Dantzler-Williams Lawsuit

ELECTRONICALLY FILED - 2023 May 15 9:20 AM - CHARLESTON - COMMON PLEAS - CASE#2023CP1002308
STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS

COUNTY OF CHARLESTON ) FOR THE NINTH JUDICIAL CIRCUIT
RANDALL WILLIAMS, Personal ) Civil Action No.:

Representative of the ESTATES OF )
SHANICE R. DANTZLER-WILLIAMS and )
MIRANDA R. DANTZLER-WILLIAMS. )
and )
)
BETTY SIMMONS, Personal Representative )
of the ESTATE OF STEPHANIE )
DANTZLER )
)
Plaintiffs, ) SUMMONS
)
v. )
)
EMILY PELLETIER; )
CLINTON SACKS; )
CHARLESTON COUNTY SHERIFF’S )
OFFICE; and )
CHARLESTON COUNTY. )
)
Defendants, )
TO THE DEFENDANTS NAMED ABOVE:
YOU ARE HEREBY SUMMONED and required to answer the Complaint herein, a copy
of which is herewith served upon you, and to serve a copy of your answer to this Complaint upon
the subscriber, at the address shown below, within thirty (30) days after service hereof, exclusive
of the day of such service, and if you fail to answer the Complaint, judgment by default will be
rendered against you for the relief demanded in the Complaint.
[Intentionally blank – signature page to follow]
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ATTORNEYS FOR PLAINTIFF
RANDALL WILLIAMS, PERSONAL
REPRESENTATIVE
/s/ Richard A. Hricik

_____________________________
Richard A. Hricik (#16871)
THE LAW OFFICES OF
RICHARD A. HRICIK, PA
941 Houston Northcutt Blvd. Ste 204
Mt. Pleasant, SC 29464
(t) 843.849.0136
[email protected]
Marvin R. Pendarvis (#101832)

Pendarvis Law, LLC
8420 Dorchester Rd. Ste. 202
North Charleston, SC 29420
O | (843) 990-9847
[email protected]
ATTORNEY FOR PLAINTIFF

BETTY SIMMONS, PERSONAL
REPRESENTATIVE
/s/ Clifford Bush, III

_____________________________
Clifford Bush, III (#17026)
The Law Office of Clifford Bush, III, LLC
28 Old Jericho Road
Beaufort, South Carolina 29906
(843)379-9500(Office)
[email protected]
Charleston, South Carolina
May 15, 2023
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STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS
COUNTY OF CHARLESTON ) FOR THE NINTH JUDICIAL CIRCUIT
RANDALL WILLIAMS, Personal ) Civil Action No.:

Representative of the ESTATES OF )
SHANICE R. DANTZLER-WILLIAMS and )
MIRANDA R. DANTZLER-WILLIAMS. )
and )
)
BETTY SIMMONS, Personal Representative )
of the ESTATE OF STEPHANIE )
DANTZLER )
)
Plaintiffs, ) COMPLAINT
)
v. ) (Jury Trial Requested)
)
EMILY PELLETIER; )
CLINTON SACKS; )
CHARLESTON COUNTY SHERIFF’S )
OFFICE; and )
CHARLESTON COUNTY. )
)
Defendants, )
NOW COMES Plaintiff Randall Williams, as Personal Representative of the Estates of
Shanice R. Dantzler-Williams and Miranda R. Dantzler-Williams, and Betty Simmons, as
Personal Representative of the Estate of Stephanie Dantzler, for their Complaint and alleges as
follows:
PARTIES
1. Plaintiff Randall Williams is sui juris, natural father and the duly appointed
Personal Representative of the Estates of his natural daughters, decedents, Shanice R. Dantzler-
Williams (hereinafter “Shanice”) and Miranda R. Dantzler-Williams (hereinafter “Miranda”) by
Order of the Probate Court of Colleton County.
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2. Plaintiff Betty Simmons is sui juris, natural mother and the duly appointed Personal
Representative of the Estate of her daughter decedent, Stephanie Dantzler (hereinafter
“Stephanie”) by Order of the Probate Court of Colleton County.
3. Defendant Emily Pelletier (hereinafter “Pelletier”) is sui juris, and was at all times
relevant, a citizen and resident of the State of South Carolina, who was acting under color of law
and within the course and scope of her employment and agency as a Deputy of the Charleston
County Sheriff’s Office. She is also sued in her individual capacity for compensatory and punitive
damages under federal law.
4. Defendant Clinton Sacks (hereinafter “Sacks”) is sui juris, and was at all times
relevant, a citizen and resident of the State of South Carolina, who was acting under color of law
and within the course and scope of his employment and agency as a Deputy of the Charleston
County Sheriff’s Office. He is also sued in his individual capacity for compensatory and punitive
damages under federal law.
5. Defendant Charleston County Sheriff’s Office (“CCSO”) is a governmental entity
organized and existing pursuant to the laws of the State of South Carolina and is located within
Charleston County who acted by and through its agents / employees, and Deputies, including, but
not limited to, Defendants Pelletier and Sacks, and its primary and final policymaker Sheriff Kristin
Graziano (“Graziano”).
6. Defendant Charleston County (“Charleston County”) is a governmental
agency/entity existing under the laws of the State of South Carolina and located in Charleston
County, South Carolina who at all times acted by and through its agents, servants, and/or
employees including, but not limited to:
a. Its primary policymakers Charleston County Council and the County Administrator
as County Council serves as a link between County government and the citizens,
municipalities and agencies located within Charleston County, and also represents
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the area's concerns and interests. Charleston County and its Council also budgets
for, purchases, owns, maintains, insures, entrusts and furnishes the patrol vehicles
and equipment (“County Vehicles”) used by CCSO and its Deputies, (including the
County Vehicles used by Deputies Pelletier and Sacks), as well as budgets for and
provides funding for the entirety of the operations of the CCSO, (roughly $80
million for 2021) that includes, as employees of the County, all Deputy training and
salaries, for the benefit and public safety of the citizens of the County of Charleston;
and
b. The call takers, law dispatchers, law enforcement dispatchers, supervisors, and its
Director, as the primary policymaker of the Charleston County Consolidated 911
Center aka Consolidated Dispatch Center (“Dispatch”), who are all County
employees within that agency/department of Charleston County, who were all
acting within the course and scope of their employment and agency;
7. This Court has subject matter jurisdiction over all claims alleged and personal
jurisdiction over the parties.
8. Plaintiffs bring these survival, wrongful death and civil rights actions on behalf of
the decedents and their heirs and statutory beneficiaries pursuant to S.C. Code Ann. § 15-51-90, §
15-5-10, 42 U.S.C. § 1983 and 42 U.S.C. § 1988 as well as the common law of South Carolina.
9. Venue is proper in that a substantial part of the acts and omissions alleged herein
occurred in Charleston County, South Carolina.
ACTS & OCCURRENCES
10. Each and every act of negligence, gross negligence, recklessness, and/or willful
and wanton conduct by any one or more of the Defendants, and their incorporation into the causes
of action set forth infra, constitute multiple acts and/or occurrences as may be determined by a
jury, under applicable South Carolina law and/or statutes, including § 15-18-10 et seq.
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FACTUAL ALLEGATIONS
DEPUTY DRIVING DATA
11. The County, by and through its Dispatch, captures and records every 6-30 seconds,
depending on the County Vehicle, the exact speed, heading, and location of the driving of every
on-duty Deputy in every County Vehicle, including as to any Incident that a Deputy is responding
to (hereinafter “Deputy Driving Data”). See excerpts from Deputy Driving Data shown below:1
Date_Time Latitude Longitude Radio_Name Location Heading Speed City

2021-12-03 17:29:46.687 | 32840956| 79967865 $0236 INTERSTATE 26 WEST\BAKER HOSPITAL BLVD | 310 | 57 | NORTH CHARLESTON
2021-12-03 17:30:10.707 32842293 79974871 Reve I) INTERSTATE 26 EAST\26 E / COSGROVE AV ON RAMP pe} Ey/ ea mete 102)
2021-12-03 17:30:34.833 32844638| 79979168 $0236 26 W 216B OFF RAMP\COSGROVE AV 317 28 NORTH CHARLESTON
2021-12-03 17:31:10.697 32845571 | 79979452 $0236 COSGROVE AV\26 W 216B OFF RAMP 6 25 NORTH CHARLESTON
2021-12-03 17:31:46.730 32846592 | 79979332 $0236 COSGROVE AV\AZALEA DR 350 5 NORTH CHARLESTON
2021-12-03 17:32:34.720 32847068| 79980262 $0236 DUNDEE\BAILEY DR 280 25 NORTH CHARLESTON
12. Deputies also receive turn-by-turn driving directions in their County Vehicles from
Dispatch that provides the safest and most direct route for the Deputies to follow when responding
to Incidents.
13. Deputy Driving Data further contains each and every time a Deputy engages in a
“Route Deviation” and does not follow the turn-by-turn driving instructions provided to them by
Dispatch in responding to an Incident. See excerpts from Deputy Driving Data shown below:
Date_Time Activity Location Comment

2021-12-03 21:24:20.373 Route Deviation CAMP\~1 Unit SO236 deviated from original dri[redacted]
2021-12-04 02:58:01.920 Route Deviation RIVER\JENKINS FARM RD Unit SO236 deviated from original dri[redacted]
2021-12-04 18:45:32.113 Route Deviation MAYBANK HWY\OLD FOLLY RD Unit SO236 deviated from original dri[redacted]
2021-12-05 03:05:22.273 Route Deviation RIVERLAND\CAMP RD Unit SO236 deviated from original dri[redacted]
2021-12-06 03:17:00.757 Route Deviation MAYBANK\BROWNSWOOD RDUnit SO236 deviated from original dri[redacted]
2021-12-09 21:19:36.407 Route Deviation RIVER\ABBAPOOLA RD Unit SO236 deviated from original dri[redacted]
14. The County further archives all Deputy Driving Data, such that every minute of
Deputy driving can be easily retrieved, reviewed, and audited at any time to see each and every
time a Deputy was either speeding and/or deviating from Dispatch provided turn-by-turn driving
1
Latitude and Longitude Data is presented without spaces and 32842293 is actually 32° 84’ 42.293”
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instructions in their County Vehicle.
15. The existence of this Deputy Driving Data means that every act of dangerous and/or
unlawful Deputy driving behavior, including those engaged in reckless and unlawful speeding, as
well as those Deputies deviating from the turn-by-turn driving directions provided by Dispatch, is
at all times captured, known, and easily reviewable by the County, CCSO and/or Sheriff Graziano
and her staff.
16. Upon information and belief, per past and current CCSO policy and custom, the
only time anyone at CCSO or Charleston County has possibly viewed Deputy Driving Data is after
a Deputy has caused a crash with their vehicle. (emphasis added).
17. Upon information and belief, even after a Deputy crash, the after-the-fact
investigations do not always include reviewing Deputy Driving Data by CCSO, and even when
done so, are incredibly limited to the crash itself and not the entire driving history of the Deput(ies)
involved in the crash at issue nor is the data provided to other investigative agencies such as the
South Carolina Highway Patrol (“SCHP”).
THE TRAINING FAILURES OF DEPUTY PELLETIER
18. As was extensively documented and publicly reported2, the training records of
Deputy Pelletier, just six months before she caused the deaths of mother Stephanie Dantzler, and
her daughters Shanice and Miranda Williams on 5/8/22 in The Crash, showed numerous instances
where Deputy Pelletier: (1) struggled tremendously with geography, including an inability to know
her location (and follow driving directions); and (2) operated her County Vehicle in a dangerously
unsafe manner including driving through a Stop Sign during training without using her emergency
lights as well as engaged in unsafe and dangerous passing while driving.
2
“Docs: Charleston deputy charged in crash ‘struggled’ behind wheel in training,” Sabol, Blair: Jan. 6, 2023
https://www.live5news.com/2023/01/06/docs-charleston-deputy-charged-crash-struggled-behind-wheel-training/
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19. Specifically, on 10/24/21, her 24th day of training, she did not know her way around
a District she had worked in over the last two days, but was still graded that day as a 4 (high
acceptable) Driving/ Orientation- Non-Stress Conditions.3
a. Her Field Training Instructor noted: “Deputy Pelletier needs to focus on learning
her district more and paying attention to her surrounding streets.”
b. Pelletier herself wrote, “Today I feel I could improve on my knowledge of the

district I am working.”
20. Again, on 10/28/21, her 26th day of training, she again did not know her way around
a District, but was still graded that day as a 2 (acceptable) Driving/ Orientation-Non-Stress
Conditions.
a. Her Field Training Instructor noted: “Deputy Pelletier continues to struggle

tremendously with geography. Deputy Pelletier had worked the east district for
nearly 6 weeks in phase one and still has no idea where she is at or landmarks. I
would ask her to tell me what community she was in and she could not tell me.”
“She needs to use her resources she has available while on shift and trust them.”
b. Pelletier herself wrote, “I need to do better with geography. There is no excuse for
not knowing the location when I am in the East…”
21. On 11/1/21, on her 27th day of field training, she turned off her emergency lights
and disregarded a stop sign without clearing the intersection but still was graded that day as a
2 (acceptable) in Field Performance – Driving/Stressful Conditions. (emphasis added).
a. Her Field Training Instructor noted: “Deputy Pelletier and I spoke about the
incident and how to break tunnel vision to eliminate simple mistakes that can have
greater consequences while conducting her job.”
b. Pelletier herself wrote, “I also need to be more observant when running Code 3.”
22. On 11/15/21, on her 34th day of field training, she drove Code 3 (lights and sirens)
and could have caused a head-on collision but still was graded that day as a 3 (acceptable) in Field
3
CCSO’s own Field Training Evaluation Form uses a Rating Scale of 1-5 in evaluating conduct with the grade of 1
as the only grade demonstrating Unacceptable performance.
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Performance – Driving/Stressful Conditions.
a. Her Field Training Instructor noted: “I advised Deputy Pelletier we could’ve been
involved in a head on collision… Deputy Pelletier was advised to just slow down
and wait for others to move out of the way where she could safely proceed around
and get to her destination.”
b. Pelletier herself wrote, “Today I felt I could have improved on being more aware
of my environment while running code…”
23. The next day, on 11/16/21, on her 35th day of field training, she drove Code 3
(lights and sirens) and was graded that day as a 3 (acceptable) in Field Performance –
Driving/Stressful Conditions.
a. Her Field Training Instructor noted: “Deputy Pelletier has to work on her code 3
response and decision making while running code and which routes would be best
to take when traffic is extremely heavy and maneuvering slow and methodical.”
b. Pelletier herself wrote, “Today I felt I could improve on finding better ways to get
through traffic while running code that is both safe and efficient.”
24. After only 7 more training days under a Field Training Instructor, on 11/30/21 she
completed her final field training phase and was recommended for advancement.
25. Thereafter, in accordance with CCSO policy and/or custom, Deputy Pelletier was
(1) never rated as unacceptable; (2) her Deputy Driving Data was never reviewed; and (3) she
received no monitoring, follow-up, or remedial training of any kind.
26. Thereafter, Deputy Pelletier’s Driving Data showed numerous instances where
she disregarded the turn-by-turn driving directions provided by Dispatch and engaged in Route
Deviations.
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27. The following is a list of Deputy Pelletier’s Route Deviations in the one month
following her recommendation for advancement. (emphasis added)

