Full text
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 1 of 134
STATE OF GEORGIA
) Case No. I :22-CV-2297
) (Related Case No.
RAISSA DJUISSI KENGNE, ) I :22-CV-2297-SEG)
Applicant, ) (Related Case No.
) 1:22-CV-2263)
v. )
ID.ME, INC. )
COGENCY GLOBAL INC. )
250 BROWNS HILL CT, )
MIDLOTHIAN, VA, 23114-9510, USA )
)
Respondent. )
EXHIBIT 2
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 2 of 134
t-'i Gmail EXHIBIT 2 Lala Kent <cianeseya2022@gmail.com>
Re: ID.me Member Support
6 messages
ID.me Member Support <support@idmeidentity.zendesk.com> Thu, May 26, 2022 at 12:22 PM
Reply-To: "ID.me Member Support" <support+id10770653@idmeidenlity.zendesk.com>
To: Cianeseya2022 <cianeseya2022@gmail.com>
Nita (ID.me Member Support)
May 26, 2022, 12:22 EDT
Good Afternoon,
Thank you for your response! We are more than happy to help you regain access to your verified
account.
To further assist you, we will need to complete a Zoom call with a live representative to confirm
your account ownership. During this call, you will be asked a series of security questions, a live
selfie will be taken, and you will need to present a Primary Identification Document (e.g. driver's
license, state ID, passport, or passport card).
To be prepared for the call:
• Have a strong wifi/data connection.
• Camera is free of debris and is not blurry.
• Ensure your device is sufficiently charged.
• Make sure your microphone and speaker are enabled.
• Make sure you are in a well-lit room.
• Bring your physical "Primary Identification Document" to the call (e.g. driver's license,
state ID, passport, or passport card).
Once you are ready, please click the link below! (Note: our hours are 8am to 6:30pm EST every
day.)
https://help.id.me/hc/en-us/p/account-recovery
l af8 6/13/2022, l 0:55 PM
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 3 of 134
We look forward to speaking to you soon! Should you have any additional questions or concerns,
feel free to reach back out.
Warm regards,
Nita
Member Support Team
ID.me, Inc.
ID.me Support I ID.me I Twitter I Facebook
Veterans Get Secure Single-Sign On for Benefits
President's National Strategy for Trusted Identities in Cyberspace
Building the Trust Graph
This message (including any attachments) may contain confidential and privileged information
belonging to the sender, for a specific individual and purpose, and is legally privileged. If you
are not the intended recipient, you should delete this message and any disclosure, copying,
forwarding or distribution of this message, or the taking of any action based on it, by you is
strictly prohibited.
Cianeseya2022
May 24, 2022, 00:01 EDT
Shamora:
Were you able to update my email address? What additional steps need to be taken? I am using my account for
GDOL; the fact that I am unable to access my ID ME account is also preventing me from receiving benefits.
Sincerely,
Raissa ~
Raissa Kengne. CISA, CRISC, CISM, CIA, CFE, Lean Six Sigma
CEO and President of A La Pousse, LLC
CEO and President of Kengne's CPA and Consulting Firm
cianeseya2022@gmail.com
raissa.kengne2022@protonmail.com
Cianeseya2022
May 20, 2022, 17:12 EDT
2 of 8 6/13/2022, 10:55 PM
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 4 of 134
Hello Shamora:
Were you able to update my email address? What additional steps need to be taken?
Sincerely,
Raissa -
Cianeseya2022
May 17, 2022, 18:51 EDT
Hello Shamora:
Thank you for your email. Please let me know if you need any additional information from me as you take some
additional steps.
Sincerely,
Raissa-
Raissa Kengne, CISA, CRISC, CISM, CIA, CFE, Lean Six Sigma
CEO and President of A La Pousse, LLC
CEO and President of Kengne's CPA and Consulting Firm
cianeseya2022@gmail.com
raissa.kengne2022@protonmail.com
404-932-1651
Shamora (ID.me Member Support)
May 17, 2022, 18:36 EDT
Hello,
Thank you for contacting ID.me. I am sorry to hear you are unable to access your verified
account. I am more than happy to assist.
In order for us to update your email address, we need to take some additional steps. We will do
our best to resolve your request as soon as possible.
If you have questions or additional information, please simply reply to this email. We will resolve
your request as soon as possible.
3 of8 6/13/2022, 10:55 PM
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 5 of 134
Warm regards,
Shamora
Member Support Associate
ID.me, Inc.
ID.me Support I ID.me I Twitter I hllps://www.facebook.com/lDmelnc)
Veterans Get Secure Single-Sign On for Benefits
President's National Strategy for Trusted Identities in Cyberspace
Building the Trust Graph
This message (including any attachments) may contain confidential and privileged information
belonging to the sender, for a specific individual and purpose, and is legally privileged. If you
are not the intended recipient, you should delete this message and any disclosure, copying,
forwarding or distribution of this message, or the taking of any action based on it, by you is
strictly prohibited.
Cianeseya2022
May 16, 2022, 16:13 EDT
Hello:
I have changed my email address from rkengne1@gmail.com to cianeseya2022@gmail.com.
I no longer have access to the initial address email I used: rkengne1@gmail.com.
I am unable to log into ID.Me in order to verify my ID and update my payment information for UI
GDOL.
Can you please assist with updating my email address on ID.Me so that I can proceed with an
Identification?
Sincerely,
Raissa -
This email is a service from ID.me Member Support. Delivered by Zendesk
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4 of8 6/13/2022, 10:55 PM
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 6 of 134
ID.me Member Support <support@idmeidentity.zendesk.com> Thu, May 26, 2022 at 12:25 PM
Reply-To: "ID.me Member Support" <support+id10770653@idmeidentity.zendesk.com>
To: Cianeseya2022 <cianeseya2022@gmail.com>
Nita (ID.me Member Support)
May 26, 2022, 12:25 EDT
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ID.me Member Support <support@idmeidenlily.zendesk.com> Fri, May 27, 2022 at 11:50 AM
Reply-To: "ID.me Member Support" <support+id10770653@idmeidentity.zendesk.com>
To: Cianeseya2022 <cianeseya2022@gmail.com>
5 of8 6/13/2022, I 0:55 PM
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 7 of 134
John (ID.me Member Support)
May 27, 2022, l l :50 EDT
Hello Raissa,
This is John, thank you for confirming your information with me on the Zoom call. We have
submitted a ticket to update your account, and will contact you as soon as it has been done.
Thank you for your patience.
Warm regards,
John
Member Support Associate
ID.me, Inc.
ID.me Support I ID.me I Twitter I Facebook
[Quoted text hidden]
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Lala Kent <cianeseya2022@gmail.com> Sun, May 29, 2022 at 8:39 PM
To: "ID.me Member Support" <support+id10770653@idmeidentity.zendesk.com>
Hello John:
I have not received an email from you or from ID.Me to let me know that the email address change was done.
Should you need any other additional information from me, please do not hesitate to reach out to me.
Sincerely,
Raissa -
Raissa Kengne, CISA, CRISC, CISM, CIA, CFE, Lean Six Sigma
CEO and President of A La Pousse, LLC
CEO and President of Kengne's CPA and Consulting Firm
cianeseya2022@gmail.com
raissa.kengne2022@protonmail.com
404-932-1651
6 of8 6/13/2022, I 0:55 PM
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 8 of 134
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ID.me Member Support <support@idmeidentity.zendesk.com> Tue, May 31, 2022 at 10:05 AM
Reply-To: "ID.me Member Support" <support+id10770653@idmeidentity.zendesk.com>
To: Cianeseya2022 <cianeseya2022@gmaiLcom>
John (ID.me Member Support)
May 31, 2022, 10:05 EDT
Hello Raissa,
Thank you for your message.
I have reviewed the status of your account update and see that the update is still being
processed. I apologize for the delay.
I will contact you again as soon as I receive confirmation that your account update has been
completed. Thank you for your continued patience.
Warm regards,
John
Member Support Associate
ID.me, Inc.
ID.me Support I ID.me I Twitter I Facebook
Veterans Get Secure Single-Sign On for Benefits
President's National Strategy for Trusted Identities in Cyberspace
Building the Trust Graph
This message (including any attachments) may contain confidential and privileged information
belonging to the sender, for a specific individual and purpose, and is legally privileged. If you
are not the intended recipient, you should delete this message and any disclosure, copying,
forwarding or distribution of this message, or the taking of any action based on it, by you is
strictly prohibited.
7 of8 6/13/2022, I 0:55 PM
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 9 of 134
Cianeseya2022
May 29, 2022, 20:39 EDT
Hello John:
I have not received an email from you or from ID.Me to let me know that the email address change was done.
Should you need any other additional information from me, please do not hesitate to reach out to me.
[Quoted text hidden]
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Lala Kent <cianeseya2022@gmail.com> Fri, Jun 3, 2022 at 5:16 PM
To: "ID.me Member Support" <support+id10770653@idmeidentity.zendesk.com>
John:
REQUEST:
I am following up again on the status of my request. Is there a legal process that I need to take on my end in order to
fast forward the process?
This is a typo. It should have been November 18th, 2021.
I have not received any income since November 18th, 2022. I was constructively discharged from BOO USA after
notifying my supervisor, the SEC, and the PCAOB of unethical behaviors that are in violation of SEC regulations and
PCAOB standards exhibited by Wesley Freeman, Scott Meier, Peter Poppo, Paul Davidson, Mark Davenport, and
Johnson Wong at the following public companies and their affiliates: Interface, Atlanticus, BioHorizons (Henry
Schein's subsidiary), Otelco, BlueLinx, NMS SPAR (subsidiary of SPAR).
Since I filed a complaint with the SEC and the PCAOB, my home has been broken into. My phones and computers
have been hacked.
ID.ME RESPONSIBILITY:
Since GDOL requires unemployed US citizens to utilize ID.ME, ID.ME has a legal responsibility to provide citizens
with its services in a timely manner.
It has been months now that I am unable to access my account.
Should the delay be resolved by a Judge injunction, please let me know and I will start the legal process.
