IN THE SUPERIOR COURT

OF DEKALB COUNTY
GEORGIA
ANTHONY S. TRICOLI,
Plaintiff,
vs.
ROB WATTS; RON CARRUTH; JIM
RASMUS; MARK GERSPACHER;
SHELETHA CHAMPION; HENRY
HUCKABY; JOHN FUCHKO; STEVE
WRIGLEY; BEN TARBUTTON; THE BOARD
OF REGENTS OF THE UNIVERSITY
SYSTEM OF GEORGIA; SAM OLENS, THE
ATTORNEY GENERAL OF GEORGIA; and
ROBIN JENKINS
Defendants.

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CIVIL ACTION NO. 14-CV-4911

JURY TRIAL DEMANDED

AMENDED CLAIMS

Comes now Plaintiff Anthony Tricoli, pursuant to OCGA 9-11-

15 and the Amended Verified Complaint, and amends his claims, as

follows:

1.
Defendants use of state computer networks to misrepresent matter under

state jurisdiction, including the status of the GPC budget, its knowing falsifications,
and to conceal these misrepresentations and falsifications violate the Georgia
Computer Systems Protection Act (GCSPA).

2.
These same GCSPA violations constitute additional violations of OCGA 16-10-

20 by state agency employees.

3.

All misrepresentations made regarding the breach of Anthony Tricolis

contract, attempts to conceal breaches of the contract and violation of applicable

USG policies constitute additional violations of OCGA 16-10-20 by state agency
employees.

4.
All actions taken to deprive Anthony Tricoli of his contract rights consitute

Theft by Deception, a RICO predicate act.

5.

All diversions of state and federal funds in the course of knowingly falsifying

state agency reports with respect to over $9 million in GOC spending that remains
unaccounted for likewise constitutes theft by deception, a RICO predicate act.
6.

The Attorney Generals knowing misrepresentations with respect to the

written contract of Anthony Tricoli constitute additional violations of OCGA 16-10-

20.
7.
Defendants misrepresentations with respect to Tricolis contract, and other actions
causing Plaintiff unnecessary trouble and expense, render them liable to claims
under OCGA 13-16-11.
8.

The Attorney Generals knowing misrepresentations with respect to the

investigation of the missing $9 million and other allegations of criminal conduct in

this complaint constitute additional violations of OCGA 16-10-20.

Respectfully submitted this 8th day of December, 2014.

STEPHEN F. HUMPHREYS, P.C.

/s/ Stephen F. Humphreys
___________________________
STEPHEN F. HUMPHREYS
Georgia Bar No. 378099
P.O. Box 192
Athens, GA 30603
1671 Meriweather Drive
Bogart, GA 30622
(706) 543-1844 f
(706) 207-6982 p