2021-12-04 02:58:01.920 Route Deviation RIVER\JENKINS FARM RD Unit SO236 deviated from original dri[redacted]
2021-12-04 18:45:32.113 Route Deviation MAYBANK HWY\OLD FOLLY RD Unit SO236 deviated from original dri[redacted]
2021-12-06 03:17:00.757 Route Deviation MAYBANK\BROWNSWOOD RDUnit SO236 deviated from original dri[redacted]
2021-12-09 21:19:36.407 Route Deviation RIVER\ABBAPOOLA RD Unit SO236 deviated from original dri[redacted]
2021-12-10 00:32:32.800 Route Deviation 503 Main Rd [CIRCLE K (MAIN/RIVER)]
Unit SO236 deviated from original dri[redacted]
2021-12-10 01:36:21.350 Route Deviation RIVER\MAYBANK HWY Unit SO236 deviated from original dri[redacted]
2021-12-15 02:58:02.123 Route Deviation RIVERLAND\DAWSON RD Unit SO236 deviated from original dri[redacted]
2021-12-17 18:14:31.277 Route Deviation COSGROVE AV\26 E / COSGROVE Unit
AVSO236
ON RAMP
deviated from original dri[redacted]
2021-12-18 02:49:34.677 Route Deviation MAYBANK\WALTER DR Unit SO236 deviated from original dri[redacted]
2021-12-18 17:52:59.660 Route Deviation JAMES ISLAND EXPWY\JAMES ISLAND
Unit SO236
EXPWY
deviated
ON RAMP
from original dri[redacted]
2021-12-19 03:35:44.243 Route Deviation RIVERLAND\WOODLAND SHORES Unit
RDSO236 deviated from original dri[redacted]
2021-12-19 05:32:31.360 Route Deviation WOODLAND SHORES\WOODLAND UnitSHORES
SO236 deviated
RD from original dri[redacted]
2021-12-19 18:05:15.823 Route Deviation MAIN\MAIN RD Unit SO236 deviated from original dri[redacted]
2021-12-19 19:37:25.650 Route Deviation MAYBANK\FENWICK HALL ALY Unit SO236 deviated from original dri[redacted]
2021-12-19 21:18:09.853 Route Deviation FOX CROFT\BIRCHDALE DR Unit SO236 deviated from original dri[redacted]
2021-12-20 02:04:26.833 Route Deviation MAYBANK\HEADQUARTERS PLANTATION
Unit SO236DR
Unit SO236DR
2021-12-23 18:30:08.000 Route Deviation FOLLY RD\COUNTRY CLUB DR Unit SO236 deviated from original dri[redacted]
2021-12-27 19:41:03.770 Route Deviation MAIN\CHISOLM RD Unit SO236 deviated from original dri[redacted]
2021-12-27 21:26:42.913 Route Deviation BOHICKET\PARTNERSHIP LN Unit SO236 deviated from original dri[redacted]
2021-12-28 03:42:07.440 Route Deviation MAYBANK\WALTER DR Unit SO236 deviated from original dri[redacted]
2021-12-28 04:47:34.427 Route Deviation N EDENVALE\BOHICKET RD Unit SO236 deviated from original dri[redacted]
Unit SO236DR
28. In the 5 months that followed, Deputy Pelletier’s Driving Data showed she engaged
in a consistent pattern of Route Deviations and an inability to follow the turn-by-turn driving
directions provided by Dispatch.
29. The following is a list of the total of the 130 times Deputy Pelletier’s Route
Deviations appeared in her Deputy Driving Data in response to her Incident Responses in the 5
months preceding The Crash that killed Stephanie, Shanice and Miranda, set forth in Exhibit A –
Pelletier’s Route Deviations, and incorporated by reference.
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DEPUTIES ARE NOT AUTHORIZED TO SPEED UNLESS IT IS AN EMERGENCY
30. CCSO Deputies regularly and routinely receive calls for service from Charleston
County Consolidated Dispatch (“Dispatch”) who receives 911 calls from the public.
31. The Emergency Driving Code Responses of Deputies are classified as either Code
1, 2, or 3 depending on the threat to public safety and the urgency of the response needed. (See
CCSO Vehicle Operations Policy 1-08; CCSO Emergency Vehicle Operations & Driving Course
Materials)
32. The call of a “Stalled Vehicle” mandates the Deputy to respond Code 1 and follow
Non-Emergency Vehicle Operations per South Carolina law and CCSO Policy, that requires the
responding Deputy to:
a. Respond via the most direct route; and
b. Obey all traffic laws.
33. Deputies also receive turn-by-turn driving directions in their County Vehicles from
Dispatch, providing the safest and most direct route for the Deputies to follow to respond.
34. In responding Code 1, using emergency lights and audible sirens is neither
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authorized nor necessary as a Deputy responding Code 1 is legally required to obey all traffic laws
and travel at the posted speed limit.
35. Deputies know they must at all times obey all traffic laws unless they are
specifically granted the legal privilege to disregard them as set forth in South Carolina law.
36. Further, Deputies also know that if, and only if, they are so authorized to exceed the
posted safe speed limits and disregard other traffic laws, the use of emergency lights and audible
siren to warn others is mandatory.4 (emphasis added).
THE UNLAWFUL “RACING5” OF SACKS & PELLETIER TO A NON-EMERGENCY
37. At approximately 10:30 p.m. on Mother’s Day, May 8, 2022, Deputies Pelletier and
Sacks were working in an official law enforcement capacity for CCSO, in uniform and driving
County Vehicles owned by Charleston County and furnished to CCSO.
38. At that time, Deputies Pelletier and Sacks were finishing up a call and were located
on Edisto Island near Jehossee Road.
39. At approximately 10:42 p.m. Defendant Pelletier received a call from Dispatch of
a non-emergency Stalled Vehicle on Highway 17 and responded Code 1.
40. Deputy Sacks, who had been a Deputy for approximately six (6) years at the time,
was not dispatched to the call but decided to respond as well (Code 1) because nothing else was
going on. (“There were only two of us, so we were rolling together, so I got out with it.”) (5/11/12
Deputy Sacks Interview by SCHP 4:46-4:55).
4
The only exception for not using emergency lights and audible sirens while speeding is for a Code 2 Response
when the Deputy is engaged in surveillance, responding to a crime in progress, or obtaining evidence of speeding.
5
The term “Racing” is used to describe the outrageous and life-threatening speed of the driving of Deputies
Pelletier and Sacks in response to the Stalled Vehicle call, although the evidence set forth infra is certainly capable of an
inference that Pelletier and Sacks engaged in a “race” with each other to see who could get to the Stalled Vehicle first.
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41. Deputy Sacks further knew that Deputy Pelletier was a recently hired Deputy who
was unfamiliar with the area they were patrolling.
42. Given the non-emergency Stalled Vehicle call, and their Code 1 responses, both
Deputy Sacks and Pelletier knew they were legally required to obey all traffic laws in responding.
43. Deputies Pelletier and Sacks both received turn-by-turn driving directions in their
County Vehicles from Dispatch that they were to follow to respond to the Stalled Vehicle.
44. The turn-by-turn driving directions from Dispatch directed Deputies Pelletier and
Sacks to travel up Highway 174 from Edisto Island toward Highway 17, then turn right on Highway
17 to reach the Stalled Vehicle. (See blue line on map below broken down into Sections A-D):
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45. Deputy Pelletier’s and Sacks’ Driving Data from each of their County Vehicles,
showing the exact time, vehicle speed, latitude, and longitude of their entire route of travel from
the beginning of this call until The Crash is set forth and summarized in table form along with
explanations. See Exhibit B - Pre-Crash Deputy Racing Data - Compared; Exhibit C – Deputy
Pelletier’s Driving Data; and Exhibit D – Deputy Sacks Driving Data and are all incorporated
herein by reference and collectively referred to as “Deputy Racing Data”.6
46. Deputy Sacks admitted he and Deputy Pelletier both left the location on Highway
174 near Jehossee Road at the same time. (“So, Deputy Pelletier and myself were on Edisto
Island.” … “We both left Edisto together.”) (5/11/12 Deputy Sacks Interview by SCHP 1:14-1:28).
47. As the Deputy Racing Data shows, Deputy Sacks (SO158) was the first to leave the
scene and as the senior Deputy, set the example for, assisted, and encouraged the new Deputy
Pelletier (SO236) to disregard the traffic laws and not use emergency lights and sirens in
responding to this non-emergency call of a Stalled Vehicle:

suonai a
fe ws
King's Farm Market
PELLETIER SO236 SO158 SPEED SO236 SO158 SACKS Feet ELAPSED

Date_Time Latitude Speed Speed LIMIT Over Limit Over Limit Date_Time Latitude Behind TIME
2022-05-08 22:39:25.787 32583470 0 0 55 2022-05-08 22:38:41.160 32583470
2022-05-08 22:42:23.880 32584203 43 50 55 2022-05-08 22:42:21.193 32584203 0:00:23
SACKS is leading PELLETIER
PELLETIER gets to identical Latitude 2.7 secs after SACKS (Latitude increases moving towards Hwy 17 from Edisto)
6
Note: Exhibit B - Pre-Crash Deputy Racing Data includes additional data and explanatory notes that is not in their
individual Deputy Driving Data, including the speed over the speed limit, approximate elapsed time of the response, and an
estimate of the distance Pelletier was behind Sacks as they sped up Hwy 174 by calculating latitude differentials (distance
apart) at the same points in time.
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48. As Deputies Sacks and Pelletier raced up the unlit rural Highway 174 to the non-
emergency Stalled Vehicle, in violation of South Carolina law, neither of them engaged their
emergency lights nor audible sirens, thus preventing the automatic recording of the dash cam video
in their County Vehicles.
49. Deputies are aware that dash cam video recording in their County Vehicles captures
and records the vehicle’s speed, use of lights and sirens, and other data points, and is triggered by
any of the following actions:
a. Automatically - by driving at a speed in excess of 90 miles per hour7;
b. Automatically - with activation of emergency lights and sirens; and
c. Manually - by turning on the video camera.
50. Per the Deputy Racing Data, within 45 seconds, both Deputies Pelletier and Sacks
greatly exceeded the posted speed limit responding to the non-emergency Stalled Vehicle without
turning on their emergency lights or audible sirens.
PELLETIER $0236| SO158] SPEED $0236 $0158 SACKS Feet | ELAPSED

Date_Time Latitude | Speed | Speed| LIMIT| Over Limit | Over Limit Date_Time Latitude | Behind TIME
2022-05-08 22:42:45.977| 32588911] 58 68 55 3 13 2022-05-08 22:42:41.460| 32589164 | 253 0:00:45
2022-05-08 22:43:05.883| 32594513] 74 71 55 19 16 2022-05-08 22:43:03.303| 32595495 | 982 0:01:05
2022-05-08 22:43:28.023] 32601097} 79 70 55 24 15 2022-05-08 22:43:23.210| 32601097 0:01:27
2022-05-08 22:43:50.117| 32607727] 71 79 55 16 24 2022-05-08 22:43:45.337| 32607638 0:01:49
2022-05-08 22:44:10.007| 32613956] 77 80 55 22 25 2022-05-08 22:44:05.227| 32614268 0:02:09
51. Per the Deputy Racing Data, this unlawful, unauthorized, and life-threatening
speeding, by Deputy Pelletier and Deputy Sacks, would continue throughout their driving, covering
19 miles in approximately 15 minutes.
7
Per CCSO Policy, and a setting within the County Vehicles, the video camera only automatically records driving
when vehicle speed exceeds 90 mph. By setting the limit at such an outrageously high and dangerous number, Deputies
know they can speed anytime, anywhere at up to 89 mph with impunity as there will be no video evidence of their
behavior.
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52. Per the Deputy Racing Data, approximately 3 minutes into their response, Deputy
Pelletier reached an incredible speed of 91 miles per hour trying to catch up to Deputy Sacks
who had already reached speeds of 80 miles per hour. (emphasis added).

2022-05-08 22:45:03.913 32629003 68 55 13 0:03:03
2022-05-08 22:45:08.960 32630230 64 80 55 9 25 2022-05-08 22:45:09.353 32634740 4510 0:03:08
2022-05-08 22:45:13.853 32631169 66 55 11 0:03:13
2022-05-08 22:45:19.367 32632792 72 55 17 0:03:19
2022-05-08 22:45:25.040 32634545 73 55 18 0:03:24
2022-05-08 22:45:30.007 32635944 68 78 55 13 23 2022-05-08 22:45:29.243 32640924 4980 0:03:29
2022-05-08 22:45:35.587 32637340 71 55 16 0:03:35
2022-05-08 22:45:41.727 32639455 80 55 25 0:03:41
2022-05-08 22:45:48.117 32641117 87 55 32 0:03:47
2022-05-08 22:45:52.727 32643141 91 77 55 36 22 2022-05-08 22:45:51.257 32647555 4414 0:03:52
2022-05-08 22:45:58.383 32645262 88 55 33 0:03:58
2022-05-08 22:46:04.180 32647179 86 55 31 0:04:03
2022-05-08 22:46:10.603 32649115 82 73 55 27 18 2022-05-08 22:46:11.460 32653158 4043 0:04:10
53. As the two speeding Deputies approached the signs at the Willtown Road
intersection, Deputy Sacks sped past the signs, following the Dispatch turn-by-turn driving
directions, and continued speeding towards Highway 17.
54. Deputy Pelletier was still speeding, without her emergency lights or sirens, well
behind Sacks, as she passed the signs located at the Willtown Road intersection: (photo below)
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55. Deputy Pelletier then became confused as to the proper route to travel, just as she
had demonstrated numerous times in training.
56. At 10:49 pm, after initially driving past the signs at Willtown Road, (#1) Deputy
Pelletier disregarded the turn-by-turn directions from Dispatch, turned around (#2), and then turned
down Willtown Road (#3), triggering a Route Deviation notice.
57. These actions are documented from Deputy Pelletier’s Driving Data and Incident
Response and are depicted and summarized below:
5/8/2022 22:49:32 $0236 Route Deviation HIGHWAY Unit $0236 deviated from original SO236
174\WILLTOWN RO driving directions route
PELLETIER $0236 | SO158 | SPEED
Date_Time Latitude Speed | Speed | LIMIT