Have a nice week-end!
Sincerely,
Raissa -
Raissa Kengne, CISA, CRISC, CISM, CIA, CFE, Lean Six Sigma
CEO and President of A La Pousse, LLC
CEO and President of Kengne's CPA and Consulting Firm
cianeseya2022@gmail.com
raissa.kengne2022@protonmail.com
[Quoted text hidden]
8 of 8 6/13/2022, 10:55 PM
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 10 of 134
STATE OF GEORGIA
) Case No. I :22-CV-2297
) (Related Case No.
RAISSA DJUISSI KENGNE, ) I :22-CV-2297-SEG)
Applicant, ) (Related Case No.
) l:22-CV-2263)
V. )
ID.ME, INC, )
COGENCY GLOBAL INC. )
250 BROWNS HILL CT, )
MIDLOTHIAN, VA, 23114-9510, USA )
)
Respondent. )
EXHIBIT 3
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 11 of 134
State of Georgia
Department of Labor
SEPARATION NOTICE
EXHIBIT 3
1. Employee1s Name_R_a_is_sa_K_e_n_g_n_e_ _ _ _ _ _ _ _ _ _ _ _ _ _ __ 2. SSN
a. State any other name(s) under which employee worked.
3l_2_o_i9_ _ _ _ _ _ _ _ _ _ _ _ To _ _IJ/_l_B/']
3. Period of Last Employment: From __9_i_ __
JJJ.l _ _ _ _ _ _ _ _ _ __
,, ... ,., •.,, '• ·f/'- • ',. ,,, ~:,ff•,:,,· ·:.,,.11'
4. REASON FOR SEPARATION:
a. LACK OF WORK □
b. If for other than lack of work, state fully and clearly the circumstances of the separation:
5. Employee received payment for: (Severance Pay, Separation Pay, Wages-In-Lieu of Notice, bonus, profit sharing, etc.)
(DO NOT include vacation pay or earned wages)
_N_i_A_(ty-pe-of_p_a-ym-•n-t)___ in the amount of$ _ _ _ _ __ for period from _ _ _ _ _ _ __ to _ _ _ _ _ _ __
Date above payment(s) was/will be issued to employee _ _ _ _ _ _ _ _ _ __
IF EMPLOYEE RETIRED, furnish amount of retirement pay and what percentage of contributions were paid by the employer.
per month o.oo% of contributions paid by employer
6. Did this employee earn at least $7,300.00 in your employ? YES ~ NOD If NO, how much?$,_ _ _ _ _ _ _ _ __
Average Weekly Wage _ _ _ _ _ _ _ __
Employer's BOO USA, LLP Ga. D. 0. L. Account Numbell!!!!!!!!!!l■■■I!_______
Name _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
This is the number assigned to the employer by Georgia
1100 Department of Labor.
Address _ _ _ Peachtree
____ Street
__ NE,
_Suite
__ 700
_ _ _ _ _ _ __
(Street or RFD) I CERTIFY that the above worker has been separated from work
and the information furnished hereon is true and correct. This
City Atlanta State GA 30309
----+----- report has been handed to or mailed to the worker.
ZIP Code
Employer's
Telephone No. _(_40_4,,,)_6_56_·,,_67_5~0~------------
(Area Code) (Number) Signature of Official, Employee of the Employer
or authorized agent for the employer
NOTICE TO EMPLOYER
At the time of separation, you are required by the Employment Senior HR Specialist
Security Law, OCGA Section 34-8-190(c), to provide the
Title of Person Signing
employee with this document, properly executed, giving the rea-
sons for separation. If you subsequently receive a request for the
11/18/2021
same infom,ation on a DOL-1199FF, you may attach a copy of this form
(DOL-800) as a part of your response. Date Completed and Released to Employee
NOTICE TO EMPLOYEE
OCGA SECTION 34-8-190(c) OF THE EMPLOYMENT SECURITY LAW REQUIRES THAT YOU TAKE
THIS NOTICE TO THE GEORGIA DEPARTMENT OF LABOR FIELD SERVICE OFFICE IF YOU FILE A
CLAIM FOR UNEMPLOYMENT INSURANCE BENEFITS.
SEE REVERSE SIDE FOR ADDITIONAL INFORMATION.
DOL-800 (R-6/19)
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 12 of 134
INSTRUCT1ONS TO EMPLOYER FOR COMPLETION
OF THIS SEPARATION NOTICE
In accordance with the Employment Security Law, OCGA Section 34-8-190(c) and Rules pursuant thereto, a Separation
Notice must be completed for each worker who leaves your employment, regardless of the reason for the separation. This
notice shall be used where the employer-employee relationship is terminated and shall not be used when partial (DOL-408)
or mass separation (DOL-402) notices are filed.
Item 1. Enter employee's name as it appears on your records. If it is different from the name appearing on the employee's
Social Security Card, report both names.
Item 2. Enter the employee's Social Security Number. Verify for correctness.
Item 3. Enter the dates of employee's most recent work period.
Item 4. a. If the reason for separation is for "LACK OF WORK," check box indicated.
b. If the reason for separation is OTHER THAN "lack of work," give complete details about the
separation in space provided. If needed, add a separate sheet of paper.
Item 5. If any type payment, (i.e. Separation Pay, Wages-in-lieu of Notice, etc.) was made, indicate the type of payment
and the period for which payment was made beyond the last day. Give the date on which the payment was/will
be issued to the employee. DO NOT include vacation pay or earned wages.
Item 6. Check the appropriate block YES or NO to indicate whether this employee earned at least $7,300.00 in your em-
ploy. If you check NO, enter amount earned in your employ. Give average weekly wage (without overtime) at the
time of separation.
Employer's Name. Give full name of employer under which the business is operated.
Address. Give full mailing address of the employer where communications are to be sent in regard to any potential
claim.
Company's Georgia DOL Account Number. Your state DOL Unemployment Insurance Account Number as it appears on
your Quarterly Tax and Wage Report, Form DOL-4.
Signature. This notice must be signed by an officer or employee of the employer or authorized agent for the employer,
and this person's title or position held with the employer must be shown.
Date. This notice must be dated as of the date it is handed to the worker. If the employee is no longer available
at the time employment ceases, mail this form (DOL-800) to the employee's last known address and enter
date the form is mailed.
····························································································································································································································--·--····
OCGA Section 34-8-256(b)
PENALTY FOR OFFENSES BY EMPLOYERS. "Any employing unit or any officer or agent of an employing unit or any other
person who knowingly makes a false statement or representation or who knowingly fails to disclose a material fact in order
to prevent or reduce the payment of benefits to any individual entitled thereto or to avoid becoming or remaining subject to
this chapter or to avoid or reduce any contribution or other payment required from an employing unit under this chapter or
who willfully fails or refuses to make any such contributions or other payment or to furnish any reports required under this
chapter or to produce or permit the inspection or copying of records as required under this chapter shall upon conviction be
guilty of a misdemeanor and shall be punished by imprisonment not to exceed one year or fined not more than $1,000.00
or shall be subject to both such fine and imprisonment. Each such act shall constitute a separate offense."
OCGA Section 34-8-122(a)
PRIVILEGED STATUS OF LETTERS, REPORTS, ETC., RELATING TO ADMINISTRATION OF CHAPTER. "All letters, reports,
communications, or any other matters, either oral or written, from the employer or employee to each other or to the de-
partment or any of its agents, representatives, or employees, which letters, reports, or other communications shall have
been written, sent, delivered, or made in connection with the requirements of the administration of this chapter, shall be
absolutely privileged and shall not be made the subject matter or basis for any action for slander or libel in any court of
the State of Georgia."
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 13 of 134
STATE OF GEORGIA
) Case No. I :22-CV-2297
(Related Case No.
RAISSA DJUISSI KENGNE, ) l:22-CV-2297-SEG)
Applicant, ) (Related Case No.
) l:22-CV-2263)
V. )
ID.ME, INC. )
COGENCY GLOBAL INC. )
250 BROWNS HILL CT, )
MIDLOTHIAN, VA, 23114-9510, USA )
)
Respondent. )
EXHIBIT 4A
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 14 of 134 1·· -
05/16/2022
RAISSA DJUISSI KENGNE
26B1 WEST MAIN STREET NW
ATLANTA, GA 3031B
Reference Loan Number 2020004139 .J Jt: ,, . , . , ," .,,~
Due to non-payments, the above-referenced 111011gage loan 15 'ctelmqucnt. The loan mu;! be,'l\'lrought current within 30 days of
the date of this letter by sending the amount shown below to Delta Community Credit Union 1n the form o( a money order or
certified check.
The total amount due as of this date ls $3,774.08.
ln order to bring the above-referenced account current, any payments or late charges that become due during this 30-day
period. along with the amount shown above, must be included to bring the account current. Delta Community Credit Union's
acceptance of less than the total amount due above does not waive our right to demand the entire balance due under the
terms of the mortgage.
If the account is not brought current within 30 days of the date of this letter, Delta Community Credit Union will accelerate the
outstanding balance of the loan pursuant to the terms of the mortgage. This amount will include but not limited to, the
principal. interest, and all other outstanding fees and costs collectible under the loan documents. If the account is not brought
curren~, Delta Community Credit Union will commence legal in rem foreclosure proceedings against the property, which could
resu\~ 1n the sa\e o1 the property.
