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Pam Touchard Supplemental Initial Disclosures
Pam Touchard Supplemental Initial Disclosures
COMES NOW the Plaintiff Pam Touchard and provides these supplements to those initial
disclosures filed previously, as follows:
1. Plaintiff has claims for DAMAGES as set forth in the Complaint, as well as other claims that
may be discovered during the course of this cause which the laws hold the Defendants liable
and responsible in an amount to be determined by a jury. Further disclosure will be
supplemented upon further receipt and development of the case.
2. Names of persons now know to Plaintiff with discoverable information. Discovery is ongoing
and other persons may become discoverable and possible witnesses:
a. Pam Touchard
b. Bayleigh Loving – student that took tests for others
c. Dr. Jo Ann Malone – MS State Department of Education Asst. State Superintendent
d. Brian McGarity – MS State Dept. of Education Safe and Orderly Schools Director
e. Barkley Henderson – George County School Board member
f. Wendell Fallon – George County School Board member
g. Derrick Gentry – George County School Board member
h. Jessie Ludgood – George County School Board member
i. Mike Steede – Geroge County School Board member
j. Allison Jordan – Food Service personnel, George County School District
k. Becky Howell – Secretary, George County School District
l. Brenda Denmark – Payroll, George County School District
m. Natasha Henderson – Business Officer, George County School District
Case 1:21-cv-00168-TBM-RPM Document 33-1 Filed 12/09/22 Page 2 of 3
Pam Touchard
By: /s/ Bobby Moak
Bobby Moak MSB 9915
CERTIFICATE OF SERVICE
This is to certify that I have served via electronic mail a true and correct copy of the above and
foregoing document to all counsel of record.