1 - Sign: To Charleston - Hwy 164 Turn
WILLTOWN ROAD
2022-05-08 22:49:31.547 | 32705910 70 55
2022-05-08 22:49:37.140 | 32707209 55 55
2022-05-08 22:49:42.580 | 32708226 49 66 55
2022-05-08 22:49:47.220 | 32709179 37 55
2022-05-08 22:49:52.907 | 32709636| 20 55
2 PELLETIER turns around to go back to turn down Hwy 164 55
2022-05-08 22:50:03.673 | 32709195 35 63 55
2022-05-08 22:50:07.923 | 32708545 45 55
Q 2022-05-08 22:50:13.063 | 32707408 48 55
2022-05-08 22:50:18.173 | 32706704 36 55
‘hurch noo RS 3 ‘| PELLETIER turns down Hwy 164

a 2022-05-08 22:50:23.033 | 32706300 | 20 | 24 | 55
58. Thereafter, Deputy Pelletier continued speeding down the unlit, rural Willtown
Road reaching a top speed of 76 miles per hour all without using her emergency lights or audible
sirens.
59. Defendant Sacks continued speeding and following the turn-by-turn directions
given from Dispatch, sped up Highway 174, and then turned right onto Highway 17.
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60. This placed the two Deputies racing at unlawful speeds, on two different paths of
travel to the Stalled Vehicle as is depicted below:
Stalled Vehicle
Sacks follows
CDC Route
me
Ww
Pelletier
Turns onto
New Road
61. Deputy Pelletier then engaged in “conscience shocking” speeding as she turned
onto New Road as confirmed by Defendant CCSO 8 (using Pelletier’s Deputy Driving Data) as part
of their internal investigation: (excerpt)
I reviewed the Global Positioning System data from Deputy Pelletier’s Computer-aided Dispatch.
It revealed, Deputy Pelletier was traveling at speeds exceeding the posted speed limit of 45 miles
per hour (mph) on New Road, From 22:54:50 hours to 22:56:56 hours, Deputy Pelletier’s lowest
recorded speed was 61 mph. The last documented speed was recorded at 22:57:01 hours and is
listed at 82 mph.
8
Note the Deputy Driving Data of Deputy Pelletier was apparently only reviewed as to her driving on New Road
and Deputy Sacks’ Driving Data was not reviewed at all by CCSO as part of their investigation. Further, it appears no
Deputy Driving Data was given to SCHP by CCSO for their investigation.
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62. Deputy Pelletier’s Driving Data shows that she continually increased her speed
from 25 mph to 82 mph over the entire 3 mile stretch of the unlit, rural, New Road as she
approached Highway 17. (emphasis added).
PELLETIER $0236 | SPEED $0236

Date_Time Latitude Speed | LIMIT +
2022-05-08 22:54:18.737 | 32728604 25 45 -20

2022-05-08 22:54:24.503 | 32729010 24 45 ail
2022-05-08 22:54:28.723 | 32729697 46 45 1
2022-05-08 22:54:34.410 | 32730884 55 45 10

2022-05-08 22:54:40.330 | 32732210 57 45 12
2022-05-08 22:54:45.177 | 32733328 59 45 14
2022-05-08 22:54:50.473 | 32734723 61 45 16
2022-05-08 22:54:55.987 | 32735689 62 45 17
2022-05-08 22:55:01.067 | 32737190 63 45 18
2022-05-08 22:55:07.143 | 32738371 62 45 17
2022-05-08 22:55:11.003 | 32739341 61 45 16
2022-05-08 22:55:16.130 | 32740730 61 45 16
2022-05-08 22:55:21.237 | 32741914 60 45 15
2022-05-08 22:55:27.177 | 32743419 64 45 19
2022-05-08 22:55:32.083 | 32744494 67 45 22
2022-05-08 22:55:38.190 | 32746434 71 45 26
2022-05-08 22:55:44.160 | 32748159 71 45 26
2022-05-08 22:55:49.130 | 32749559 71 45 26
2022-05-08 22:55:55.130 | 32751171 71 45 26
2022-05-08 22:56:01.113 [ 32752894 70 45 25
2022-05-08 22:56:06.097 | 32754297 68 45 23
2022-05-08 22:56:11.020 | 32755265 67 45 22
2022-05-08 22:56:17.020 | 32756877 69 45 24
2022-05-08 22:56:23.113 | 32758923 74 45 29
2022-05-08 22:56:29.113 | 32760645 75 45 30
2022-05-08 22:56:34.490 | 32762364 75 45 30
SACKS arrives at Stalled Vehicle
2022-05-08 22:56:40.177 | 32763871 78 45 33

2022-05-08 22:56:45.207 [| 32765491 31 45 36
2022-05-08 22:56:51,177 | 32767429 32 45 37
2022-05-08 22:56:56.770| 32769366 81 45 36
2022-05-08 22:57:01.223 | 32770969 32 45 37
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63. At 22:55:58, the exact same time that Deputy Pelletier was engaged in “conscience
shocking” speeding on the unlit New Road, Deputy Sacks was also dangerously speeding at 79
mph without using his emergency lights or audible siren (as is shown in his dash cam video that
he manually engaged – screenshot below).9
riggers
[— Lights
[~ Siren
(ER
64. CCSO did not provide SCHP the Deputy Driving Data of either Deputy Sacks or
Deputy Pelletier to assist in their investigation into The Crash and their Deputy Driving Data is not
part of the SCHP MAIT Report of The Crash.
65. Neither the SCHP nor CCSO noted, commented, or inquired as part of their
investigation as to the speed of Defendant Sacks in arriving at the non-emergency Stalled Vehicle.
66. Neither the SCHP nor CCSO noted, commented, or investigated the obvious fact
that if the two Deputies left the same place at the same time, as Defendant Sacks stated, (and that
the Deputy Driving Data showed in great detail), and if Defendant Pelletier was dangerously
9
Per CCSO Policy, and a setting within the County Vehicles, the camera only automatically records driving when
the speed exceeds 90 mph. By setting the limit at such an outrageously high and dangerous number, Deputies know they
can speed anytime, anywhere at up to 89 mph with impunity as there will be no video evidence of their unlawful behavior.
Note that Deputy Sacks never sped past 90 mph during his driving and stayed below this threshold.
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speeding along the way, exactly how did Defendant Sacks get to the Stalled Vehicle first.
67. Both Deputy Pelletier and Sacks by their acts and omissions, knowingly, recklessly,
and needlessly put the lives of all the people on the road that night at grave risk, including Shanice,
Miranda and their mother Stephanie, all in violation of South Carolina law and CCSO policy
DEVIATIONS, DELIBERATE INDIFFERENCE, & DEATH
68. Prior to the night of May 8, 2022, both Deputies Pelletier and Sacks had completed
South Carolina Criminal Justice Academy training.
69. As a result of that training, both Deputy Pelletier and Sacks knew:
a. Deputies spend more time behind the wheel than any other place;
b. As Deputies spend more time behind the wheel than in any other place, it is
imperative that an officer possess driving skills that are superior to those of the
general motoring public;
c. ”Excessive speeds are seldom, if ever, warranted since the Deputy has, as their
first duty, to get to the scene before they can be of any assistance”; and
d. When authorized, the use of emergency lights and audible signal when traveling
over the posted speed limit is mandatory, especially as fatal collisions are 2 ½ times
more likely to occur at night than in daylight because of the difficulty of visual
perception at night due to the darkness, which causes Deputies to lose many of the
“cues” they depend on in daylight for judging distances.
(Excerpts South Carolina Basic Law Enforcement Student Manual (2010)).
70. As a result of that training, Deputies Pelletier and Sacks knew of the extreme
dangers and lethality a County Vehicle posed to other people on the roads, as a County Vehicle
can be more lethal than a handgun. (CJA Academy Training Materials - Lesson Plan Outline -
Driving Training):
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44 MAGNUM REVOLVER CAR
Weight of Bullet.......00000000.00. 240 grains Weight ofVehicle............. 4,000 Ibs.
Muzzle Velocity.......... 1,600 fps. (1,090 mph) Velocity......cccceeeeeeees 88.02 fps (60 mph)
Foot-Pounds of Energy at Muzzle......... 1,400 Foot-Pounds of Energy at Impact with a
Stationary Object......app. 480,000
PEOPLE IT COULD KILL - MAYBE 4 PEOPLE IT COULD KILL — ABOUT

WITH AN AVERAGE OF 325 FP PER 1,477 WITH AN AVERAGE OF 325
PERSON FP PER PERSON
71. Prior to the night of May 8, 2022, as a result of that training, both Deputies Pelletier
and Sacks knew:
a. A stalled vehicle mandated a Code 1 Response; and
b. A Code 1 Response required them to follow Dispatch-provided turn-by-turn driving

directions and obey all traffic laws.
72. The South Carolina Criminal Justice Academy Basic Law Enforcement Manual
states that “Due to the nature of our work and the amount of time spent behind the wheel, we will
encounter more accidents and emergencies than other professions. Therefore, an officer must
possess driving skills that are superior to those of the general motoring public.”
73. Those training materials further instructed Deputies Pelletier and Sacks regarding
reaction time:
Driving Techniques
a. The elements of reaction time
Reaction time depends on two things: the driver's awareness and the driver's
attention. The average perception/reaction time is 1.6 seconds. That is the time it
takes for a driver to observe, recognize the hazard, decide what to do, and finally
initiate that decision. For example: in 1.6 seconds at 60 mph, you will travel
approximately 44 yards before you can react - almost half the length of a football
field.
74. In addition, based upon their experience and training, including personally
witnessing and investigating high-speed car collisions, issuing citations, and enforcing traffic laws
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as part of their job duties as Deputies, both Pelletier and Sacks personally knew the incredible and
often fatal dangers reckless speeding and the disregarding of traffic control signals by motorists
posed to the public at large.
75. With all of this actual, subjective knowledge, Deputy Pelletier deviated from the
safest and most direct turn-by-turn driving directions provided by Dispatch, and with conscience
shocking deliberate indifference to the safety of everyone on the road, raced the three (3) miles
down New Road reaching speeds of up to 82 mph and never once obeyed the speed limit.
76. Deputies Pelletier knew10, and had every reason to know, as she raced the three (3)
miles down New Road for nearly three (3) minutes, accelerating along the way to 82 mph, (37 mph
over the limit) that she was violating both South Carolina law and CCSO Policy because:
a. She was responding Code 1 to a non-emergency Stalled Vehicle;
b. She was legally required to obey the speed limit;
c. She had deviated from the main roads and driving directions assigned by Dispatch;
d. She was unfamiliar with the area and with New Road;
e. She knew New Road was poorly paved, dark, and unlit and that she was driving at
night with poor visibility;
f. As she sped on New Road for several minutes, she became increasingly aware of
its darkness, lack of lighting, and poor visibility;
g. She knew that she was not displaying her emergency lights nor using her audible
sirens, thereby increasing the danger she knew she was posing to others on the road;
h. As she sped on New Road for several minutes, she knew she was coming ever closer
to an intersection with Highway 17 where other vehicles would be traveling in
cross-directions at speeds of 60 mph at that intersection;
10
Deputy Pelletier admitted her actual knowledge of many of these facts in her statements to the CCSO Investigating
Officer:
- Deputy Pelletier had never worked the south district and was unfamiliar with the area.
- Deputy Pelletier was dispatched to a disabled vehicle located in a remote area of Highway 17 South.
- Deputy Pelletier traveled on New Road, which is not illuminated by any streetlights or lights from businesses.
- Deputy Sacks notified dispatch he was out with the disabled vehicle.
- She was not utilizing her blue light and sirens while responding to the call. (CCSO IA Report- Interview Excerpts).
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i. As she sped on New Road for several minutes, she knew she would not have the
right of way when she reached the Highway 17 intersection and would need to yield
to other motorists in order to safely enter Highway 17; and
j. As she sped on New Road for several minutes, at some point she knew or should
have known that Deputy Sacks had already reached the Stalled Vehicle.
77. At any point in time on New Road, Deputy Pelletier could have and should
have determined her exact GPS location and distance to Highway 17, as she had access to her own
cell phone (Google Maps / Waze, etc) and/or MDT computer in her County Vehicle.
78. At approximately 10:57 p.m. at a speed of approximately 82 mph, without
emergency lights or audible sirens, Defendant Pelletier sped past the Stop Sign on New Road
(MAIT scene photo below), and crossed multiple lanes of traffic on Highway 17:
79. As Deputy Pelletier sped past the Stop Sign and through two lanes of Highway 17,
she violently struck the vehicle driven southbound by Shanice Dantzler-Williams like a missile, at
a speed of 73 mph, destroying the vehicle (the “Crash”) (SCHP scene photo below):
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80. Inside that vehicle, Shanice was the driver, her sister Miranda was a passenger,
along with their mother Stephanie, who were all together for Mother’s Day.
81. Immediately prior and at the moment of The Crash, Shanice was driving her vehicle
lawfully in her lane of travel and below the speed limit when Deputy Pelletier struck her vehicle.
82. Given the speed at which Deputy Pelletier was operating her vehicle without using
her emergency lights and audible sirens, the lack of street lighting, the darkness at that time of
night, and that Pelletier was entering Highway 17 without the right-of-way from a poorly lit
wooded side road on Shanice’s left, it was not humanly possible for Shanice to avoid Defendant
Pelletier’s speeding County Vehicle prior to The Crash.
83. Shanice was not at fault and in no way contributed to the cause of the Crash.
84. Following the impact, Shanice’s vehicle was deflected west and careened into a
wood line, striking a utility box, power pole guy wire, SCDOT signs, and trees.
85. Deputy Pelletier’s vehicle rotated counterclockwise onto the other side of New
Road and finally came to a stop on the Southbound shoulder of New Road in a southwesterly
direction.
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86. Mother Stephanie, and her daughters, Shanice and Miranda, all sustained
catastrophic injuries as a result of The Crash, suffered conscious pain and suffering, and then died
shortly afterward.
CONSOLIDATED DISPATCH CENTER’S ACTIONS & INACTIONS
87. On the night of May 8, 2022, a motorist (“Caller”) called Dispatch and reported
that their car had stalled in one lane of Highway 17, (“Stalled Vehicle”) and that it was not blocking
all traffic on the road nor posed any immediate danger as the vehicle’s flashing hazard lights were
working.
88. Dispatch operator did not immediately inform the Caller to call a tow truck, nor
did the operator call a tow truck for them, which would have easily and quickly resolved whatever
routine and limited public safety hazard the Stalled Vehicle posed.
89. The responding operator instead only told the Caller they had no idea how long it
would take for an officer to arrive, and dispatched Deputy Pelletier, who was joined by Deputy
Sacks, to respond to the Stalled Vehicle.
90. If Dispatch Operator had arranged and/or suggested to the Caller to get an
immediate tow, the entire problem would have been solved without Deputy involvement.
91. Further, the Caller’s stalled vehicle in the road would obviously need to be removed
by a tow truck anyway, so involving a Deputy and needlessly delaying the timing of that removal
only increased the possible danger to the Caller, other people on the road, and the responding
Deputies who would presumably need to travel to the scene, and then make the call for a tow truck.
92. Less than 10 minutes passed and the Caller again called Dispatch.
93. The Caller said that nothing had changed, but inquired of the Dispatch operator
about the location of the responding Deputies and whether the Caller should call a tow truck or if
the operator could call one for them as the Caller didn’t know one to call. (emphasis added).
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94. The Dispatch operator went on, presumably pursuant to policy, and informed the
Caller that “it’s a weird thing I can’t advise you on which tow company to call.”
95. Dispatch operator told the Caller that she would inform the responding Deputies
that nothing had changed but that the Caller was just scared as she was in the road.
96. Dispatch operator then informed Deputies Pelletier and Sacks of a second call from
the Caller, but only relayed that the Caller “Advised she was in a bad spot” and did not inform the
Deputies that nothing had changed. (emphasis added).
97. In response to this call Deputy Sacks and Pelletier raced to the Stalled Vehicle as
set forth supra.
98. Thereafter, Deputy Sacks notified Dispatch that he had arrived on the scene with
the Stalled Vehicle.
99. Approximately one minute later, Defendant Pelletier, racing to the Stalled Vehicle,
caused The Crash.
100. Thereafter, a tow truck was called to remove the Stalled Vehicle from the road.
CCSO’s HISTORY OF DANGEROUS DEPUTY DRIVING,