Delta Co,mmunity Credit Union hereby demands and notifies you that it requires strict compliance with the terms of th I
documents as se! forth therein. Any previous acceptance ~f late payment~ does not constitute in any way a de artur:
the terms or requrrements of the loan documents, nor a waiver or any previous or subsequent default occu • ~h f
f~i;
future acceptance of late payments by the Delta Comr:,unity Credit Union does not constitute a waiver of mngf
0 O
uf ar. Any
Community Credit Union's rights to exercise its remedies underthe loan documents and pursuant to th I an~ h eta
default. e .aw 1n t e even.t of
If you have received a bankruptcy discharge of the indebtedness secured by your mart th· .
attempt to collect the persona! debt; howe~er, it will be necessary for you to bring the delin guaegn~' b rs letter IS n~t an
avoid foreclosure If you do not intend to retain the property, we would request that you cont qt t al~nce current m order to
available to you. · ac us O discuss other options
You have the right to reinstate your loan current after legal action has commenced. Yo I h .
foreclosure proceeding against you and refute the stated default or Present relevant defiu a so ave the right to respond to any
Union's legal action against the property. ense to our Delta Community Credit
Delta Community Credit Union wishes to work with you to reso6v~!~: Problem and help ou .
standing. We urge you to contact us _at (404) 677-8688 or (BO ) 3328, and someon~ wi1f~~g/our account into good
possible alternatives to foreclosure with you. appy to discuss with you the
Sincerely,
Loss Mitigation Recovery
I
i
NCUA
'!r1,,--, ,•~•,l~d,'1 •,
•,1,,-:t.,1•,'..,',•.1l(,1!1
IJ:. i:•• .:1C.,1
----
!v1ortgagE< Servicing D~p.m!~n0_0.!
·-- .. ---
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 15 of 134
•
0MB Approval No. 2502-0584
Servicemembers Civil Relief U.S. Department of Housing
Expire 11/30/2024
Act Notice Disclosure and Urban Development
office of Housing
Legal Rights and Protections Under the SCRA
Servicemembers on "active duty" or "active service," or a spouse or dependent of such a sen:i~eme~ber
may be entitled to certain \cgnl protccti011s and debt relief pursuant to the Servicemembers Civil Relief Act
(50 use§§ 390\4043) \SCRA).
Who l\fay Be Entitled lo Lcgal l'rotcclions Undcr the SCRA?
• Regular 1nembcrs of th!! U.S. Armed Forces (Anny. Navy, Air Force Marine Corps and
Coast Guard\.
• Reserve and Nati0n::i\ Guard personnel who have been aclivatcd and arc on Federal active duty
• National Guard personnel undc\' a call or order to active duty for more than 30 consecutive days under
section 502.(f) of title 32, Un\tcd States Code, for purposes of responding to a national emergency
declared by the President and supported by Pcderal funds
• A.cti\"e ser\"ice members of the commissioned corps oftha Public Health Service and the
'National Oceanic and Atmospheric Administration.
Certain United States citizens serving with the anned forces of a nation with which the United
States is a\lied in the prosecution ofa war or military action.
\\'hat Legal Protections Are Servicemembers Entitlec\ To Under the SCRA?
The SCRA states that a debt incurred by a servicemember, or seivicernember and spouse jointly, prior to enterin('I'
:11ilitary service shal_l no_t bear ~tc~~t at a r?~ aboVe6 % during the period of military service and one year the~fler.
m the case of an obhganon or liab1hty c.ons1stmg of a mortgage, trust deed, or other security in the nature of a
mortgage, or dtJring the period of military seivice in the case of any other obligation or liability.
• The SCRA states that in a legal action to enforce a debt against real estate that is filed during or ,v·ith'
• , •i· • , m one
year after the serv1ce~~mber s m1 1tary service, a cou~ may stop the proceedings for a period of time, or
adjust the debt. In add1t1on, the sale, foreclosure, or sei~~ire of real estate shall not be valid if it occurs
during or v-.-ithin one year after the servicememb:r's military service unless the creditor has obtained a valid
court order approving the sale, foreclosure, or seizure of the real estate.
The SCRA contains many other protections besides those applicable to home loans.
How Docs A Servicemembcr or Dependent Rcgue st Relief Under the SCRA?
• Jn order to request relief under the SCH.A from lo.rns with interest rates above 6o/c .
spouse must provide a written request to tht! lcndi:~·: _together with n copy of the s::tcerv1cc111:n,1bcr_ ~r
orders. !Note: Lender should place its name, addn,:ss,. ur~d con!nct information I l ~member s nulnary
. I SC!lA I1ow1wer, Jor ,1 serv1c iere.
• There is no requ1rcm1:nt under t 1e • , , I ·r. emcmber to provid ,. .
1
copy of a servicemcmbcr's military orders to_ tll1e ~1~~:cut/111;,~nru.~ction With a forcc~:t,\\rtttcn 1h1ot1ce or a
. • . ·~· I cst·th.! Undc1 t 1es <tnces le re or at er debt
enforcement aclwn agam st lt:,I ' • fl)d'cnse's D • ll(Iers should inq ·
status of a person by searching the Dcpar_tn_1cnt lo ·r Jih:s lo . e!e_nse rvlanpower D t uC1re a 6o,ut the military
· b , d cx·1111mmg t iei r 1ntlic1a of 11 ·i· u a enters websit
contacting the scrv1ccmcm er, cm ' • • 1t1er of their nii\it
1
11 ltary service A ltl e,
requirement for scrvicemembcrs to akrt tic u 1 ary status in thcst: silt. t' 10~1gh there is no
.1 so ia tons it st'II.
idea !Or the scrviccmcm bcr IO uo · . ' L IS u good
, . dl'nl Obtain (lllo1·n1a.tion Ab
lloW Docs a Scrviccmcmbcr or De ,en out the SCRA'?
uoul Lhc SCR
l l' vllh qucstiuns a • . • A should
Scrvicc:membcrs and dcpc1!l l.!II s \ . I Assif.\aJIL'L' 01t1~1:_r.l I\ n1tlit•1ry I contact their unit'. J
· · •t• lht1on's Lcg,i · · .. //l~!.!ll ;is,· ' cgaJ • .s udge
Advocate, or t I1c1r 111s d ' • • . . • • , blL' iit IJ.!!f11!·-- 1str1nc\ I· assistance off·~
1
branches of the Armed Forces is t1V,U ,1 ·, ··• . I.!, aw.nf.rnil/ li.:c locator for all
f l)i.;Ji.;llSL: S 1/Jf
.... tlw U S. Dcp11rtn1c11t o 1cnsc go to orniution re•
"IVlililary OncSourcc is s'cl' A (st.:c abuVC), p 1·,11<l IJ~t Www.,nn·,,. source, If you ilP 1·
· • 111dcr th!.!' ' . ,·1 to . llJo • a o, • c IStcd a• .
to legal protcc11ons L . J t.: l 'niii.:d Slat1::-. ~·i..!p;lll!, re Utfon . icsourct!.mil/le ,. :s ~ntllleJ
(800) 3•12·')647 (toll Jh.:i: from 11. providi.:d on tile' 1
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ar(;as outside the United swics arc .s ructions for
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 16 of 134
STATE OF GEORGIA
) Case No. I :22-CV-2297
) (Related Case No.
RAISSA DJUISSI KENGNE, ) 1:22-CV-2297-SEG)
Applicant, ) (Related Case No.
) l:22-CV-2263)
v. )
ID.ME,INC. )
COGENCY GLOBAL INC. )
250 BROWNS HILL CT, )
MIDLOTHIAN, VA,23114-9510, USA )
)
Respondent. )
EXHIBIT 4B
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 17 of 134
1691 lions Club Road• PO Box 111 • Madison, GA 30650-0111
706.342.2352. 888.327.3969 ext. 5 • 706.342.8117 (fax)
EXHIBIT 4B AgSouthFC.com
January 19. 2022
Mr. Raissa Kengne
1280 W Peachtrtcc St 112109
Atlanta. GA 30309 f, :,s;,
Dear Mr. Kcngnc:
As of this date. \\'C have not received your January installment. This installment is now
more than 15 days past due. Please have this payment paid no later than Friday, January
28th, 2022. It is very important that we receive your payments in a timely manner.
Please go ahead and make your payment immediately.
Because it is so late in the month, do not mail your payment to Loekbox in Texas. Please
mail this payment directly to the Madison office at PO Box 111, Madison or bring your
payment by the branch office at I 691 Lions Club Road, Madison.
If you bring your payment by the office after hours or over the weekend, please put it in
our mailbox.
We appreciate your immediate attention to this important matter.
Sincerely,
~~ir~~
Kenny 1-Iuto
Vice President
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 18 of 134
109 E. Church St, PO Box 2607 • Batesburg-Leesville, SC 29070
803.532.3841 • 800.238.7447 • 803.532.8202 (fax)
AgSouthfC.com
February 23, 2022
Raissa D. Kengne
1280 W. Peachtree Street NW #2109
Atlanta, GA 30309
CERTIFIED WITH RETURN RECEIPT REQUESTED AND REGULAR MAIL
#70190160000090392854
RE: Loan# 0114485610
Dear Ms. Kengne;
As a result of your failure to pay the sums due and owing as called for in the Note, AgSouth has
elected to exercise the remedies available to it under the Note and related loan documents
(collectively "Loan Documents") and accelerate the full amount of the debt.
Accordingly, notice is hereby given you that the terms of said Note wherein you agree to pay
reasonable attorney's fees in the event of a default shall be enforced by legal proceedings
unless the full amount of the unpaid principal, accumulated interest, advances, etc., in the sum
of$ 36,164.33 together with interest accruing thereon, are fully paid within ten (10) days from
receipt of this notice as provided in Section 13-1-11 of the Official Code of Georgia, Annotated.
If you pay the full amount set forth above within ten (10) days, you may consider your
obligations under the Loan Documents satisfied. Should you fail to do so, AgSouth will exercise
the remedies available to it under the Loan Documents and applicable law including legal action
against you.
As a further result of your loan being in default, your "C" Participation Certificates in the
Association shall be retired in total or partial liquidation of the loan. As of the projected date of
the retirement of your "C" Participation Certificates, your outstanding debt to the bank will be
your present outstanding debt in the amount of $36,164.33, together with accrued interest,
attorney's fees and costs, less application of "C" Participation Certificates in the amount of
$765.00.
Please note that interest, late fees, and costs continue to accrue; therefore, it is imperative that
you contact me before tendering any sums to obtain a correct figure for payoff.
I look forward to hearing from you.
