School districts are considered to be customer service oriented meaning they may have additional staff to actually speak to someone. Some may argue that many businesses have significantly reduced personnel by using voicemail and they don’t have much administrative support. Then again, when a parent calls about concerns with a school, they typically want to know they have been heard.

  30. From the Barnes law group website —

    DeKalb County Teachers Retirement

    In 2009, the DeKalb County School District stopped payment on a retirement fund for district employees. Plaintiffs claim this was in direct violation of the contract the district agreed to and has resulted in a loss of millions of dollars for district employees.

    DeKalb teacher Elaine Gold and school psychologist Amy Shaye filed suit against the district in June 2011. Their suit seeks class action status, which would allow other DeKalb Schools employees to join the suit against the district.

    The next hearing in the case will take place on August 21 at 9:00am before DeKalb Superior Court Judge Mark Anthony Scott. Judge Scott will hear oral arguments on various issues, including whether to grant class-action status to the case. This hearing is open to the public. For those unable to attend, please check back here for regular updates.

    Below is a summary of the case status.

    June 2011 Suit filed.
    [Click here to read the First Amended Complaint]
    October 2011 DeKalb Superior Court Judge Clarence Seeliger issued several orders, including a denial to the school district to dismiss the breach of contract claim.
    November 2012 The school district appealed to the Georgia Court of Appeals, which upheld Judge Seeliger’s decision to allow the contract claim to proceed.
    August 21, 2013 Hearing at 9:00am before DeKalb Superior Judge Mark Anthony Scott on various issues, including whether this case will be granted class action certification.
    This hearing is open to the public.
    [Click here to read the Motion for Partial Summary Judgment]
    [Click here to read our Reply Brief regarding Class Certification]

    For information on DeKalb Superior Court, please visit their website.

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