MISUSE OF COUNTY VEHICLES, & VIOLATIONS OF 14TH AMENDMENT RIGHTS
101. The Charleston County Sheriff’s Office has a long and known history of dangerous
and reckless driving by its Deputies that involves the misuse and destruction of County Vehicles
that threatens public safety and has resulted in recurrent violations of the 14th Amendment rights
of those they injure and/or kill.
102. CCSO admits this history in its own Emergency Vehicle Operation and Driving
Lesson Plans wherein it states:
a. The Charleston County Sheriff’s Office was involved in 78 collisions in 2019 which
they admit fault in over half of them; and
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b. In 2020, Charleston County Sheriff’s Office was involved in at least 23 collisions
and admitted fault in at least seven of the crashes.
103. The recent history of CCSO Deputies using County Vehicles and repeatedly
causing vehicle crashes, especially those causing serious injury and death, is alarming. These are
some of the recent, known crashes and their circumstances, based upon information and belief:
a. On November 18, 2018, a CCSO Deputy was involved in a collision that resulted
in the death of Megan Eichman. The subsequent lawsuit alleges that the Deputy was
traveling in excess of 100 mph and without emergency lights or sirens when he
collided with the decedent, Megan Eichman;
b. On April 24, 2019, just six months after Eichman’s death, another CCSO Deputy
driving southbound on Savannah Highway at a high rate of speed (76 mph) at night
collided with a motorist driving eastbound on Dobbin Road causing serious injury
to a passenger as a result of the deputy’s reckless speeding;
c. On July 19, 2019 a bystander, Lane Lusk, was killed by a CCSO Deputy engaged
in a chase. The pursuit quickly became dangerous and the fleeing vehicle ran two
red lights and reached speeds of 109 MPH;
d. On September 20, 2019, a CCSO Deputy lost control of her vehicle while clearly
traveling at an excessive speed for conditions, struck a tree, resulting in her injury;
e. On April 13, 2020, CCSO Deputy was driving in the far-right lane on Highway 17
when he made a sudden an illegal U-turn across the center lane of traffic and crashed
into Kwamane Mitchell’s vehicle, causing Mitchell’s death. The deputy reportedly
was not operating his emergency lights or equipment prior to initiating his turn or
at the time of the collision;
f. On April 19, 2020, a CCSO Deputy collided with a vehicle driven by a North
Charleston Police Department officer near the intersection of Rivers Avenue and
Cherokee Street, sending the North Charleston officer to the hospital;
g. On May 21, 2020, a CCSO Deputy was speeding (74 mph) well above the posted
limit on Old Towne Road when another driver traveling in the southbound lane
attempted to make a left-hand turn. The Deputy failed to yield and crashed into
them causing serious physical injuries and death. The Deputy was charged with
reckless homicide and fired because of violations of department policies; and
h. On January 3, 2021, two people were killed when their vehicle was hit by a CCSO
vehicle on Highway 17 near Bee Hive Road. The Deputy was traveling at an
incredible 130 MPH and was later cited for driving too fast for conditions.
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104. Defendants Charleston County and CCSO certainly knew and know of each of these
instances and every other involving County Vehicles furnished and entrusted to CCSO and its
Deputies as all claims related to damage to County Vehicles are handled through the Charleston
County Administrator, as well as many of these collisions have resulted in litigation.
105. Further, Charleston County collects and archives all Deputy Driving Data such that
every minute of Deputy driving can be easily retrieved, reviewed, and audited at any time to see
each and every time a Deputy was either speeding and/or deviating from Dispatch provided turn-
by-turn driving instructions in their County Vehicle.
106. The existence of Deputy Driving Data means that every act of dangerous and
unlawful Deputy driving behavior, including those engaged in reckless and unlawful speeding, as
well as those Deputies deviating from the safe direct driving routes provided by Dispatch, is at all
times captured, known, and easily reviewable by the County, CCSO and/or Sheriff Graziano.
107. Upon information and belief, per past and current CCSO policy and custom, the
only time anyone ever reviews Deputy Driving Data is after a Deputy has caused a crash with their
County Vehicle, and even then, the after-the-fact investigations of Deputy Driving Data are
incredibly limited to the crash itself and not the entire driving history of the Deput(ies) involved in
the crash at issue.
108. In addition, CCSO had a policy whereby the County Vehicle video cameras were
set so that they would not automatically record the driving of any Deputy unless and until a County
Vehicle exceeded an incredible 90 mph. (emphasis added).
109. This unreasonable and dangerously high setting for automatic recording of Deputy
driving of County Vehicles at 90 mph or faster, implicitly encouraged unlawful speeding up to 89
mph without the use of emergency lights or sirens.
110. Together, these then existing, policies, customs, actions and inactions by
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Defendants CCSO and Charleston County have created a culture and conditions whereby Deputies
know that there is non-review, tacit approval and acceptance for any of their dangerous and/or
unlawful driving of County Vehicles and as such, making it forseeable to CCSO and Charleston
County that more people on the road will suffer injuries and death from the ongoing and future
dangerous misuse of County Vehicles by CCSO Deputies.
111. This tacit condonation and ongoing community safety problem of the dangerous
misuse of County Vehicles by Deputies, was made expressly known to CCSO and Charleston
County in 2020. (See Eichman v. Rissanen, CCSO and Town of James Island, USDC South
Carolina – Charleston Division 2:20-cv-04057).
112. More importantly, as the above listing of crashes and pending litigation shows,
Defendant Charleston County and CCSO had actual knowledge that these policies, customs,
actions, and inactions by Defendants CCSO and Charleston County were and are causing injuries
and death and violations of citizens’ 14th Amendment rights of bodily integrity.
113. Despite this extensive history and knowledge of dangerous Deputy driving, set forth
above, upon information and belief, there has been a complete absence of any review of any Deputy
Driving Data; any monitoring, supervision, disciplining, reporting, re-training and/or investigation
of Deputies and their dangerous driving by either CCSO and/or Charleston County so as to ratify
and condone this often dangerous misuse of County Vehicles that are causing injuries and death
and violations of citizens’ 14th Amendment rights of bodily integrity.
114. Upon information and belief, the only time there is or has been any investigation
into the dangerous misuse of County Vehicles by any Deputy or review of any Deputy Driving
Data is only after a Deputy has caused a crash, and even then, the after-the-fact investigations are
incredibly limited to the collision itself and not the driving history of the Deputy at issue.
115. This complete absence of supervision and review by CCSO and/or Charleston
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County is borne out by the very investigation into the senseless deaths of Shanice, Miranda and
their mother Stephanie, as CCSO possessed Deputy Driving Data of Defendants Pelletier and
Sacks unlawfully speeding for 15 minutes but never questioned Deputy Sacks about his speed and
actions or Deputy Pelletier regarding her entire driving response including her Route Deviation
while responding.
116. CCSO and/or Charleston County did not even provide SCHP the Deputy Driving
Data of either Defendant Sacks or Defendant Pelletier to assist the SCHP investigation of The
Crash.
117. As a direct and proximate result of any one or more of the acts and/or omissions of
any one or more of the Defendants as alleged herein, Shanice, Miranda, and Stephanie all suffered
catastrophic injuries with conscious pain and suffering that ultimately resulted in their deaths.
FOR A FIRST CAUSE OF ACTION

(Negligence/ Negligence Per Se)
118. All allegations made in the preceding paragraphs are re-alleged as if fully set forth
herein.
119. Defendant Pelletier was negligent, careless, reckless, grossly negligent and wanton,
and proximately caused The Crash, the injuries, and the death of Shanice, Miranda and Stephanie
in any one or more of the following respects:
a. Exceeded the posted speed limits, disregarded traffic signals, and endangered life
and property in violation of S.C. Code Ann. §56-5-760 Operation of authorized
emergency vehicles;
b. Violated numerous traffic laws as set forth in S.C. Code Ann. §§ 56-5-10 et seq;
c. Failed to operate her vehicle in a lawful manner with due care for public safety;
d. Failed to maintain control of her vehicle;
e. Failed to keep a proper lookout while operating her vehicle;
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f. Failed to direct Defendant Sacks to follow the law and CCSO policy;
g. Failed to exercise the degree of care that a reasonable person would have exercised
under the same or similar circumstances; and
h. In such other and further particulars as the evidence and/or trial may show.
120. Defendant Sacks was negligent, careless, reckless, grossly negligent, and wanton
and proximately caused The Crash, injuries and death of Shanice, Miranda and Stephanie in any
one or more of the following respects:
a. Exceeded the posted speed limits and endangered life and property in violation of
S.C. Code Ann. §56-5-760 Operation of authorized emergency vehicles;
b. Violated numerous traffic laws as set forth in S.C. Code Ann. §§ 56-5-10 et seq;
c. Failed to operate his vehicle in a lawful manner with due care for public safety;
d. Failed to direct Defendant Pelletier to follow the law and CCSO policy especially
as he was the more senior Deputy;
e. As the more senior Deputy, aided and abetted Deputy Pelletier’s tortious conduct
by his example and acting in concert through substantial assistance and
encouragement by his own dangerous tortious conduct;
f. Substantially encouraged the negligent and dangerous actions of Deputy Pelletier;
g. Failed to exercise the degree of care that a reasonable person would have exercised
h. In such other and further particulars as the evidence and/or trial may show.
121. Defendant CCSO is vicariously liable for the negligent, careless, reckless, grossly
negligent, and wanton acts and omissions of Defendants Pelletier and Sacks.
122. Defendant Charleston County, by through the acts and omissions of its employees,
was negligent, careless, reckless, grossly negligent and wanton acts and is liable for the injuries
and death of Shanice, Miranda and Stephanie in any one or more of the following respects:
a. Failed to have policies in place negating the need to engage law enforcement for
callers with routine automobile breakdowns who need towing services;
b. Failed to inquire and give reasonable pre-arrival instructions to the Caller;

32 of 45
c. Failed to exercise reasonable care in the communication of complete and accurate
information to responding Deputies;
d. Failed to exercise reasonable care to monitor, supervise, create and enforce policies,
as well as investigate the use of its funds and equipment and property misused by the
CCSO and its Deputies given the extensive history of crashes involving County
Vehicles by the CCSO Deputies and the data captured by Dispatch related to the
driving of each and every Deputy, that is known to exist by CCSO and Charleston
County and is readily and easily accessible to same;
e. Failed to exercise the degree of care that a reasonable person would have exercised
f. In such other and further particulars as the evidence and/or trial may show.
123. Defendant Charleston County is vicariously liable for the negligent, grossly
negligent, and reckless conduct of the relevant and responsible employees as alleged herein.
any one or more of the Defendants as alleged herein, Shanice, Miranda and Stephanie all suffered
FOR A SECOND CAUSE OF ACTION

(Negligent Hiring & Retention)
125. All allegations made in the preceding paragraphs are re-alleged as if fully set
forth herein.
126. CCSO owed a duty to hire, train, and retain Deputies to ensure that those
Deputies did not create an unreasonable risk of harm to the public at large with their driving of
County Vehicles, given
a. the vast amount of time Deputies spend behind the wheel; and
b. the extreme dangers and lethality a County Vehicle poses to people on the
roads - recognizing a County Vehicle is more lethal than a handgun.
127. CCSO knew, or reasonably should have known, at the time of hiring, that
Defendant Pelletier did not have the proper disposition and/or temperament to safely operate a
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County Vehicle given her driving history with a conviction for speeding greater than 10 mph over
the speed limit roughly one year prior to being hired.
128. Further as demonstrated during her training, and then in her Deputy Driving Data,
Deputy Pelletier consistently demonstrated difficulty with geography and following the turn-by-
turn-directions from Dispatch triggering over one hundred Route Deviation notices in responding
to Incidents.
129. Based upon Defendant Pelletier’s prior driving history, and Deputy Driving Data
after she was hired, CCSO knew or should have known that hiring and retaining her as a law
enforcement officer presented a danger to the public at large, and it was foreseeable that she would
fail to operate her County Vehicle in a reasonable manner consistent with South Carolina law and
law enforcement policies, especially as she had never previously worked as a law enforcement
officer.
FOR A THIRD CAUSE OF ACTION

(Negligent Training – CCSO of Pelletier & Sacks)
herein.
132. Defendant CCSO knew or should have known that its failure to provide adequate
training to and supervision of the Deputies of the CCSO, including Defendants Sacks and Pelletier,
would and could result in serious injury and/or death.
133. Defendant CCSO breached their duties by their policies, customs, and failure to
reasonably train Deputies Sacks and Pelletier, as set forth supra, who committed the acts and
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omissions described in this Complaint.
FOR A FOURTH CAUSE OF ACTION