Sincerely,
//~--
Gene Mccutchen
Special Assets Manager
NMLS#1071117 Office: (803)532-3841, Ext. 8417 Cell: (803)429-7042
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 19 of 134
~~•AgSouth
••
Farm Credit, ACA
1691 Lions Club Road• PO Box 111 • Madison, GA 30650-0111
706.342.2352 • 888.327.3969 ext. 5 • 706.342.8117 (fax)
AgSouthFC.com
March 15, 2022
Greetings from AgSouth Farm Credit,
Because you are such a valued custonwr or AgSnuth Farm Credit, I want to let you lmow that Zack Lovingood has
accepted a new job within the Farm cn,dit System and has relocated to North Carolina, I would like to take this
opportunity to thank you for your business, and I would also like to introduce to you to Zack's replacement,
Kenny Hutto.
Kenny will be working with you in the future and will place the same high value on maintaining your
relationship as Zack did. Kenny received a Bachelor of Business Administration from Georgia College. He has
been with AgSouth since August, 2019 and has been in community banking for nearly 20 years. He has the
knowledge and experience to help ensure your success. Kenny resides in Barnesville, GA with his wife and two
children. You may have already met him at a local meeting or event. If not, I'm sure he will be making plans to
introduce himself either in-person or over the phone.
Please note that this will in no way impact the way your account is handled. We expect this transition to be a
smooth one, and I assure you that Kenny is committed to serving your financial needs. If you have any questions
about your account or would like to inquire about a new loan or lease, please give Kenny a call at 706.342.2352
or email him at KHutto@agsouthfc.com.
We appreciate your business.
As a reminder, we make loans for: Benefits of financing through AgSouth:
• Small & large acreage tracts •Fixed rates up to 20 years on land
• Recreational properties (15 years for lot loans)
• Timber land •Competitive rates & terms
• Farms •Up to 85% financing available
• Operating lines of credit •Participate in our Patronage Program
• Livestock & equipment • Lending staff specialized in land & ag financing
• Home construction & purchases
Very truly yours,
~~
Clark David
Regional Vice President
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 20 of 134
FORTSON, BENTLEY AND GRIFFIN, P.A.
ELBERT N. WHlTM\RE. 1\1. C,P.A, ELINORE R, YOUNG
ATTORNEYS AT LAW
G, MARCUS HODGE (GA&. SC) 2500 DANIELL"S BRIDGE ROAD EMILY I<. ESCOE
DAVID K. LINDER BUILDING :200, SUITE 3A
LINDSEY B. WOODARD
ATHENS, GEORGIA 30606
ROY E. MANOLL. 111 ABBEY J. DUH~
WALTER W. HAYS. JR. (706) 546•1161 JOHNELI..E SIMPSON. 11
MICHAEL J. MCCLEARY
V, KEVIN lANG UPSHAW C. BENTLEY. JR.
(192A - 2013)
TREVOR T. JONES (GA So. AL)
EDWIN B, FORTSON
BRICKER S. DAUGHTRY (1913-2007)
JOHN E, GRIFFIN
H. SCOTT LOWRY, JR.
(1923·2002)
DAVID F. ELLISON HERBEIH T. HUTTO
( 1933-1998)
WADE A. SCHUENEMAN
GREGORY 0. DEBACKER
June 2, 2022
OECOIJNSEI
WIWAM C, BERRYMAN, .JR.
Ms. Raissa Kengne
570 Piedmont Avenue, NE Unit 55166
Atlanta, Georgia 30308
Re: Ag South Fam1 Credit Loan No: 114485610
Dear Ms. Kengne:
AgSouth forwarded your Request for Forbearance letter to me for review. Even
presuming the Cares Act Moratorium and the forbearance period tllat you referenced were ever
applicable your land loan, both the Moratorium and the forbearance period expired. AgSoutll
therefore rejects your request for a forbearance of the above referenced loan and will proceed
with the foreclosure.
Please do not hesitate to contact me if you have any questions.
Sincerely,
FORTSON, BENTLEY AND GRIFFIN, P.A.
6½ <!M~-;;:;-
Roy E. Manoll, III
.:;,---
REM/kdd
cc: AgSouth Farm Credit
THIS FIRM IS ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THOSE PURPOSES
Ol 11198fl.l I/Ol02!J7-0l>OOlol
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 21 of 134
~)AgSouth Farm Credit, ACA
109 E. Church St • PO BoK 2607 • Batesburg-Leesville, SC 29070
803-532-3841 • 800-238-7447 - 803-532-8202 (fax)
AgSouthFC.com
April 28. 2022
Raissa D. Kengne
1280 W. Peachtree St. NW #2109
Atlanta. GA 30309
Re: BE II 316124-0001
Dear Ms. Kengne:
You currently have a loan with our association that is in default. Pursuant to Section
840.40 of the Bylaws, the Board of Directors of AgSouth Farm Credit has approved the
application of your 2021 Patronage in the amount of$641.61 to your past due balances.
You are hereby advised as follows:
1. Your loan with the association is currently in default.
2. The association intends to apply all or a portion of your Patronage in full
or partial liquidation of the unpaid balances of your loan(s).
3. The application of the Patronage will have no other effect on your
relationship with our association.
4. After application of your Patronage, the remmmng amount of your
indebtedness to the association will be $37,279.97.
5. Your Patronage will be applied as of May 12, 2022.
Sincerely,
Gene McCutchen
Special Assets Manager
GMC/ttn
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 22 of 134
/\
~V FARM CREDIT
AGSOUTH FARM CREDIT ACA
MADISON BRANCH OFFICE STATEMENT DATE 02/10/22
1691 LIONS CLUB RD LOAN NUMBER 03-052-019·0114485610
PO BOX 111
~IADISON GA 30650-0111 PAYMENT DUE DATE 03/01/22
TOTAL AMOUNT DUE $1,071.74
Any activity after the statemont date will appear
on your next billing statement.
Questions concerning your account?
Please write us at the address above or call:
1-706-342-2352 or 1-888-327-3969
BALANCES FOR THIS LOAN AS OF 02/10/22:
LOAN PURPOSE PRINCIPAL BALANCE CURRENT RATE INTEREST PAID YEAR-TO-DATE FUNDS HELD
LOT PURCHASE S35,569.70 6.375% $0.00 $0.00
AMOUNT DUE:
PAST DUE ITEMS $661.16
PRINCIPAL $143.12
INTEREST $187.46
TAXES/FEES $30.00
LATE CHARGES $50.00
TOTAL AMOUNT DUE 03/01122 $1,071.74
YOU MAY INCUR A LATE CHARGE IF YOUR PAYMENT IS RECEIVED AFTER THE DUE DATE.
PURSUANT TO 12 U.S.C. SECTION 1701X, YOU AS A HOMEOWNER ARE ENTITLED TO HOMEOWNERSHIP COUNSELING
AVAILABLE THROUGH HUD-APPROVED NONPROFIT ORGANIZATIONS, TO OBTAIN A LIST OF SUCH ORGANIZATIONS
II~ YOUR AREA, CALL TOLL-FREE 1-800-569-42B7.
Plt1abu bl:f: ltltl 1eve1110 of this page !or an o•planaU011 cl Uus bilL D11lach 11nll ro!um lho bottom rcmll\anco ponlon 11,i\h ~our p.1ymonl. Pluase wri!o ,n black 01 bluo Ink.
AGSOUTH FARM CREDIT ACA PAYMENT NUMBER: AMOUNT DUE: $1,071.74
MADISON BRANCH OFFICE 6-052-11448561 Q.019 AODITIONAL
1691 LIONS CLUB RD PRINCIPAL: S, _ __
PO BOX 111 FUNDS
MADISON GA 30650-0111 HELD: S, _ __
LATE
BE#: 0000316124-0001 CHARGES: $. _ _ __
D Check here and see reverse for address correction.
IAmount Enclosed $ •
I,'' 1I•I• 11111 II1•11 1•111,' 11,1111 II I• I' 111 111 •I•'' 1111111, hI' 1I
, T6 P114669B-1-5-1 -1001
FARM CREDIT PROCESSING CENTER
,i RAISSA D KENGNE
PO BOX 650831
1280 W PEACHTREE ST NW #2109
DALLAS, TX 75265-0831
1/J ATLANTA GA 30309
3
605211448561 □□ 191 □□□□□□ 991743 □□□ 3 □□□ 900 □□□□□□□□□ 5 □□□□□□□□□□ 9 □□□□ 1 □ 71743
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 23 of 134
STATE OF GEORGIA
) Case No. 1 :22-CV-2297
) (Related Case No.
RAISSA DJUISSI KENGNE, ) I :22-CV-2297-SEG)
Applicant, ) (Related Case No.
) 1 :22-CV-2263)
V. ).
ID.ME, INC. )
COGENCY GLOBAL INC. )
250 BROWNS HILL CT, )
MIDLOTHIAN, VA,23114-9510, USA )
)
Respondent. )
EXHIBIT 5.
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 24 of 134 Page 1 012
Draft Date Dec 13, 2021
Customer Namo EX HI 8 IT 5
~ Georgia Power
Account Number
Total Due $ 96.50
RAISSA KENGNE 8:143/ !if1009
Service Addrns So, vioe Pe riod Contact Us
1280 W PEACHTREE ST NW Del 7/ 71171 Nov i'!). 707 1
APT2109 georg1apower.com
Billing Summary
,.l Accounl Number Web Accus Code
9343/ ~5009 232723
Previous B111 Amount $ !10 04 Cuslomer Se rvice Power Oulage Reporting
Payment Received On 11 / 10/21
_cu_ r
r_e_n_
1_El_ec_1_11_c_s_e,_v_1c_e_ _ _ _ _ _&...,..,,....
l hanl You 1
1t•.....,....•...,_<=-l, ' - - - - - - - -•:,
,,,,
!,B 04
I DGJdh
V 1-888 660-5890
7A-7P Mon-Fn
1-888·891 ·0938
24n
Espanol BA-SP
Total Due $ 96.50 Cha i 8A·6P
Balances unpaid 7 dai-s aftPr thP total dJP dJtt' d'P . ul>/1Yt t,111 latr
charge of 1 5". of the amo~nt dul' c,r S: OV 11'~•,hri·t" 1< g·ratp, Go Pttperlep!