(Negligent Supervision by CCSO of Sacks & Pelletier)
herein.
136. Defendant CCSO owed a duty to exercise reasonable care to monitor, supervise,
create, and enforce policies, as well as investigate the dangerous, wrongful, and/or unlawful
conduct of its Deputies operating County Vehicles, including Deputies Pelletier and Sacks, to
determine if these persons were safe and appropriate drivers on the road, especially given the vast
amount of time spent driving as well as the lethality of a County Vehicle.
137. Despite the extensive history of crashes involving County Vehicles by CCSO
Deputies, the Deputy Driving Data captured by Dispatch related to the driving of County Vehicles
by each and every Deputy that is known to exist by CCSO and Charleston County, that is readily
and easily accessible to same, lawsuits involving this very issue with ongoing litigation over the
last two years, there has been a complete absence of any review of Deputy Driving Data,
monitoring, supervision, disciplining and/or investigation of Deputies and their driving, including
Defendants Pelletier and Sacks, prior to injuring or killing others on the road, and even then, the
after-the-fact investigations are limited solely to the crash itself.
138. Further, this absence of supervision extends to CCSO policy whereby the in-County
Vehicle video cameras would not automatically record the driving of any Deputy unless and until
a County Vehicle exceeded an incredible 90 mph, thereby encouraging unlawful speeding up to 89
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mph and prevented video evidence of these violations of South Carolina law and CCSO policy by
Deputies from being captured.
139. Specifically, as to Defendant Pelletier, CCSO owed a duty to monitor and supervise
her with even greater scrutiny as she had a recent conviction of speeding greater than 10 mph
roughly one year before being hired, had never worked previously as a law enforcement officer,
was only recently hired on 4/23/21 and had a well-documented series of safety problems and
difficulties in her training, see supra, before causing The Crash.
140. Defendant CCSO breached their duty by failing to supervise Deputies Pelletier
and/or Sacks, who committed the acts and omissions described in this Complaint.
FOR A FIFTH CAUSE OF ACTION

(42 U.S.C § 1983 – Civil Rights Violation by Defendants Pelletier and Defendant Sacks)
herein.
143. The acts and omissions of Defendants Pelletier and Sacks, by knowingly driving
their County Vehicles in violation of South Carolina law and CCSO policy, at such extreme and
outrageous speeds, without using emergency lights or audible sirens, while responding to a non-
emergency call, constituted a conscience-shocking deliberate indifference to the lives and safety
of those on the road that evening, including Shanice, Miranda, and their mother, Stephanie.
144. Specifically, Defendants Pelletier and Sacks subjectively knew and recognized the
substantial risk of harm their dangerous driving of their County Vehicles that night posed with full
knowledge of the risks involved to the public as they:
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a. Had over 10 minutes from when first dispatched until The Crash to deliberate their
conduct—to slow down, encourage each other to slow down, and apply their
knowledge and training to the situation, reflect on their actions, and conform their
behavior to lawful behavior;
b. Knew they were not responding to any emergency;
c. Knew the law (and department policy) that required them to drive the speed limit
and obey all traffic laws;
d. Continued to drive at incredibly excessive and dangerous speeds, especially

Pelletier’s conscience-shocking 81 mph — nearly forty miles per hour over the 45-
mph speed limit—on a dark, wooded road with full knowledge of the risks of night
driving as she was approaching a busy Highway 17, as well as her failure to
determine her exact location and to stop at a Stop sign before crossing multiple
lanes of a busy highway; and
e. Both knew that driving without using their emergency lights and audible sirens,
especially at night, only increased the danger to everyone on the road, as it
eliminated any warning to other drivers that a law enforcement vehicle was
approaching at a high rate of speed.
145. At all times material to this Complaint, and as alleged supra, Defendants Pelletier
and Sacks acted with recklessness and deliberate indifference constituting a conscious disregard to
the clearly established Fourteenth Amendment substantive due process rights of Shanice, Miranda,
and their mother, Stephanie, including those of their heirs and statutory beneficiaries in their
familial relationships with the decedents:
a. to be free from deliberately indifferent and conscious shocking government
behavior; and
b. to be free of the loss of bodily integrity and property.
146. As a direct and proximate cause of the acts and omissions as alleged supra,
Defendants Pelletier and Sacks violated 42 U.S.C. § 1983, and acted with deliberate indifference
constituting a conscious disregard to the clearly established Fourteenth Amendment rights of
Shanice, Miranda, and their mother, Stephanie, that resulted in their injury and death.
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42 U.S.C. § 1983 MONELL LIABILITY
herein.
148. CCSO and its final policymaker Sheriff Graziano, are County actors for the
purposes of 42 U.S.C. § 1983 liability for any one or more of the following reasons:
a. Due to the unique legal structure of the CCSO (and Sheriff Graziano) neither
Charleston County nor the State nor any other governmental entity has any direct
supervisory control over CCSO Deputies and policies relating to same, especially
those as to administrative matters such as supervision of Deputy driving; and
b. Specifically, the policies of Sheriff Graziano as to her supervision and training of
her Deputies and their driving, especially as to responding to non-law enforcement
calls, is purely an administrative matter, and is hers alone as the final policymaker
because no other governmental entity or person has such authority on this particular
issue.
149. CCSO is thus an entity capable of being sued pursuant to 42 U.S.C. § 1983 for any
one or more of the following reasons:
a. The State of South Carolina Treasury will not and does not pay or satisfy or is any
way responsible for any judgment rendered against CCSO; and
b. Every aspect of the operations of the CCSO is budgeted for, funded, and paid for
by the County, including, the training, salaries, and benefits of its Deputies who are
classified and paid as County employees; and
c. This funding by Charleston County includes the responsibility to insure and
indemnify CCSO, Sheriff Graziano, and Deputies and as such, Charleston County,
is liable for any judgment rendered against them pursuant to 42 U.S.C. § 1983.
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150. Charleston County is therefore liable for any judgment pursuant to 42 U.S.C. § 1983
rendered against CCSO, Sheriff Graziano, and/or her Deputies.
151. At all times material to this Complaint, CCSO acting by and through Sheriff
Graziano its agents and Deputies, including Defendants Pelletier and Sacks, as set forth supra,
were at all times acting under color of state law.
152. Through the policies, customs, actions, and inactions as alleged supra, and the
dangerous misuse of County Vehicles by Deputies and documented in the Deputy Driving Data
related to same, Defendant CCSO and its policymaker Sheriff Graziano had both actual and
constructive knowledge that Charleston County citizens and others on its roads in Charleston
County had and were experiencing recurrent and numerous violations of their 14th Amendment
rights by the dangerous misuse of County Vehicles by Deputies pursuant to these policies, customs,
actions and inactions.
153. These policies, customs, actions, and inactions by CCSO as alleged supra,
implicitly ratified this dangerous misuse of County Vehicles by Deputies, and created a culture
whereby Deputies, including Defendants Pelletier and Sacks, knew that there was no supervision,
monitoring, and/or accountability for their dangerous misuse of County Vehicles unless and until
that driving resulted in a property loss, injury, or loss of life, including 14th Amendment violations.
154. At all times material to this Complaint, and as alleged supra, Defendant CCSO
County, acting by and through Sheriff Graziano, its policymaker, acted with recklessness and
deliberate indifference constituting a conscious disregard to the clearly established Fourteenth
Amendment rights of Shanice, Miranda, and their mother Stephanie, by implicitly ratifying and
failing to take any actions to monitor, supervise, stop, correct, or ameliorate these known and
ongoing violations of clearly established Fourteenth Amendment rights resulting from the
dangerous misuse of County Vehicles by Deputies that proximately caused and resulted in the
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catastrophic injuries and death of Shanice, Miranda, and their mother Stephanie, including those
of their heirs and statutory beneficiaries in their familial relationships with the decedents.
FOR A SIXTH CAUSE OF ACTION

(42 U.S.C. § 1983 – Municipal Liability Official Policy)
herein.
156. At all times material to this Complaint, Defendant CCSO, acting by and through
their Sheriff, agents, Deputies and policymakers, had official policies as alleged supra, of
Amendment substantive due process rights of rights and safety of the citizens of Charleston County
and others on its public roads including Shanice, Miranda, and their mother Stephanie, who came
in contact with Deputies engaged in the unlawful misuse of County Vehicles, and documented in
the Deputy Driving Data related to same including Defendants Pelletier and Sacks.
157. These policies were the moving force that caused the injury and death of Shanice,
Miranda and their mother Stephanie, and not only violated their clearly established Fourteenth
Amendment substantive due process rights as set forth supra, but also violated the substantive due
process rights of their heirs and statutory beneficiaries in their familial relationships with the
decedents.
FOR A SEVENTH CAUSE OF ACTION

(42 U.S.C. § 1983 – Municipal Liability Unofficial Policy / Custom)
herein.
159. At all times material to this Complaint, Defendant CCSO acting by and through
their agents and policymakers, including Sheriff Graziano, had unofficial policies and/or customs
that were so persistent so as to become standard operating procedure and/or policy, as alleged
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supra, of deliberate indifference constituting a conscious disregard to the clearly established
Fourteenth Amendment substantive due process rights and safety of the citizens of Charleston
County and others on its public roads including Shanice, Miranda, and their mother Stephanie,
who came in contact with Deputies engaged in the dangerous misuse of County Vehicles, including
Defendants Pelletier and Sacks.
160. These unofficial policies and/or customs were the moving force that caused the
injury and death of Shanice, Miranda, and their mother Stephanie, and not only violated their
clearly established Fourteenth Amendment substantive due process rights as set forth supra, but
also violated the substantive due process rights of their heirs and statutory beneficiaries in their
familial relationships with the decedents.
FOR A EIGHTH CAUSE OF ACTION

(42 U.S.C. § 1983 – Municipal Liability - Inadequate Training & Supervision)
herein.
162. As alleged supra, Defendant CCSO inadequately trained and supervised employees
and agents, including its Deputies as to their use and dangerous misuse of County Vehicles.
163. The failure to adequately train and/or supervise was done with recklessness and
Amendment substantive due process rights and safety of the citizens of Charleston County and
others on its public roadways including Shanice, Miranda and their mother Stephanie, who came
in contact with Deputies engaged in the dangerous misuse of County Vehicles, including
Defendants Pelletier and Sacks, especially as Deputy Driving Data easily allowed for supervision
and documentation of dangerous misuse by Deputies.
164. The failure to adequately train and/or supervise Deputies and others regarding the
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dangerous misuse of County Vehicles by Deputies, including Defendants Pelletier and Sacks, were
the moving force that caused the injury and death of Shanice, Miranda, and their mother Stephanie,
and not only violated their clearly established Fourteenth Amendment substantive due process
rights as set forth supra, but also violated the substantive due process rights of their heirs and
statutory beneficiaries in their familial relationships with the decedents.
FOR A NINTH CAUSE OF ACTION

(Survival Action & Damages)
herein.
any one or more of the Defendants as set forth, supra, Shanice, Miranda. and Stephanie suffered
fear, physical pain and suffering, mental and emotional distress and anguish in the time before their
deaths, as well as property damage, and their respective estates further incurred funeral expenses
and are entitled to an award of all damages pursuant to S.C. Code Ann. § 15-5-90 and the common
law of South Carolina.
FOR A TENTH CAUSE OF ACTION

(Wrongful Death Action & Damages)
herein.
any one or more of the Defendants as set forth, supra, Shanice, Miranda and Stephanie suffered
fear, physical pain and suffering, mental and emotional distress and anguish and then died.
169. As a result of their deaths, their heirs and statutory beneficiaries have lost his aid,
comfort, support, society and companionship, and have suffered severe and extreme emotional
distress, anxiety, grief and sorrow, and pecuniary losses for which the Plaintiffs are entitled to
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recover, on behalf of the statutory beneficiaries, damages pursuant to S.C. Code Ann.§ 15-51-10,
et. seq., and the common law of South Carolina.
FOR AN ELEVENTH CAUSE OF ACTION

42 U.S.C. § 1988
herein.
171. Plaintiffs are also entitled to reasonable costs and attorney fees pursuant to 42
U.S.C. § 1988 and applicable statutes and laws.
PUNITIVE DAMAGES
herein.
173. Plaintiffs are further entitled to punitive damages for the grossly negligent, wanton
and/or reckless acts and/or omissions of any one or more of the Defendants as alleged herein.
[Intentionally blank – signature page to follow]
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WHEREFORE, Plaintiffs pray for judgment against the Defendants, for all damages each may
be lawfully entitled to, as may be determined and awarded by a jury against each Defendant, jointly
and severally, and for such other and further relief as may be deemed appropriate by the jury and
this Court, including attorney fees and costs.
Respectfully Submitted,
ATTORNEYS FOR PLAINTIFF

RANDALL WILLIAMS, PERSONAL
REPRESENTATIVE

_____________________________
THE LAW OFFICES OF
RICHARD A. HRICIK, PA
941 Houston Northcutt Blvd. Ste 204
Mt. Pleasant, SC 29464
(t) 843.849.0136
[email protected]

Pendarvis Law, LLC
8420 Dorchester Rd. Ste. 202
North Charleston, SC 29420
O | (843) 990-9847
[email protected]
ATTORNEY FOR PLAINTIFF

BETTY SIMMONS, PERSONAL
REPRESENTATIVE

_____________________________
The Law Office of Clifford Bush, III, LLC
28 Old Jericho Road
Beaufort, South Carolina 29906
(843)379-9500(Office)
[email protected]
Charleston, South Carolina
May 15, 2023
44 of 45
Trial by Jury Requested pursuant to SCRCP 38

_____________________________

_____________________________
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2021‐12‐03 21:24:20.373 Route Deviation CAMP\~1 Unit SO236 deviated from original dri[redacted]
2021‐12‐04 02:58:01.920 Route Deviation RIVER\JENKINS FARM RD Unit SO236 deviated from original dri[redacted]
2021‐12‐04 18:45:32.113 Route Deviation MAYBANK HWY\OLD FOLLY RD Unit SO236 deviated from original dri[redacted]
2021‐12‐05 03:05:22.273 Route Deviation RIVERLAND\CAMP RD Unit SO236 deviated from original dri[redacted]
2021‐12‐06 03:17:00.757 Route Deviation MAYBANK\BROWNSWOOD RD Unit SO236 deviated from original dri[redacted]
2021‐12‐09 00:24:06.603 Route Deviation CAMP\~1 Unit SO236 deviated from original dri[redacted]
2021‐12‐09 21:19:36.407 Route Deviation RIVER\ABBAPOOLA RD Unit SO236 deviated from original dri[redacted]
2021‐12‐10 00:32:32.800 Route Deviation 503 Main Rd [CIRCLE K (MAIN/RIVUnit SO236 deviated from original dri[redacted]
2021‐12‐10 01:36:21.350 Route Deviation RIVER\MAYBANK HWY Unit SO236 deviated from original dri[redacted]
2021‐12‐15 02:58:02.123 Route Deviation RIVERLAND\DAWSON RD Unit SO236 deviated from original dri[redacted]
2021‐12‐17 18:14:31.277 Route Deviation COSGROVE AV\26 E / COSGROVE Unit SO236 deviated from original dri[redacted]
2021‐12‐18 02:49:34.677 Route Deviation MAYBANK\WALTER DR Unit SO236 deviated from original dri[redacted]
2021‐12‐18 17:52:59.660 Route Deviation JAMES ISLAND EXPWY\JAMES ISL Unit SO236 deviated from original dri[redacted]
2021‐12‐19 03:35:44.243 Route Deviation RIVERLAND\WOODLAND SHORESUnit SO236 deviated from original dri[redacted]
2021‐12‐19 05:32:31.360 Route Deviation WOODLAND SHORES\WOODLAN Unit SO236 deviated from original dri[redacted]
2021‐12‐19 18:05:15.823 Route Deviation MAIN\MAIN RD Unit SO236 deviated from original dri[redacted]
2021‐12‐19 19:37:25.650 Route Deviation MAYBANK\FENWICK HALL ALY Unit SO236 deviated from original dri[redacted]
2021‐12‐19 21:18:09.853 Route Deviation FOX CROFT\BIRCHDALE DR Unit SO236 deviated from original dri[redacted]
2021‐12‐20 02:04:26.833 Route Deviation MAYBANK\HEADQUARTERS PLANUnit SO236 deviated from original dri[redacted]
2021‐12‐23 18:30:08.000 Route Deviation FOLLY RD\COUNTRY CLUB DR Unit SO236 deviated from original dri[redacted]
2021‐12‐27 19:41:03.770 Route Deviation MAIN\CHISOLM RD Unit SO236 deviated from original dri[redacted]
2021‐12‐27 21:26:42.913 Route Deviation BOHICKET\PARTNERSHIP LN Unit SO236 deviated from original dri[redacted]
2021‐12‐28 04:47:34.427 Route Deviation N EDENVALE\BOHICKET RD Unit SO236 deviated from original dri[redacted]
2022‐01‐06 19:22:17.787 Route Deviation MAIN\MAIN RD Unit SO236 deviated from original dri[redacted]
2022‐01‐06 22:53:01.300 Route Deviation MAYBANK\PRODUCE LN Unit SO236 deviated from original dri[redacted]
2022‐01‐10 18:18:15.497 Route Deviation JAMES ISLAND EXPWY\HARBOR VUnit SO236 deviated from original dri[redacted]
2022‐01‐10 19:31:18.857 Route Deviation WOODLAND SHORES\RIVERLANDUnit SO236 deviated from original dri[redacted]
2022‐01‐10 19:54:28.923 Route Deviation MAYBANK\MAYBANK HWY Unit SO236 deviated from original dri[redacted]
2022‐01‐14 18:29:29.697 Route Deviation FOLLY\CAMP RD Unit SO236 deviated from original dri[redacted]
2022‐01‐14 20:57:23.677 Route Deviation MAYBANK\GRIFFITH LN Unit SO236 deviated from original dri[redacted]
2022‐01‐15 01:38:49.547 Route Deviation RIVERLAND\MAXCY ST Unit SO236 deviated from original dri[redacted]
2022‐01‐15 19:42:05.517 Route Deviation MAIN\BELVEDERE RD Unit SO236 deviated from original dri[redacted]
2022‐01‐15 22:00:50.097 Route Deviation CAMP\FOLLY RD Unit SO236 deviated from original dri[redacted]
2022‐01‐16 03:55:46.650 Route Deviation MAYBANK\OLD FOLLY RD Unit SO236 deviated from original dri[redacted]
2022‐01‐16 18:47:14.450 Route Deviation RIVER\NEVER NO DR Unit SO236 deviated from original dri[redacted]
2022‐01‐16 21:49:21.400 Route Deviation BOHICKET\MAYBANK HWY Unit SO236 deviated from original dri[redacted]
2022‐01‐19 23:37:58.740 Route Deviation BOHICKET\N EDENVALE RD Unit SO236 deviated from original dri[redacted]
2022‐01‐20 05:28:34.430 Route Deviation VILLAGE GREEN\KIAWAH ISLAND Unit SO236 deviated from original dri[redacted]
2022‐01‐21 02:47:09.293 Route Deviation BOHICKET\BERRYHILL RD Unit SO236 deviated from original dri[redacted]
2022‐01‐21 03:32:10.767 Route Deviation MAYBANK\BUGBY BRIDGE RD Unit SO236 deviated from original dri[redacted]
2022‐01‐25 20:47:14.670 Route Deviation MAYBANK\BRIGGER HILL RD Unit SO236 deviated from original dri[redacted]
2022‐01‐25 23:56:08.157 Route Deviation BOHICKET\EDINGS CT Unit SO236 deviated from original dri[redacted]
2022‐01‐28 23:34:44.583 Route Deviation SAVANNAH\UN[redacted] Unit SO236 deviated from original dri[redacted]
2022‐01‐29 02:58:36.263 Route Deviation AZALEA\INDUSTRIAL AV Unit SO236 deviated from original dri[redacted]
2022‐01‐30 03:45:26.647 Route Deviation FOLLY\CAMP RD Unit SO236 deviated from original dri[redacted]
2022‐01‐31 01:04:34.087 Route Deviation CAMP\FOLLY RD Unit SO236 deviated from original dri[redacted]
2022‐02‐12 21:29:40.620 Route Deviation SEA AIRE\RED GATE RD Unit SO236 deviated from original dri[redacted]
2022‐02‐12 22:56:06.683 Route Deviation BOHICKET\N EDENVALE RD Unit SO236 deviated from original dri[redacted]
EXHIBIT A - Pelletier's Route Deviations
Page 1 of 3
2022‐02‐13 02:54:55.877 Route Deviation BOHICKET\BERRYHILL RD Unit SO236 deviated from original dri[redacted]
2022‐02‐13 22:31:16.720 Route Deviation BEARS BLUFF\GRANS AV Unit SO236 deviated from original dri[redacted]
2022‐02‐16 21:19:23.687 Route Deviation MAYBANK\PAULETTE DR Unit SO236 deviated from original dri[redacted]
2022‐02‐17 00:34:51.603 Route Deviation RIVER RD\MAIN RD Unit SO236 deviated from original dri[redacted]
2022‐02‐17 03:50:48.873 Route Deviation BOHICKET\CLAM DIGGER CT Unit SO236 deviated from original dri[redacted]
2022‐02‐17 21:41:41.793 Route Deviation ARROW ARUM\DUNWICK DR Unit SO236 deviated from original dri[redacted]
2022‐02‐17 21:56:40.560 Route Deviation BOHICKET\EDENVALE RD Unit SO236 deviated from original dri[redacted]
2022‐02‐17 23:32:23.103 Route Deviation MARK CLARK EXPWY WEST\SAM Unit SO236 deviated from original dri[redacted]
2022‐02‐21 18:16:42.010 Route Deviation MEETING\WRAGG SQ Unit SO236 deviated from original dri[redacted]
2022‐02‐21 18:24:10.793 Route Deviation SAVANNAH HWY\LOCKWOOD DRUnit SO236 deviated from original dri[redacted]
2022‐02‐21 21:11:09.987 Route Deviation MAIN\MARY ANN POINT RD Unit SO236 deviated from original dri[redacted]
2022‐02‐22 03:50:00.023 Route Deviation BENJAMIN\MAIN RD Unit SO236 deviated from original dri[redacted]
2022‐02‐22 19:04:26.200 Route Deviation AZALEA\LEEDS AV Unit SO236 deviated from original dri[redacted]
2022‐02‐23 03:41:52.007 Route Deviation BOHICKET\ANGEL OAK RD Unit SO236 deviated from original dri[redacted]
2022‐02‐26 21:40:05.640 Route Deviation MAYBANK\RIVER RD Unit SO236 deviated from original dri[redacted]
2022‐02‐27 00:24:01.370 Route Deviation RIVERLAND\CANAL ST Unit SO236 deviated from original dri[redacted]
2022‐02‐27 01:02:16.103 Route Deviation RIVERLAND DR\CAMP RD Unit SO236 deviated from original dri[redacted]
2022‐03‐02 22:32:16.337 Route Deviation BOHICKET\FAIRDELL LN Unit SO236 deviated from original dri[redacted]
2022‐03‐03 20:14:36.400 Route Deviation MAIN\DOCTOR WHALEY RD Unit SO236 deviated from original dri[redacted]
2022‐03‐04 01:11:58.473 Route Deviation RIVERLAND\PENTLAND DR Unit SO236 deviated from original dri[redacted]
2022‐03‐08 04:14:22.000 Route Deviation BONANZA\CONSERVANCY LN Unit SO236 deviated from original dri[redacted]
2022‐03‐08 05:56:46.377 Route Deviation SAVANNAH HWY\MEDIAN CROSSUnit SO236 deviated from original dri[redacted]
2022‐03‐08 19:20:07.247 Route Deviation INGLESIDE\CYPRESS LAKE RD Unit SO236 deviated from original dri[redacted]
2022‐03‐08 20:48:53.953 Route Deviation STAFFORD\~1 Unit SO236 deviated from original dri[redacted]
2022‐03‐08 21:38:05.970 Route Deviation ROCK\ASHLEY PHOSPHATE RD Unit SO236 deviated from original dri[redacted]
2022‐03‐09 05:48:15.533 Route Deviation INTERSTATE 26 EAST\26 E 211A OUnit SO236 deviated from original dri[redacted]
2022‐03‐12 04:36:33.530 Route Deviation RIVER\ABBAPOOLA RD Unit SO236 deviated from original dri[redacted]
2022‐03‐12 20:51:35.937 Route Deviation FOLLY\ELLIS OAK AV Unit SO236 deviated from original dri[redacted]
2022‐03‐12 23:01:59.617 Route Deviation RIVER\MAYBANK HWY Unit SO236 deviated from original dri[redacted]
2022‐03‐13 19:41:53.383 Route Deviation CAMP\PAULINE AV Unit SO236 deviated from original dri[redacted]
2022‐03‐14 01:08:20.640 Route Deviation MAIN\CHISOLM RD Unit SO236 deviated from original dri[redacted]
2022‐03‐17 02:40:44.633 Route Deviation BEARS BLUFF\ALBERS LN Unit SO236 deviated from original dri[redacted]
2022‐03‐17 03:37:55.153 Route Deviation MAYBANK\FENWICK HALL ALY Unit SO236 deviated from original dri[redacted]
2022‐03‐17 22:13:39.420 Route Deviation MAYBANK\BROWNSWOOD RD Unit SO236 deviated from original dri[redacted]
2022‐03‐22 02:01:34.420 Route Deviation FOLLY\HARBOR VIEW RD Unit SO236 deviated from original dri[redacted]
2022‐03‐22 23:09:25.220 Route Deviation BLUEBIRD\CANE SLASH RD Unit SO236 deviated from original dri[redacted]
2022‐03‐26 00:31:30.670 Route Deviation MAYBANK\MAIN RD Unit SO236 deviated from original dri[redacted]
2022‐03‐27 01:10:55.803 Route Deviation RIVERLAND\SAMSON RD Unit SO236 deviated from original dri[redacted]
2022‐03‐30 23:57:54.757 Route Deviation MAIN\PATTON AV Unit SO236 deviated from original dri[redacted]
2022‐03‐31 19:04:23.270 Route Deviation BETSY KERRISON\CHRISTINE DR Unit SO236 deviated from original dri[redacted]
2022‐03‐31 19:40:50.690 Route Deviation BOHICKET\TONI LN Unit SO236 deviated from original dri[redacted]
2022‐04‐04 20:40:11.247 Route Deviation HARBOR VIEW\NORTH SHORE DRUnit SO236 deviated from original dri[redacted]
2022‐04‐08 19:57:33.110 Route Deviation 1017 ‐ 1025 Honey Hill Rd Unit SO236 deviated from original dri[redacted]
2022‐04‐09 00:51:25.157 Route Deviation GIBBS\LEGAREVILLE RD Unit SO236 deviated from original dri[redacted]
2022‐04‐09 03:53:48.073 Route Deviation RIVER\ARDWICK RD Unit SO236 deviated from original dri[redacted]
2022‐04‐09 21:50:33.853 Route Deviation CAMP\RIVERLAND DR Unit SO236 deviated from original dri[redacted]
2022‐04‐09 22:15:55.520 Route Deviation BEARS BLUFF\TACKY POINT RD Unit SO236 deviated from original dri[redacted]
2022‐04‐09 22:46:37.907 Route Deviation MAYBANK HWY\RIVERLAND DR Unit SO236 deviated from original dri[redacted]
2022‐04‐10 05:05:42.673 Route Deviation FOLLY\GRIMBALL RD Unit SO236 deviated from original dri[redacted]
Page 2 of 3
2022‐04‐10 18:49:17.547 Route Deviation HEADQUARTERS\~0 Unit SO236 deviated from original dri[redacted]
2022‐04‐10 22:01:52.870 Route Deviation FOLLY\CARLIN AV Unit SO236 deviated from original dri[redacted]
2022‐04‐11 02:22:36.407 Route Deviation BRADHAM\RIVERLAND DR Unit SO236 deviated from original dri[redacted]
2022‐04‐18 20:57:26.580 Route Deviation BEARS BLUFF\LONNIE TAYLOR LNUnit SO236 deviated from original dri[redacted]
2022‐04‐18 21:02:24.547 Route Deviation MCCULLOUGH DAM\JOHN MACKUnit SO236 deviated from original dri[redacted]
2022‐04‐19 01:25:26.423 Route Deviation CAMP\FERGUSON RD Unit SO236 deviated from original dri[redacted]
2022‐04‐22 19:02:49.853 Route Deviation MAYBANK\ANDROS RD Unit SO236 deviated from original dri[redacted]
2022‐04‐24 19:13:41.393 Route Deviation CAMP\JAMES POINT DR Unit SO236 deviated from original dri[redacted]
2022‐04‐25 00:34:29.967 Route Deviation BOHICKET\WINNSBORO DR Unit SO236 deviated from original dri[redacted]
2022‐04‐28 19:39:06.643 Route Deviation BOHICKET\MAYBANK HWY Unit SO236 deviated from original dri[redacted]
2022‐05‐02 21:16:32.320 Route Deviation MAYBANK\BOHICKET RD Unit SO236 deviated from original dri[redacted]
2022‐05‐02 21:52:30.153 Route Deviation RIVER RD\STARFISH DR Unit SO236 deviated from original dri[redacted]
2022‐05‐03 02:49:00.463 Route Deviation RIVERLAND\~1 Unit SO236 deviated from original dri[redacted]
2022‐05‐03 03:05:07.067 Route Deviation SAINT JOHNS WOODS\MAYBANK Unit SO236 deviated from original dri[redacted]
2022‐05‐07 22:05:14.417 Route Deviation HEDGEROW\FRESHFIELDS DR Unit SO236 deviated from original dri[redacted]
2022‐05‐08 01:17:35.303 Route Deviation 836 Riverland Dr Unit SO236 deviated from original dri[redacted]
2022‐05‐08 21:41:51.773 Route Deviation HIGHWAY 174\VILLAGE RD Unit SO236 deviated from original dri[redacted]
2022‐05‐08 22:49:32.750 Route Deviation HIGHWAY 174\WILLTOWN RD Unit SO236 deviated from original dri[redacted]
Page 3 of 3
2022‐05‐08 22:39:25.787 32583470 0 0 55 2022‐05‐08 22:38:41.160 32583470
2022‐05‐08 22:42:23.880 32584203 43 50 55 2022‐05‐08 22:42:21.193 32584203 0:00:23
SACKS is leading PELLETIER
PELLETIER gets to identical Latitude 2.7 secs after SACKS (Latitude increases moving towards Hwy 17 from Edisto)
2022‐05‐08 22:42:45.977 32588911 58 68 55 3 13 2022‐05‐08 22:42:41.460 32589164 253 0:00:45
2022‐05‐08 22:43:05.883 32594513 74 71 55 19 16 2022‐05‐08 22:43:03.303 32595495 982 0:01:05
2022‐05‐08 22:43:28.023 32601097 79 70 55 24 15 2022‐05‐08 22:43:23.210 32601097 0:01:27
2022‐05‐08 22:43:50.117 32607727 71 79 55 16 24 2022‐05‐08 22:43:45.337 32607638 0:01:49
2022‐05‐08 22:44:10.007 32613956 77 80 55 22 25 2022‐05‐08 22:44:05.227 32614268 0:02:09
2022‐05‐08 22:44:22.867 32618083 73 55 18 0:02:22
2022‐05‐08 22:44:27.883 32619428 69 78 55 14 23 2022‐05‐08 22:44:27.290 32621364 1936 ft 0:02:27
Time is the exact same for both ‐ Latitude difference is the distance apart as both moving toward Hwy 17
Latitude difference = 1936 = 19.36 seconds of latitude = 100 feet per sec
Sacks is pulling away from Pelletier ‐ she is speeding but cannot keep up
2022‐05‐08 22:44:33.897 32621122 68 55 13 0:02:33
2022‐05‐08 22:44:39.913 32622819 67 55 12 0:02:39
2022‐05‐08 22:44:45.867 32624420 67 55 12 0:02:45
2022‐05‐08 22:44:51.897 32625979 66 55 11 0:02:51
2022‐05‐08 22:44:57.883 32627444 67 83 55 12 28 2022‐05‐08 22:44:47.257 32627834 0:02:57
SACKS is 10 secs ahead of PELLETIER at same latitude (83 mph v. 67 mph)