\;loar rhe clutter of p1por by g0tn9 paptrlass R1c11v, •m••I
♦ The amount of this bill will be automatically deducted II om yUlll ban~ account 011 12 13-20? 1 not,licouon, when your b•ll II rudy to v11w onl•n1 11• lrul
S•gn up at georg,apowtr com/p1porlon
Please call the numbe1 on\ our bill at least a , eel p11or to this d.ite 1f you have nwde any
bank account changes 01 ha.e any questions about this bill
Payment Options
Onli ne/Mobi le App Pa1 u~rng a check, debit or credit card
at 9eorgIapower com or via the Georgia Power Mobile App
Add1110n•I Payment Opr,ans an bock
( ► USPS Changes to First Class ll.1atl Deliver\ r-.1ay Affect You 1
The United States Postal Service Is changing the way they deliver 111 st class mail For For cuffent billing details. tum page over
more information. • st about usps com A1-01d delays 111 receIv111g your bill wi th
Paperless B1lhng Enrol ng Is easy and convenient. please vIsIt
Usage Information
georgIapower com/paperless and start enJoying all the benefits.
Total Used Next Scheduled Raad Date
~
I~:
723 kWh On or after Dec 28 2021
► Free Doorbell Came1a Pro 101 Georgia Power Customers
We've partnered wrth \lrv1nt to offe1smar t home security to our customers For a /60 '
limited lllne. get a FREE Doorbell Camera Pro. free installation and $0 ac11va11on
when you sign up for professionally monitored home securi ty V1s11
geoIgIapower com/V1vint to learn more
.... I
raral kWh tlo, Doc J.. lrb M.• A1, ~bi .11n Jul Aug 'iep Otl Nu,
1020 11121
► Save on your home effrc,ency upgrades
1 Year l lSt This
Ou, onhne Marketplace has mstant rebates and exclusive savings on a wide array of Ago \1onth Month
energy saving products such as smart thermostats, LEO lighting, advanced power Total kWh Used 613 390 723
strips, smart home devices and more As the weather cools down. check ou t all the Average Daily kWh 19 IJ 22
products that can help improve your home's eff iciency savmg you energy and money, Days In B1lhng Penod 33 29 33
Shop onllne today at georgrapowermaiketplace com
PUASE ~HP THIS POIITION FOR YOUR Rl'COROS
PLEASE RITURN TH•S PORflON W TH 10UR PAYMENT, M.UING SURI' THE R£TUflN ADDRESS SHOWS IN THE ENVELOPE WINDOW
Account Number 93437 55009
Draft Date Dec 13, 2021
~IN 11010i
4.. Georgia Power lt 1 ll•lph McGIii Sllid
1111•••• LA 30J08-)37'
Total Due $ 96.50
O Yu, I want 10 Hvt a stamp on my naxt pJyn•em1 t 11 oMme 111 P•Pt<lhs 01lhng today
Please verily you, en111I add10» 0111he back ol th" ua111n1on1
□ 29343755 □□ 951 □□ oooo~bs □ oo □□□ o □□ o □□ o □□□□□□□□□□□□ ooooo
MailTo:
RAISSA KENGNE 96ANNEX
APT 2109 ATLANTA GA
t 280 W PEACHTREE ST NW 30396-000 t
ATLANTA GA 30309
A00033739 20
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 25 of 134
Page 2 ofZ
Draft Date Dec 13, 2021
Customer Nnme Account Numbor
Total Due $ 96.50
~ Georgia Power HAISSA KENGNt
Payment Options (cont.)
Current Electric Service - Residenti11I Auto Pay Auto Pay by authorwng your hill amount to be
Next Sche duled Read Date On or after Dor 28, 2021 automaucally debited from your checking or savings account
Mo1o, Rood1ng
Sorvico Poriod Motor • Rud1ng Typo Cun 1n1 t>,e viou, Constt1n1 - U1og o Mail Georgia Power Pa•1ment:;
Oci 27 · Nol 29 7328442 l oHWh 789~, ~ ·.1,1 //.t % llnnex Atla11ta GA 30396-000 I
Phone Pav by phone directly to Georgia Power w,th vour
Billing Period
checking or savmys account by calling 1-888-660-5890 Pay by
Oct 27. 2021 Nov 29 2021 phone with your credit or debit card via 81IIMatnx by call111g
I 800 612 2402
Current Service $ 72 23
Environmental Comoha,ce Cos: 10 62 In Porson Use your account number to pay at thousands of
Authorize d Payment Locations IAPLsl Locations include
'lluclear Consiruc: ,01 Cost Recove'i 3 13
most retail and grocery stoll!s that have night and weekend
Mun,c1pal Franch se Fee 2 63 hours
Sales Tax 7 89 To pay your bill at partIcIpaong CheckOut locat1ons. use the
barcode found on your bill ~tub
Total Currant Electric Service S 96.50
All APLs accept cash and some accept debit cards. however
these locattons do not accept checks or credit cards V1s1t
georgIapower com/a pl for more information
Text GPPAY to 99123 to find the closest Payment Locatton IAPL1
near you
V1s1t georgIapower com/pa•1mentopttons for a complete menu or
available options
Consumer Check Conversion - When you pay your bill by
check. you authonze us to make d one-time electronic debit
from your bankmg account
Do we have your correct primary phone number and email?
Wl1y? When you ca ll tu ruport a power outage, our autuma tetl syste111 s 11l enbfy your uddruss
t,y your phone numb~• Wo may occ as1011ally w an t to contac t you via oma1I w uh unportant
information.
If your phon, number 11r 11m1il addr•n hes ch■ uged, plnu update our record s in the boll
below ind mark Utu bu• pn the trout ot tile stub ii you have enllred a correcl ion.
..
r--
M
(0
0 Primary Phone Numbo1 on tile: 404-1131-i516 11 12'0 W PEACHTREE ST NW
Ii0
a,
in
:g Email Address on l1lw rk1ngnelctgm1ll.oom
M
a,
a,
r--
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 26 of 134 PaQe \ 012
Draft Date Jan 13, 2022
Customer Name Account Number
Total Due $ 96.07
A Georgia Power RAISSA KENGNE 934]7 5!i009
Service Address Service Period Contact Us
1280 W PEACHTREE ST NW Nov 7!1. 7071 IJec 79, 7021
APT 2109
Billing Summary
.:•?, georg1 apower.com
Account Number
93437-55009
Web Access Code
232723
Previous Bill Amount $ 96 50 Customer Service Power Ou\lge Reporting
Payment Received On 12/14/21 l hank YouI 96 50 1-888-660-5890 1·888-891·0938
Current Electr ic Service +96 0/ 7A-7P Mon-Fri 24n
Espanol 8A-6P
Total Due $ 96.07 Cha t BA·6P
Balances unpaid i days after the totar due date dte sub1ect to a l,Jtp
charge of 1 5"'o of the amourit due or SZ DO whrchri-rr 1s grrate, Go Paperless!
Cle ar tho clutter of papor bv going paporlsss Rac&ive email
not1f1cat1ons whon vour b1ll 1s raadv 10 view onhn• Ir's fr ao I
♦ The amount of this bill will be automatically deducted from youi bank account on 01-13-2022 S,on up ar georg,apower com/paporloss
Please call the number on your bill at least a week prio, to this date II you have made any
bank account changes 01 have any questions about this bill
Payment Opti ons
Online/Mobile App Pay using a check, debit or credit card
at georg1apower com or via the Georgia Power Mobile App.
Add111011a/ Paymenr Opnon, on back
For current billing details. t■m page over
( ► Give the gift of security this season )
Sign up for V1vmt, our preferred home security partner, and receive a FREEDoorbell Usage Information
Camera Pro, flee installation and $0 ac11va11on Enroll today at Total Used Nexl Scheduled Raad Date
georgIapower com/V1vmt 736 kWh On or alter Jan 27, 2022
► Give back to your ne1ghbo1hood
A small donation can make a big difference In your community Th1ough Project
SHARE, Georgia Powe, will match $1.50 101 every $1 you give to help people In your
area facmg a temporary crisis Donate today through your electrtc bill 01vIsIt
~,- ~
Totalk~~h :i 1,b
Jan
I:: I
Ma, \p, May.Jun ~ I lsg S~ Ocl ,1ov 08c
georgIapowe1 .com/pi ojec tshare to learn more Xl1 1
I Year l ast This
► Flat81II means no surprises Ago \Aonth Month
When you sign up 101 our FlatBill rate plan, you sign up loi stab1l1 ty For 12 months, Total kWn Used 910 723 736
you'll know exactly what your energy bill will be, without any changes based on the Average 0d1ly kWh 30 22 25
season Not a bad idea, 1f we say so ourselves Learn mo,e and ernoll today at Days In 8111mg Period 30 33 30
georg1apower com/ flatb1II
PlEASE KEEP TfilS PORn ON FOR YOUR RECORDS
PLEA6f RETURN THIS PORTION WlfH YOUR PAYMENT, MAKINOSURE THE RflURN ADDRESS SHOWS IN lHE EN VELOPE WINDOW
Accou nt Number 9J437 550U9
Draft Date Jan 13, 2022
BIN 11010'/
~ Georgia Power 141 Helph McG~l 81vll Total Due $ 96.07
A1la111a, GA 30'.l00-~~/4
0 Y"', I want to••••• UJmp 011 mv noxt pav111u11t1 Enroll ine ,n ~aporlus billing roday
Pleue vur,ly vuu, u111J1i ,Hldr•» 011 rho bJca of rnis ,tdtemonr
029343 7 5500951000000960700000000 0 0000 0 0000000 □ □ □ □ □□□□
Meil To: 11ShXHE $ 1 0 sz □ $5 □ s100
96 ANNEX
RAISSA KENGNE ATLAN IAGA
APT 2109
303!/b (XX) I
1280 WPEACHTREE ST NW
ATLANTA GA 30309
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 27 of 134
, ... Page 2 ofZ
Draft Date Jan 13, 2022
Cusromor Namo Account Nurnbor Total Due $ 96.07
~ Georgia Power RAISSA KENGNF fl3437 b!:i009
Payment Options (cont.I
Current Electric SeNice - Residential Auto Pay Auro-Pay by authorwng your bill amount to be
Next Scheduled Rearl Date Dn or alter Jan 27, 2022 automaucally debited from your checking or savings account
Mo111r R..Ihno
Sorvn:• Ponod Moi.r • RHd1ng Type Curro nl Pravrous Co1101nn1 • Usngo Mail Georgia Power Payments
Nol' 29 Dec 29 7328442 Tot kWh 79689 78953 736 96 Annex Atlanta GA 30396·0001
Billing Period Phone Pay by phone directly to Georgia Power with your
checking or savings account by calling l-888-660-5890 Pay by
Nov 29 2021 - Dec 29. 2021
phone with your credit or debit card Via 61IIMatr1x by calling
Cur·ent Se-v,ce 1-800-672-2402
$ 72 OD
E.nv1ronmental Corrp11ance Cost 10 51 In Person Use your account number to pay at thousands of
Nuc,ear Consirucvon Cost Recovery 3 10 Authorized Payment Locations fAPLsl Locations include
most retail and grocery stores that have night and weekend
Mun1c1pa Franchise ~ee 2 62 hours.
Sa es Tax 7 84 To pay your bill at parucIpanng CheckOut locat1ons. use the
Total Current Electric Service S 96.07 bartode found on your bill stub
All APLs accept cash and some accept debit cards, however
these locations do not accept checks or credit cards V1s1t
georgIapower com/apl for more information.
Text GPPAY to 99123 to find the closest Payment Location IAPLJ
near you
V1s1t georg1apowercom/paymemopt1ons for a complete menu of
available options
Consumor Chock Convorslon When you PdY your bill by
check, you duthonie us 10 make a one-ume electron1t debit
lrom your nank,ng account
Do we have your correct primary phone number an d email?
Why? When you c~ll tu re port a power outage our automdled ,ys1e111s 1dur1uly your Jddres,
by your phone rIu111hur We may oc cas1onally want to co111act you v,u 0ind1I with 11nporta11t
111torma1ion
II your phona numbvr or om1il address has ohanged. please up data our records in the box
below and mark the ~011 011 lhB tronl ol the stub ii you havo entered a correotion.
Primary Phono Nu111~ur un hie: 404-932-657ti al 1280 W PEACHTREE ST NW
Email Addr&n on hie. rk1ngn11 0gm1ll.com
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 28 of 134 Page l of ?
Draft Date Feb 11 , 2022
Customor Nnmo Account Numbor
Total Due $ 206.67
~ Georgia Power RAISSA nNLiNf !)343/ \1!.,009
Service Address Sorvico Poriod Contact Us
,nn
1280 W PEACHTREE ST NW
APT 2109
Payments Since Last Billing
llec ,!.l. 71121 J,111 ,II,
o~ georgi apower.com
Account Number
93437-55009
Web Access Coda
232723
Customer Service Power Oulaga Reporting
Payment Rece'1ved On 01 / 13/22 lhank YouI !.l(i0/
Billing Summary
V 1-888-660-5890
7A-7P Mon-Frt
1-888-891-0936
24n
Espanol 8A-6P
Past Due Electr 1c Ser~1ce $ !.l6 0/ Chat BA-BP
Current Electr 1c Service ~/0.60
Go Paperless!
Late Payment Charge - Elect11c +2.00 Clear lh& cluner of paper by going paperlen Rece ive email
Returned Item Charge +30.00 no11hcanons when your bill is ready to view onl1ne It's frn 1
Sign u p ar georg1apower com/paperless
Bala·ces urpard 7 da1 s afte• tfie to:al due datf' ,ire subJect to a fare
charge of 1 Slit, of the arnoi1~r i!;;I' o• SZ VD. whrchrvr r 1s greater
Payment Options
♦ Thi s btll includes a previous balance If this amount has been paid, please accept our thanks Onli ne/Mobile App Pay using a check, debit or credit card
and pay only the curr ent char ge at georg1apower com or via the Georgia Power Mobile App
Billing summery continues on neKt pego
Additional Paymenr Opnons on back
( ► FlatB1II means no surpnses 1 For cunent billing details, tum page over
When you srgn up for our FlatB1II rate plan. you sign up for stabthty. For 12 months.
you'll know exactly what your energy bill will be, without any changes based on the Usage Information
season. Not a bad idea, 1! we say so ourselves Learn more and email today at Total Used Next Scheduled Raad Date
georg1apower com/flatb1II 538 kWh On or after Feb ZS, 2022
► Save money, and enet gy this winter
Small changes around the house now can keep you comfortable while delivering
energy savrngs thrs winter We offer sever al tips to help you save at
georg1apower com/tips Also don't forget to check out georgiapowermar ketplace.com ,. JJn hb Mai Apt M,v Joo .Iii Auy S..11 Del !lo, Doc J;,i)
ToraI kw" 201 I 1rm
for addrt,onal products that can help you save time and energy rn almost every room
r Year l ast This
► New Year. new improvements Ago Month Month
Enjoy energy eff1c1ency improvements that can help you save energy and reduce your Total kWh Used 877 736 538
bill If you are an income-qualified Georgia Power customer, you may be eligible for Average Dally kWh 29 25 18
fr ee home energy efl 1c1ency improvements through our Horne Energy Effrciency Days In B1lhng Period 30 30 30
Assistance Program Learn more at georgrapower com/ heeap
PLEASEKEE P THIS PORTI ON FOR YOUR RttOROS
PLEASERETURN THli PORTION WITH YOUR PAYMENT, MA(INO SURE TIIE RETURN ADDRESS SltOWS IN TIIE[NVHOPE WIN DOW
Account Number 93437 55009
Draft Date Feb 11, 2022
~IN11010'/
~ Georgia Power 141 RJlph MtG1II Ylvd Total Due $ 206 67
Allatdd. loll J030tl.:J:l/4
O Yes, I wanr to sav, a 11amp on my nu•r paymunr 1 enroll ma ,n paperless b1i11ng roday
Please ve11fy your 0n1&1t atJtJ•••• on rho back of 1h1s staten,ont
□ 29343755 □□ 951 □□□□□ 2 □ bb7 □□□□□□ 9b □ 7 □□□□□□□□□□□□ ooooooo
Meil To:
96 ANN[ X
RAISSA KENGNE
APT 2109 ATLANlA GA
1260 W PEACHTREE ST NW 30396 0001
ATLANTA GA 30309 Total Due Summary
Elec Service 78.60
Prev Service 96.07
Rtn Item Chg 30.00
~~P~C_h_ _ _ _ ~00
Total Due $ 206.67
R00032984 20
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 29 of 134
Page z ofZ
Draft Date Fe b 11 , 2022
cu, tomor Nftme Account Numbor Total Due $ 206.67
~ Georgia Power RAISSA KENGNI- !J3437 '.l11JOD
♦ The amount of this bill will be automatically deducted Ii 0111 yow ba11k account on 07 11 7072 Payment Options (cont.)
Please call the numbe1 on your bill at least a week µ1101 to this dc1te it you have marle any Auto Pay Auto Pay by authorwng your btll amount to be
bank account changes 01 have any questions about this bill au1om~tIcally debited from your checking or saving, account
♦ This bill 1e1lects a previously billed balance that was not deducted fl om yow bank account Mall Georgia Power Payments
96 Annex Atlanta GA 30396 0001
We have included both your previous bill and current amount on this bill
Phono Pay by phone directly to Georgia Power with your
checking or ~avings account by calling 1 888·660-5890 Pay by
Current Electric Service - Residential phone with your credit or debit card via 81IIMatnx by calling
Nut Scheduled Read Date. On or after Feb 25, 2022 1-800-672·2402
Moi.r Rooding In Person Use your account number to pay at thousands of
S1rv1ce Ponod Moror , Reading Typo Current Previous • Constonl = Usoge
Authorized Payment Locations (APLsl Locations include
Dec 29 · Jan 28 7328U2 Tot ~Wh 80227 79689 1 538
most retail and grocery stores that have night and weekend
Billi ng Period hours
Dec 29. 2021 • Jan 28. 2022 To pay your bill at par1IcIpaung CheckOut locauon,, use the
barcode found on your bill stub
- Current Service $ 60 03
Env,rcn11e1ta Corrpl1 ance Cost 8 26 All APLs accept cash and some accept debit cards, howe\'er
Nuc,ear ConS1ruct1on Cost Reco..,ery these loca11ons do not accept checks or credit cards V1s1t
1 75
georgIapower com/a pl for more information.
Mun1c1pal Franchise Fee 2 14
Sales Tax Text GPPAY to 99123 to find the closest Payment Location (APLI
6 42
near you
Total Current Electric Service S 78.60 Visit georgIapower com/ paymentop11ons for a complete menu of
avaliable options
Consumer Ch eck Conversion When you pay your bill by
check, you authoJ1ze us to make done-time elecuon,c debit
hom your bJn\,ng acount
Do we have your correct primary phone number end email?
Why? When you call to roport u powur ou tage, our automatod systems 1denllly your address
by your pho11e numlier Wo may occas1011ally want to contact you via orna1I with 1111 por ta11t
1nformat1on.
II your phone number or email address hu changed. pleeso update our records in the boll
balow and 1nark U1a box on the lron1 of the stub ii you have onturud a c orrection.