2022‐05‐08 22:45:03.913 32629003 68 55 13 0:03:03
2022‐05‐08 22:45:08.960 32630230 64 80 55 9 25 2022‐05‐08 22:45:09.353 32634740 4510 0:03:08
2022‐05‐08 22:45:13.853 32631169 66 55 11 0:03:13
2022‐05‐08 22:45:19.367 32632792 72 55 17 0:03:19
2022‐05‐08 22:45:25.040 32634545 73 55 18 0:03:24
2022‐05‐08 22:45:30.007 32635944 68 78 55 13 23 2022‐05‐08 22:45:29.243 32640924 4980 0:03:29
2022‐05‐08 22:45:35.587 32637340 71 55 16 0:03:35
2022‐05‐08 22:45:41.727 32639455 80 55 25 0:03:41
2022‐05‐08 22:45:48.117 32641117 87 55 32 0:03:47
2022‐05‐08 22:45:52.727 32643141 91 77 55 36 22 2022‐05‐08 22:45:51.257 32647555 4414 0:03:52
2022‐05‐08 22:45:58.383 32645262 88 55 33 0:03:58
2022‐05‐08 22:46:04.180 32647179 86 55 31 0:04:03
2022‐05‐08 22:46:10.603 32649115 82 73 55 27 18 2022‐05‐08 22:46:11.460 32653158 4043 0:04:10
2022‐05‐08 22:46:16.930 32650401 63 55 8 0:04:16
2022‐05‐08 22:46:22.227 32651992 68 55 13 0:04:21
2022‐05‐08 22:46:27.807 32653510 73 55 18 0:04:27
2022‐05‐08 22:46:32.383 32654983 79 72 55 24 17 2022‐05‐08 22:46:33.383 32659183 4200 0:04:32
2022‐05‐08 22:46:37.447 32656391 85 55 30 0:04:37
2022‐05‐08 22:46:43.023 32657932 82 55 27 0:04:42
2022‐05‐08 22:46:47.493 32659372 81 55 26 0:04:47
2022‐05‐08 22:46:53.993 32660716 59 76 55 4 21 2022‐05‐08 22:46:53.243 32664433 3717 0:04:53
2022‐05‐08 22:46:58.883 32662145 65 55 10 0:04:58
2022‐05‐08 22:47:04.417 32663609 72 55 17 0:05:04
2022‐05‐08 22:47:09.767 32665024 78 55 23 0:05:09
2022‐05‐08 22:47:15.407 32666804 79 78 55 24 23 2022‐05‐08 22:47:15.280 32670707 3903 0:05:15
2022‐05‐08 22:47:20.390 32668182 77 55 22 0:05:20
2022‐05‐08 22:47:26.767 32669835 75 55 20 0:05:26
2022‐05‐08 22:47:31.467 32671212 74 55 19 0:05:31
2022‐05‐08 22:47:36.437 32672589 74 78 55 19 23 2022‐05‐08 22:47:35.327 32676396 3807 0:05:36
2022‐05‐08 22:47:42.453 32674150 72 55 17 0:05:42
2022‐05‐08 22:47:47.500 32675434 73 55 18 0:05:47
2022‐05‐08 22:47:52.610 32676778 74 55 19 0:05:52
2022‐05‐08 22:47:57.547 32678252 78 78 55 23 23 2022‐05‐08 22:47:57.313 32682889 4637 0:05:57
2022‐05‐08 22:48:02.673 32679666 77 55 22 0:06:02
2022‐05‐08 22:48:07.640 32680994 71 55 16 0:06:07
2022‐05‐08 22:48:13.030 32682527 72 55 17 0:06:12
2022‐05‐08 22:48:20.063 32684445 73 69 55 18 14 2022‐05‐08 22:48:17.233 32688904 4459 0:06:19
2022‐05‐08 22:48:25.673 32686278 74 55 19 0:06:25
EXHIBIT B - Pre-Crash Deputy Racing Data
Page 1 of 3
2022‐05‐08 22:48:30.750 32687735 74 55 19 0:06:30
2022‐05‐08 22:48:35.593 32689266 75 55 20 0:06:35
2022‐05‐08 22:48:42.110 32691144 77 74 55 22 19 2022‐05‐08 22:48:39.377 32695281 4137 0:06:41
2022‐05‐08 22:48:46.687 32692716 77 55 22 0:06:46
2022‐05‐08 22:48:52.220 32694295 79 55 24 0:06:51
2022‐05‐08 22:48:56.737 32695855 81 55 26 0:06:56
2022‐05‐08 22:49:01.767 32697552 80 70 55 25 15 2022‐05‐08 22:49:01.330 32701844 4292 0:07:01
2022‐05‐08 22:49:07.767 32699398 79 55 24 0:07:07
2022‐05‐08 22:49:13.673 32700855 73 55 18 0:07:13
2022‐05‐08 22:49:20.297 32703043 65 55 10 0:07:20
2022‐05‐08 22:49:25.830 32704540 72 69 55 17 14 2022‐05‐08 22:49:23.203 32707773 3233 ft 0:07:25
1 ‐ WILLTOWN ROAD ‐ Sign: To Charleston ‐ Hwy 164 Turn
2022‐05‐08 22:49:31.547 32705910 70 55 15 0:07:31
2022‐05‐08 22:49:37.140 32707209 55 55 0 0:07:36
2022‐05‐08 22:49:42.580 32708226 49 66 55 ‐6 11 2022‐05‐08 22:49:43.347 32713140 4914 0:07:42
2022‐05‐08 22:49:47.220 32709179 37 55 ‐18 0:07:46
2022‐05‐08 22:49:52.907 32709636 20 55 ‐35 0:07:52
2 ‐ PELLETIER turns around to go back to turn down Hwy 164
2022‐05‐08 22:50:03.673 32709195 35 63 55 ‐20 8 2022‐05‐08 22:50:03.250 32718064 0:08:03
2022‐05‐08 22:50:07.923 32708545 45 55 ‐10 0:08:07
2022‐05‐08 22:50:13.063 32707408 48 55 ‐7 0:08:12
2022‐05‐08 22:50:18.173 32706704 36 55 ‐19 0:08:17
3 ‐ PELLETIER turns down Hwy 164
2022‐05‐08 22:50:23.033 32706300 20 24 55 ‐35 ‐31 2022‐05‐08 22:50:25.250 32720712 0:08:22
2022‐05‐08 22:50:29.080 32706363 34 55 ‐21 0:08:28
2022‐05‐08 22:50:35.063 32707033 55 55 0 0:08:34
2022‐05‐08 22:50:40.533 32707859 59 55 4 0:08:40
2022‐05‐08 22:50:45.203 32708350 63 58 55 8 3 2022‐05‐08 22:50:47.250 32723624 0:08:44
2022‐05‐08 22:50:51.190 32709013 64 55 9 0:08:50
2022‐05‐08 22:50:56.097 32709571 66 55 11 0:08:55
2022‐05‐08 22:51:01.237 32710274 66 55 11 0:09:00
2022‐05‐08 22:51:06.190 32710887 69 68 55 14 13 2022‐05‐08 22:51:09.673 32729211 0:09:05
2022‐05‐08 22:51:11.127 32711334 69 55 14 0:09:10
2022‐05‐08 22:51:16.220 32712071 68 55 13 0:09:15
2022‐05‐08 22:51:21.377 32712636 69 55 14 0:09:21
2022‐05‐08 22:51:27.360 32713389 68 55 13 0:09:27
2022‐05‐08 22:51:32.517 32713975 68 73 55 13 18 2022‐05‐08 22:51:31.360 32735366 0:09:32
2022‐05‐08 22:51:37.753 32714625 68 55 13 0:09:37
2022‐05‐08 22:51:42.487 32715276 70 55 15 0:09:42
2022‐05‐08 22:51:47.877 32715869 71 55 16 0:09:47
2022‐05‐08 22:51:53.533 32716702 74 67 55 19 12 2022‐05‐08 22:51:53.220 32741471 0:09:53
2022‐05‐08 22:51:58.440 32717360 76 55 21 0:09:58
2022‐05‐08 22:52:03.550 32718077 75 64 55 20 9 2022‐05‐08 22:52:15.207 32747035 0:10:03
2022‐05‐08 22:52:08.487 32718758 76 55 21 0:10:08
2022‐05‐08 22:52:13.970 32719423 73 55 18 0:10:13
2022‐05‐08 22:52:18.627 32720072 73 55 18 0:10:18
2022‐05‐08 22:52:31.097 32721253 65 55 10 0:10:30
2022‐05‐08 22:52:35.783 32721695 64 51 55 9 ‐4 2022‐05‐08 22:52:35.300 32751612 0:10:35
2022‐05‐08 22:52:40.673 32722047 67 55 12 0:10:40
2022‐05‐08 22:52:46.643 32722647 69 55 14 0:10:46
2022‐05‐08 22:52:53.440 32723402 68 55 13 0:10:53
SACKS turns onto Hwy 17
2022‐05‐08 22:52:58.580 32723797 67 18 55 12 ‐37 2022‐05‐08 22:52:57.253 32754929 0:10:58
2022‐05‐08 22:53:05.550 32724564 67 55 12 0:11:05
2022‐05‐08 22:53:11.080 32724825 66 47 55 11 ‐8 2022‐05‐08 22:53:17.253 32755360 0:11:10
2022‐05‐08 22:53:16.643 32725401 62 55 7 0:11:16
2022‐05‐08 22:53:22.863 32725946 59 55 4 0:11:22
2022‐05‐08 22:53:28.643 32726492 58 55 3 0:11:28
2022‐05‐08 22:53:35.377 32727117 56 74 55 1 19 2022‐05‐08 22:53:39.410 32754946 0:11:35
Page 2 of 3
2022‐05‐08 22:53:40.660 32727385 58 55 3 0:11:40
2022‐05‐08 22:53:46.597 32727513 57 55 2 0:11:46
2022‐05‐08 22:53:52.113 32727752 55 55 0 0:11:51
2022‐05‐08 22:53:56.830 32727934 54 79 55 ‐1 24 2022‐05‐08 22:53:59.283 32755022 0:11:56
2022‐05‐08 22:54:01.690 32728079 52 55 ‐3 0:12:01
2022‐05‐08 22:54:07.723 32728278 47 55 ‐8 0:12:07
2022‐05‐08 22:54:12.910 32728459 44 55 ‐11 0:12:12
PELLETIER turns onto New Road ‐ Speed Limit 45 mph
2022‐05‐08 22:54:18.737 32728604 25 81 45 /55 ‐20 26 2022‐05‐08 22:54:19.457 32757003 0:12:18
2022‐05‐08 22:54:24.503 32729010 24 81 45 /55 ‐21 26 2022‐05‐08 22:54:41.787 32759600 0:12:24
2022‐05‐08 22:54:28.723 32729697 46 45 /55 1 0:12:28
2022‐05‐08 22:54:34.410 32730884 55 45 /55 10 0:12:34
2022‐05‐08 22:54:40.330 32732210 57 45 /55 12 0:12:40
2022‐05‐08 22:54:45.177 32733328 59 45 /55 14 0:12:44
2022‐05‐08 22:54:50.473 32734723 61 45 /55 16 0:12:50
2022‐05‐08 22:54:55.987 32735689 62 45 /55 17 0:12:55
2022‐05‐08 22:55:01.067 32737190 63 82 45 /55 18 27 2022‐05‐08 22:55:03.410 32762336 0:13:00
2022‐05‐08 22:55:07.143 32738371 62 45 /55 17 0:13:06
2022‐05‐08 22:55:11.003 32739341 61 45 /55 16 0:13:10
2022‐05‐08 22:55:16.130 32740730 61 45 /55 16 0:13:15
2022‐05‐08 22:55:21.237 32741914 60 45 /55 15 0:13:20
2022‐05‐08 22:55:27.177 32743419 64 82 45 /55 19 27 2022‐05‐08 22:55:25.363 32765036 0:13:26
2022‐05‐08 22:55:32.083 32744494 67 45 /55 22 0:13:31
2022‐05‐08 22:55:38.190 32746434 71 45 /55 26 0:13:37
2022‐05‐08 22:55:44.160 32748159 71 81 45 /55 26 26 2022‐05‐08 22:55:45.393 32767480 0:13:43
2022‐05‐08 22:55:49.130 32749559 71 45 /55 26 Sacks turns on dash cam 0:13:48
2022‐05‐08 22:55:55.130 32751171 71 45 /55 26 0:13:54
2022‐05‐08 22:56:01.113 32752894 70 45 /55 25 0:14:00
2022‐05‐08 22:56:06.097 32754297 68 78 45 /55 23 23 2022‐05‐08 22:56:05.300 32769294 0:14:05
2022‐05‐08 22:56:11.020 32755265 67 45 /55 22 0:14:10
2022‐05‐08 22:56:17.020 32756877 69 45 /55 24 0:14:16
5/8/2022 22:56 32758923 74 45 /55 29 0:14:22
2022‐05‐08 22:56:29.113 32760645 75 68 45 /55 30 13 2022‐05‐08 22:56:27.270 32770698 0:14:28
2022‐05‐08 22:56:34.490 32762364 75 45 /55 30 0:14:34
SACKS arrives at Stalled Vehicle
2022‐05‐08 22:56:40.177 32763871 78 45 /55 33 0:14:39
2022‐05‐08 22:56:45.207 32765491 81 45 /55 36 0:14:44
2022‐05‐08 22:56:51.177 32767429 82 45 /55 37 0:14:50
2022‐05‐08 22:56:56.770 32769366 81 45 /55 36 0:14:56
2022‐05‐08 22:57:01.223 32770969 82 45 /55 37 0:15:00
PELLETIER CRASHES
Page 3 of 3
2022‐05‐08 22:44:22.867 32618083 80344013 SO236 HIGHWAY 174\JEHOSSEE RD 6 73 EDISTO ISLAND
2022‐05‐08 22:44:27.883 32619428 80343952 SO236 HIGHWAY 174\UNNAMED_3980 ST 356 69 EDISTO ISLAND
2022‐05‐08 22:45:08.960 32630230 80342141 SO236 HIGHWAY 174\ROSA SCOTT RD 22 64 UNINCORPORATED
2022‐05‐08 22:45:52.727 32643141 80341563 SO236 HIGHWAY 174\UNNAMED_1271 ST 343 91 UNINCORPORATED
2022‐05‐08 22:46:58.883 32662145 80340695 SO236 HIGHWAY 174\WHITE POINT RD 340 65 UNINCORPORATED
2022‐05‐08 22:47:09.767 32665024 80342241 SO236 HIGHWAY 174\FREEMAN VILLAGE RD 334 78 UNINCORPORATED
2022‐05‐08 22:47:31.467 32671212 80345617 SO236 HIGHWAY 174\LITTLE BRITTON RD 335 74 UNINCORPORATED
2022‐05‐08 22:47:52.610 32676778 80348729 SO236 FAIRVIEW NURSERY RD\HIGHWAY 174 333 74 UNINCORPORATED
2022‐05‐08 22:47:57.547 32678252 80349461 SO236 HIGHWAY 174\FAIRVIEW NURSERY RD 333 78 UNINCORPORATED
2022‐05‐08 22:48:30.750 32687735 80350430 SO236 HIGHWAY 174\BARREL FACTORY RD 9 74 UNINCORPORATED
2022‐05‐08 22:48:35.593 32689266 80350150 SO236 HIGHWAY 174\TOOGOODOO RD 9 75 UNINCORPORATED
2022‐05‐08 22:48:42.110 32691144 80349806 SO236 HIGHWAY 174\MOFFETT RD 9 77 UNINCORPORATED
2022‐05‐08 22:48:46.687 32692716 80349502 SO236 HIGHWAY 174\MOFFETT RD 9 77 UNINCORPORATED
2022‐05‐08 22:49:07.767 32699398 80348068 SO236 HIGHWAY 174\SLANNS ISLAND RD 11 79 UNINCORPORATED
2022‐05‐08 22:49:25.830 32704540 80348313 SO236 HIGHWAY 174\DAWHOO RD 337 72 UNINCORPORATED
2022‐05‐08 22:49:31.547 32705910 80349073 SO236 HIGHWAY 174\WILLTOWN RD 335 70 UNINCORPORATED
2022‐05‐08 22:49:37.140 32707209 80349801 SO236 HIGHWAY 174\HIGHWAY 164 336 55 UNINCORPORATED
EXHIBIT C - Deputy Pelletier Driving Data
Page 1 of 3
2022‐05‐08 22:50:29.080 32706363 80348564 SO236 HIGHWAY 164\HIGHWAY 174 53 34 HOLLYWOOD
2022‐05‐08 22:50:35.063 32707033 80347410 SO236 HIGHWAY 164\SLANNS ISLAND RD 51 55 HOLLYWOOD
2022‐05‐08 22:50:40.533 32707859 80345976 SO236 HIGHWAY 164\RODD DR 56 59 HOLLYWOOD
2022‐05‐08 22:51:01.237 32710274 80339818 SO236 HIGHWAY 164\HICKMAN HILL RD 65 66 HOLLYWOOD
2022‐05‐08 22:51:16.220 32712071 80335341 SO236 HIGHWAY 164\JACQUELINE RD 63 68 HOLLYWOOD
2022‐05‐08 22:51:58.440 32717360 80322554 SO236 HIGHWAY 164\UNNAMED_1465 ST 62 76 HOLLYWOOD
2022‐05‐08 22:52:31.097 32721253 80312348 SO236 HIGHWAY 164\UNNAMED_1465 ST 69 65 MEGGETT
2022‐05‐08 22:52:53.440 32723402 80305607 SO236 HIGHWAY 162\STORAGE RD 69 68 HOLLYWOOD
2022‐05‐08 22:52:58.580 32723797 80304369 SO236 HIGHWAY 162\STORAGE RD 69 67 HOLLYWOOD
2022‐05‐08 22:53:05.550 32724564 80301971 SO236 HIGHWAY 162\CHARLIE RD 69 67 HOLLYWOOD
2022‐05‐08 22:53:11.080 32724825 80300790 SO236 HIGHWAY 162\RECTORY RD 69 66 HOLLYWOOD
2022‐05‐08 22:53:16.643 32725401 80299023 SO236 HIGHWAY 162\RECTORY RD 68 62 HOLLYWOOD
2022‐05‐08 22:53:22.863 32725946 80297360 SO236 HIGHWAY 162\BOCK RD 68 59 HOLLYWOOD
2022‐05‐08 22:53:56.830 32727934 80287954 SO236 HIGHWAY 162\NEW RD EXT 81 54 HOLLYWOOD
2022‐05‐08 22:54:18.737 32728604 80283208 SO236 NEW RD\NEW RD EXT 80 25 HOLLYWOOD
2022‐05‐08 22:54:24.503 32729010 80282930 SO236 NEW\HIGHWAY 162 22 24 HOLLYWOOD
2022‐05‐08 22:54:28.723 32729697 80282758 SO236 NEW\HIGHWAY 162 14 46 HOLLYWOOD
2022‐05‐08 22:54:34.410 32730884 80282399 SO236 NEW\CHAD LN 14 55 HOLLYWOOD
2022‐05‐08 22:54:40.330 32732210 80282065 SO236 NEW RD\CHAD LN 14 57 HOLLYWOOD
Page 2 of 3
2022‐05‐08 22:56:01.113 32752894 80275950 SO236 NEW\SAVANNAH HWY 14 70 HOLLYWOOD
2022‐05‐08 22:57:01.223 32770969 80270866 SO236 NEW RD\SAVANNAH HWY 13 82 HOLLYWOOD
Page 3 of 3
2022‐05‐08 22:38:41.160 32583470 80345275 SO158 HIGHWAY 174\PINE LANDING RD 0 EDISTO ISLAND
2022‐05‐08 22:42:21.193 32584203 80345994 SO158 HIGHWAY 174\PINE LANDING RD 325 50 EDISTO ISLAND
2022‐05‐08 22:42:41.460 32589164 80347524 SO158 HIGHWAY 174\JAMES BAILEY RD 3 68 EDISTO ISLAND
2022‐05‐08 22:43:03.303 32595495 80346806 SO158 HIGHWAY 174\JAMES BAILEY RD 5 71 EDISTO ISLAND
2022‐05‐08 22:43:23.210 32601097 80346112 SO158 HIGHWAY 174\RUSSELL CREEK DR 6 70 EDISTO ISLAND
2022‐05‐08 22:43:45.337 32607638 80345173 SO158 HIGHWAY 174\RUSSELL CREEK DR 6 79 EDISTO ISLAND
2022‐05‐08 22:44:05.227 32614268 80344480 SO158 HIGHWAY 174\JEHOSSEE RD 6 80 EDISTO ISLAND
2022‐05‐08 22:47:35.327 32676396 80348381 SO158 HIGHWAY 174\FAIRVIEW NURSERY RD 334 78 MEGGETT
2022‐05‐08 22:48:17.233 32688904 80350216 SO158 HIGHWAY 174\TOOGOODOO RD 7 69 UNINCORPORATED
2022‐05‐08 22:49:43.347 32713140 80350129 SO158 HIGHWAY 174\WASHINGTON LN 12 66 UNINCORPORATED
2022‐05‐08 22:50:03.250 32718064 80348839 SO158 HIGHWAY 174\DOCTOR TAYLOR RD 11 63 UNINCORPORATED
2022‐05‐08 22:50:47.250 32723624 80352698 SO158 HIGHWAY 174\ARTIS RD 323 58 UNINCORPORATED
2022‐05‐08 22:51:31.360 32735366 80351075 SO158 HIGHWAY 174\MARY RAVENEL RD 11 73 UNINCORPORATED
2022‐05‐08 22:51:53.220 32741471 80349593 SO158 HIGHWAY 174\GABE RD 11 67 UNINCORPORATED
2022‐05‐08 22:52:35.300 32751612 80347001 SO158 HIGHWAY 174\OLD JACKSONBORO RD 11 51 UNINCORPORATED
2022‐05‐08 22:52:57.253 32754929 80346202 SO158 HIGHWAY 174\SAVANNAH HWY 12 18 UNINCORPORATED
2022‐05‐08 22:53:17.253 32755360 80344679 SO158 SAVANNAH\HIGHWAY 174 93 47 UNINCORPORATED
2022‐05‐08 22:53:39.410 32754946 80337399 SO158 SAVANNAH\HIGHWAY 174 94 74 UNINCORPORATED
2022‐05‐08 22:53:59.283 32755022 80330089 SO158 SAVANNAH 81 79 UNINCORPORATED
2022‐05‐08 22:54:19.457 32757003 80322795 SO158 SAVANNAH HWY\MEDIAN CROSSOVER 68 81 UNINCORPORATED
2022‐05‐08 22:54:41.787 32759600 80314887 SO158 SAVANNAH\OLD JACKSONBORO RD 68 81 UNINCORPORATED
2022‐05‐08 22:55:25.363 32765036 80298885 SO158 SAVANNAH HWY\UNNAMED_2793 ST 68 82 UNINCORPORATED
2022‐05‐08 22:56:48.787 32771285 80273723 SO158 SAVANNAH HWY\MEDIAN CROSSOVER 1 UNINCORPORATED
2022‐05‐08 22:57:45.140 32772157 80270445 SO158 SAVANNAH\NEW RD 0 RAVENEL
EXHIBIT D - Deputy Sacks Driving Data
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Dantzler-Williams Lawsuit