Primary Phono Number on fllo 404-932-6576 ■11280 W PEACHTREE ST NW
Email Addross 011 hie. 1keng11110 9m1il.c11111
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 30 of 134 PJge I olZ
Please Pav By Mar 14, 2022
Custome, N11mo Account Number
Total Due $ 320.32
,~ Georgia Power nAlSSt\ ~l Ni,Nl 'l.M l/ 'i',fl(lf]
Service Ad drus Service Period Contact Us
1280 W f'tACHlRH ~l NW
APl 2109
01 1ron1111r.t Nnttr.u
,l,111 /ll, / (li't I uh /II. /On
,.1 georg1apower.com
Account Number
93437-55009
Web Access Code
232723
lo dl'O ,I \ OU e Clli'l l CIVltO ho,n~ d1:;tolllll!dOd lur rMJfl payment. this Customer Service Power Outage Reporting
I' sen: .e Id sco~,e, le;i \'O, "1<'!1 NI a oot.ta11 10 t'tlll, anti may ho l11llcd a ,ow1111uc1charge an<I rcquuell
1l 1·888-660-5890
7A-7P Mon -Fri
1·888·891-0938
24n
to t1a1 d jeoo; I J Jjd t•,na .leN. i t,efo'C ,ef\ Ct?,. IC,hnil If \'OU la,I lo PJVyour clcctrrc SCIVICC 1!111 each Espanol BA-SP
n>M'.'l ti\ l'le ,he ~ate \'O, "'31 tie ·eqJ ·cd to PJV a dcpo.it or a1ld111unJI 1lepo, 11 CVCII thou~h ,OIVICO ,. 1101 Chat BA-SP
d.s,J11e.ted , oa ma1 co11an ,, at 1 S:' ~O.l 7149 lo. 111fo,ma11011011 Jyc11cics that may be at,lc lo a:;:;I:;1 you
'" oa1· ,~ 1·; ,. :ia1: j . e ti. J a;1,m'ltc a1J •able ,t rou have J 1enou1 1llncs, In you, household that could be Go Paperless!
a~~-a\a~i?d t'i\ :~e j s,o,1i?\.t ~, \)• '"'wr c'ctt 11. S~!\ cc Clear the clutter of paper by going paperless Receive email
not1ficat1ons when your b1ll 1s ready 10 view onhne It's fre&I
E111a H ••• notitn,ac10• do duconu 1on da urv,oio Paro mas inlormooion, llilmono• ol 1-B00-253-1077. Sign up at gtorg1apower com/paperless
Payment Options
Payments Since Last Billing Online/Mobile App Pay using a check, debit or credit card
at georgrapower com or v,a the Geo1g1a Power Mobile App
Payment Rece1;,ed On 02/11 ,'22 Thank You! -206.67
Addirion•I Psym9nr Opnoni on back
Billing Summary For current billing details. tum page over
Pas1 Due ElectJ Ic Service $ 174.67
Pasl Due Returned Item Charge $ 30.00 Usage Information
Pasl Due Late Payment Charge • Electric $ 2.00 Total Used Next Scheduled Read Date
Current Electric Ser~1ce 545 kWh On or dlter Mar 29, 2022
+61.03
900 r-,::--------,,--- - -- - - -
Rewrned l1em Cha, ge +30.00 no Ill 11 ..,
Late Payment Chai ge • Elecu Ic +2 62 540 - "' ---',--- - ------'~"--~~
360 1-,--,---~.-:~=---.,....:J;....,.....;:.-.~~--
Balances unpaid 7 days after the total due dare are subJect to a late 180 t-,..,--,--- ~--;.....,..----'-'.---~--
0 . I ~ I
charge of1 5% of the amount due or $2.00, whichevens greater.
Total kWh ~:, ~b, A('> May Jun ..1,1 Auy Sep OCI Ntw Doc Joo ~
1 Year l ast This
Ago Month Month
Total kWh Used 869 538 545
Average oa,ly kWh 31 18 18
Days In 81lhng Penod 28 30 31
P1.EA6E KEEP THIS POROON fDR YOUR Rf CORDS
Pl£ASE RHURN llil6 PORTION WITH YOUR PAYM[NT, MAKINGSURE !HERCTURN ADDRESS SHOWS IN 111( (NVILOPE WI NOOW
Account Number 93437-55009 NC
Disconnect
Notice Please Pay By Mar 14, 2022
ijlN /1U1U2
4.. Georgia Power /\11.,~•. ~/\ '.l03UIJ.3J/4
241 Halph Mlulll ~Iv~ Total Due $320.32
0 Yu, Iwant to save a stamp on mynext payment• Enroll me ,n paporltss b1 ling today
Pleau vo11fy your oma,I address on tho back ot this statement
02934 3 7550095100000320 32000 0020 6670 000000 0 000 00000001
Ma ll To:
96 ANNEX
RAISSA KENGNE
ATLANTA GA Total Due Summary
APT 2109
30396.CXXJ t
1280 W PEACHTREE ST NW Elec Service 81.03
ATLANTA GA 30309 Prev Service 174 67
Rtn Item Chg 3000
Prev Rtn Item Chg 3000
Late Pymt Chg 262
Prev Late Pymt Chg 200
R00066777 20
Total Due s 321).32
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 31 of 134
o:vo312022
UN I 1 2 l()l)
RA ISSA DJU ISS I ~ I Nt: NrN W
128 ()W PL AC HlR I l ~l
ATLAN TA GA ,l()J 09
Account Number ### ##ft 186
Dear RAl ~SA D.IU ISS I I\[ NG N[.
mu nity Cre dit Union Checkin g
date of tt11 s lett , , your Delta Com
f the ,
Acc-ord1n9 to our rec-o rd • , as o a nc>g atrv e stot us
rn
and/or si rngs Acc -oun t rc>m arns
n you r a_ c cou nt bal anc e
our ace unt pos ItIve w1th1n 55 calendar days of whe
It ,s ur"Qent that ou bnn p
If you have alre ady take n car
e of the neg ativ e bal anc e,
ativ e to a o~d acc oun t clos ure
beca~e neg
please disregard th s letter
oth er collection opt io_ns
brou ght to a pos ItIve stat us, we will consider any and all
If your accoun t ,s not rep orts neg ativ e
oun t serv ices may also be sus pen ded . Delta Com mu nity also
ava ilable and ,our acc tion ser vice and con sum er
loss es to Ear ly Wa rnin g Ser vice s, a che ck verifica
account clos ure s and yea rs, whi ch ma y affe ct
Onc e repo rted , the inci den t will remain on you r record for five is
reporting agency you r acc oun t be cha rge d off, this
r abih ty to ope n acc oun ts with othe r financial institutions. Should , a deb t
you Dre w, Eckl & Far nha m LLP
you r account to the Law Firm of
to notify you that we may transfer following em a il add res s for you
:
ecto r and we ma} pro vide Dre w, Eckl & Farnham LLP with the mu nica te w ith
coll ail add res s to com
l & Farnham LLP may use this em
rkengne 1@gmail.com Drew, Eck then it is pos sibl e the y ma y see
the
e access to this ema il add res s,
you about the debt. If others hav l & Far nha m LLP to the abo ve
wou ld hke to opt out of ema il communications by Dre w, Eck
ema ils If you w the instruction s pro vide d by
ed ema il, plea se go to http s-//s ettle.defrecovery,com /optout and follo
stat
04/0 8/20 22 .
ase
me nts to fun d you r acc ount, ple
in you r neg ativ e bala nce am ount and make pay me nt arra nge 0 p.m . Er at 404 -67 7-
To obta a.m . and 5:0
y th:ough Friday, between 8:0 0
contact our servIcIng group Monda Cre dit Union, P.O . Box 20541 , Atla nta
, GA
may also sen d
_ fund ~ by m_ a1I to Del ta Community fun ds from a
8650. You . We also acc ept
Onh~e Banking or our Mobile App
3~320-2541 , or electro~1ca lly_vI~ a fee ass ess ed for this pay me nt typ e.
er® , Mas terC ard or Visa deb it card . There is
Discov
reg ard ing you r acc oun t
r pro mp t atte ntio n to this ma tter. If you hav e any que stio ns '
We appreciate you
plea se call us.
Sincerely,
Delta Community Credit Union
DeltaCo mm unityCU.com
0-2541
P.O. Box 2054 1 I Allan la I GA 3032
800- 544-3328
Tel 404-715-4725 I Toll Free
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 32 of 134
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ew •l•nce 1IS 61 Av~1l1ht1 •nri l'•nrllno •• of Ol / l 1/21
1, .. 7 30 6,283
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tc- 0111 <"fll ..c-, ~ ,,.. ,.. "-'-"'"" I:.(,• •"•mrl•
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C 11dlt Limit
$1 ,.537.30
S 13,100.00
__J
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-~ And y.,v will pay an
l
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:,,0-.l')e)
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Mtn •mun Pevt'l4'n: Du. $42, 186
-- '-----____...J
If )10... WO..ttO lt q rnformatio., abovt c"f'd,t couns•lr ng servtces call l-888-733-4139.
~ pa{1lt 2 fOf tmpo,tant 1nformatt0t1 abo.Jt your account.
Your account ts put due.
~ Please rt'fet to the IMPORTANT NOTICES section on
pesii• s.
Concinued on page 3
l!!!I Payment Coupon r:I Pey by Computer 9'!! Pay by Phone Account Ending 0·21 009
~ Do not staple or use paper clips liil amerlcane><press.com/pbc 1,11 l-000-472-9297
Enter 1Sdigit account # on all payments.
MO 0104807588092 B 186 A llt'~ Make check payable to American E><press.
l•l1ll11l 111 1111 1 11 1ll1 llllll111l1•l'1 ll1 1lll 111 l1l111 l1111 1l1 1l1
RAISSA D KENGNE Payment Due Date
1280 W PEACKTR ST NW 03/28/22
UNIT 2109
ATLANTA GA 30309-3445 New Balance
$15,613.99
AutoPay Amount
$6S0.00
.J
11I" t II"• 11 •11 11 IIII11 11III1 11111 1III 111II• 1111 1111 •II II 11II• II
$ _____ _ _ _
See reverse side for Instructions AMERICAN EXPRESS
on how to update your address, P.O. BOX 1270 Amount Enclos.d
phone number, or email. NEWARK NJ 07101 -1270
0000349992216712024 001561399000153730 02 n
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 33 of 134
Aetna CVS Health'M
PO Box 981131
El Paso. TX 79998-1131 ~aetnaCVSHealth .