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Dantzler-Williams Lawsuit

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ELECTRONICALLY FILED - 2023 May 15 9:20 AM - CHARLESTON - COMMON PLEAS - CASE#2023CP1002308

STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS

RANDALL WILLIAMS, Personal ) Civil Action No.:

TO THE DEFENDANTS NAMED ABOVE:

rendered against you for the relief demanded in the Complaint.

[Intentionally blank – signature page to follow]

/s/ Richard A. Hricik

Marvin R. Pendarvis (#101832)

ATTORNEY FOR PLAINTIFF

/s/ Clifford Bush, III

RANDALL WILLIAMS, Personal ) Civil Action No.:

NOW COMES Plaintiff Randall Williams, as Personal Representative of the Estates of

Shanice R. Dantzler-Williams and Miranda R. Dantzler-Williams, and Betty Simmons, as

Williams (hereinafter “Shanice”) and Miranda R. Dantzler-Williams (hereinafter “Miranda”) by

Order of the Probate Court of Colleton County.

Representative of the Estate of her daughter decedent, Stephanie Dantzler (hereinafter

“Stephanie”) by Order of the Probate Court of Colleton County.

damages under federal law.

damages under federal law.

5. Defendant Charleston County Sheriff’s Office (“CCSO”) is a governmental entity

6. Defendant Charleston County (“Charleston County”) is a governmental

employees including, but not limited to:

jurisdiction over the parties.

occurred in Charleston County, South Carolina.

ACTS & OCCURRENCES

DEPUTY DRIVING DATA

Date_Time Latitude Longitude Radio_Name Location Heading Speed City

Date_Time Activity Location Comment

and her staff.

a Deputy has caused a crash with their vehicle. (emphasis added).

South Carolina Highway Patrol (“SCHP”).

THE TRAINING FAILURES OF DEPUTY PELLETIER

lights as well as engaged in unsafe and dangerous passing while driving.

acceptable) Driving/ Orientation- Non-Stress Conditions.3

b. Pelletier herself wrote, “Today I feel I could improve on my knowledge of the

a. Her Field Training Instructor noted: “Deputy Pelletier continues to struggle

2 (acceptable) in Field Performance – Driving/Stressful Conditions. (emphasis added).

received no monitoring, follow-up, or remedial training of any kind.

following her recommendation for advancement. (emphasis added)

Date_Time Activity Location Comment

directions provided by Dispatch.

Pelletier’s Route Deviations, and incorporated by reference.

DEPUTIES ARE NOT AUTHORIZED TO SPEED UNLESS IT IS AN EMERGENCY

responding Deputy to:

a. Respond via the most direct route; and

b. Obey all traffic laws.

and travel at the posted speed limit.

siren to warn others is mandatory.4 (emphasis added).

THE UNLAWFUL “RACING5” OF SACKS & PELLETIER TO A NON-EMERGENCY

County Vehicles owned by Charleston County and furnished to CCSO.

on Edisto Island near Jehossee Road.

a non-emergency Stalled Vehicle on Highway 17 and responded Code 1.

Deputy Sacks Interview by SCHP 4:46-4:55).

was unfamiliar with the area they were patrolling.

herein by reference and collectively referred to as “Deputy Racing Data”.6

responding to this non-emergency call of a Stalled Vehicle:

King's Farm Market

PELLETIER SO236 SO158 SPEED SO236 SO158 SACKS Feet ELAPSED

in their County Vehicles.

any of the following actions:

a. Automatically - by driving at a speed in excess of 90 miles per hour7;

b. Automatically - with activation of emergency lights and sirens; and

c. Manually - by turning on the video camera.