1111 , 111111 1IIIII111 I111I 11111 11 11 •h11 11•11• 11• I111 •11 11••111
11
1 01/18/2022
RAISSA KENGNE 531576
1280 W PEACHTREE ST NW APT 2109 ~.·•~- Internal Purposes: RM04
ATLANTA GA 30309-34 36
Time is almost out. We need t o receive your first month's premium payment by January 31 or your plan application will be cancelled,
and you will not receive health coverage.
Payment can be made trhough one of the beleow options:
Pay online: https:/ /aetnacvshealth.com/payment
Pay by phone: 1-844- 365-7373
Pay by check: you will receive a reminder invoice and coupon in the mail. Include this coupon with your check and send to the
address provided. Note: Allow time for mail delivery.
If you have already made your payment, please disregard this message.
We're here to help
If you have any questions, call us at 1-844-365-7373 (TTY: 711). We're here Monday through Friday, 8 AM-6 PM local time.
~
Health plans are offered or undanvritten or administered by Coventry Health Plan of Florid.a. Inc., Aetna Health Inc. (G.orgla), Aetna Ufa
ln5W'MC& Company, Aetna Health of Utah Inc., Aetna Health Inc. (Pennsylvania), or Aetna Health Inc. (Texas) (Aa1na). Aetna ,s p..rt ot the CVS
Health family of companies.
@ 2022 Aetna Inc.
34.32.349.1 (11/21)
GA Page, or ·
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 34 of 134
AC'111R C'\'S HC'olth,u
1'0 Bo, 981131
El l'nso. 1 \ 79998 1131
01/15/2022
lll1·•1'••lrl'l1l'l1l•11llll••1l'llll•1lll1l 1l1ll1l1ll 1 l111l 11 11' 520664
RAISSA t\ENGNE Internal Purposes: RM04
1280 \I\/ PEACHTREE ST NW APl 2109 f:~
ATLANTA GA 30~09-3436 ~
Your Monthly Premium Invoice
Your premium payment ,s due by 01 / 31/2022. If you've already sent us your full premium payment, please disregard this notice. If you
don't pay your premium. this will affect your coverage as of 02/01/ 2022. Your payment details are the following:
ACCOUNT SUMMARY
Previous Balance: $ 715.82
$ (0.00) Due Date: 0 1/31/2022
Payments: Aetna CVS Bronze: Low-Cost Walk-in Clinic
$ ( 715.82) Plan Name:
Past Due / (Credit Balance): Visits, Telehealth , Atlanta
$ . Member ID: HIM0011231
Current Premiums: 357 91
$ _ . Exchange ID: 0005067974
Adjustments: 357 91
22015000062
APTC: $ (357.91) :~:~:~:: Date: 01/15/2022
TOTAL AMOUNT DUE: _$$___3_5_7_·9-1 Bill Period: 02/ 01/ 2022 - 02/ 28/ 2022
Balance Forward: 357.91
Notes: More information on page 2.
Payment Options
Make a payment by calling 1- 844-365-7373
Pay by check. Detach and return the portion below with your payment to the address noted below. Please make checks payable
to Aetna CVS Health™
Pay online using a credit/debit card or a bank withdrawal by logging into https://aetnacvshealth.com/payment
-----Cut Here-----Do Not Staple-----Cut Here-----Do Nol Staplo-·--·Cut Hore-----Do Not Staple··---Cut Here-----Oo Not Staple-·--·Cut Here--·-· Do Not Staple---Cut
RETURN THIS WITH PAYMENT
Raissa Kengne
1280 WEST PEACHTREE ST NW UNIT 2109
Total Amount Due: $357.91 ATLANTA, GA 30309
Exchange ID: 0005067974
System ID: 285105
Payment Due By: 01/31/2022
Invoice: 22015000062
Invoice Date: 01/15/2022 SEND PAYMENT TO:
Bill Period: 02/01/2022 - 02/28/2022
Enrollment Type: 1111 ·I• 111 11 1•· 1·•I 11 1••1••1•1•1111 •ii 11 II I11 1 II 111 III" II' 1III II
AETNA/CVS HEALTH
PO BOX 842920
DALLAS TX 75284-2920
ODDDDDDDD285105 □ 000035791I3
GA COCO_164129 20220115_1Pg DX 81 0001 PDF Page 1 ot :Z
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 35 of 134
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Plea mal.t a paymtnt to ~placr thl' rl'turnl'd 111110 11111 below, us soon as poulble. See below for easy,
~ "-.~ to pa~·.
Thcst att the detail oftbe ~rumed payment:
Re-turn Amount: $650.00
Return Dare: 0) /2512022
R.etum Reason : insufficient Funds
If your ~unt is enrolled in our automatic scheduled payment arrangement, we encourage you to check this
ami.ngcmcnt as it may have been canceled or suspended. Please visit us online at amerlcanexpress.com/
Autopay to review and confinn your status.
Ways to Pay:
To make a payment by phone, call us at 1-800-1-PAY-AXP ( 1-800-472-9297). To make a payment on-line, visit
us at americanexpress.com/pbc.
Sin.cerely,
American Express Account Services
FLOEUFL00191001 Paae l of l
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 36 of 134
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A payment was returned unpaid
Please ma ea replacement payment right away
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H, Ra,ssa A recent payment of $651 .02 on your Citi Simplicity® Mastercard® account
was returnee unpaid by BANK OF AMERICA NA.
What happened and what's next?
BANK OF AMERICA NA indicated the account doesn't have the funds needed to cover
the payment. Before making a replacement payment, make sure this account has the
necessary funds to cover it - a different payment account can also be used. You can
quickly and easily manage your payment accounts and make a replacement payment in
the Citi Mobile® App or Citi® Online. The payment will be credited same-day .
Please contact BANK OF AMERICA NA directly for any further questions or clarifications
about this returned payment.
Your Citi Team
®2022 Citibank, N.A. Citi, Citibank, Citi with Arc Design , Citi Mobile and Citi Simplicity are
registered service marks of Citigroup Inc.
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0.L02 400 35001 . I 20220 2 19002 4 379 1 202 I ZZ .SY .8000 SYS T EMB018845657l492765 NY
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 37 of 134
Roadside assistance bill
"'"'•'"' ~.-,.i.
:'""\ \a,,""'iltf\oJ \u,t,f,.._
~,.,~l( t,('~"'·
In formation as of February 14, 2022
1•11111 i.,1•1111I', 11, 111111 •1•I• 1I•1 111111111•1hI•111 11I11 I
1 11 1 Primary Member
Ralua Kengne
Page 1 of 2
RAI. A KLNGNE
1280 W PTRlE T NE APT 2109 Membershl Number
A TL ANT A A 3 3 9 3436 367943593
Membership period
September 18, 2021 through
September 18, 2022
Visit www.allstatemotorclub.com for more
Information about your exclusive
Amount Due $ 52.68 members hip be nefits .
Due by January 17, 2022
Benefits at a Glance:
Your credit card was declined Fast 24/7 Roadside Assistance
Get roadside service for towing,
Thank you for your membership in Allstate Roadside. We wanted to inform you that fuel delivery, tire changes, jump
the credit card we have on hie ca rd ending in 9430 was declined. Please use the form starts, lockouts and more.
below or call us to update your credit card and pay your balance. You ca n also send a Easy Digital Access
check or money order. Select a service, request a rescue
• and track your service provider's
arrival time - all from your phone.
Pay today and avoid interruption to your 24/ 7 Roadside Assistan ce, travel benefits
and exclusive member discounts. We appreciate your loyalty t o Allstate Roadside Discounts & Savi11g5
and look forward to serving you on the roa d ahead! 0 Save up to 50% on restaurants,
retailers, entertainment and more.
Plus, get deals on travel expenses,
Ways to Pay from hotel stays to car rentals.
1. Credit Card
Complete the payment form below and return by mail or
call 1-800-347-8880.
2. Check or Money Order
Detach the payment form below and return by mail.
(Please disregard this notice if you 've already submitted payment.)
Detach bottom portion here
Return this portion with your payment
~Allstate.
Amount Due $ 52.68 Primary Member
Raissa Ke ngne
Due by January 17, 2022
Membership Number
Fill out the Information below to pay by credit card. Or, make check or money order payable
to Allstate Motor Club.
I367943593 l
I J Visa Ll MasterCard I J American Express f J Discover Indicate name or address
changes on the reverse side.
~ ll II JI j\ I ll
Card
f_ JI lf JI JI JI JI JI ll expires I
When paying by uedlt cord, I pe,mlt Allstote Motor Club lo aulomalicolly char{I<! ul/ future dues. al U1e lhet1 cu,re,11 rat,. lo tl,e
account indicated, unlll my mtmbetshtp Is cancded III wrltmo by me or by All,tate Motor Club wl11ch wlll se11d me notice of futu,e
dues, All benefits subject to the term, ortd cond11ions ,n Ille Membenhip Gu,de.
Your Signature _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Date _ _ _ _ __
~i1
36794359302144000526800 005268000052660
RTF_MDClAMC
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 38 of 134
J221l lM.1/JSI I of I
Nati0nal Gl!ln!'trAI AocldMI 1111d Hl"Allh
PC' 1:1(1 ,:w~
~
- \\1NSh') SAU:M NC 2"116
Forwarding Service Requested
(,f"'llf'f,11 ))
I11h I11tih 11 111 •I1'•11'• I' 1•I 1111111111 1111 I• II 1111•11 1I1••I11
1
For Questions please
••••••••••• ••••t••• Al l FO R AADC 10) Call 606-J67-0484 or Fax 644-279-1983
PB-STL _U NS~~ T[ D-M A(H-L NV a9 J a 22
R<\IS \ <\ l) 1-.l N~, "
I "-11 :HW
I :Sil\\ r1 \\ ·1 nRl I '1 , \\
<\Tl \ , 1 \ ,; \ :,1:,N.;~ lt,
Date : 02/1 4 /2022
Dear Policyhold er:
Your :nsJrance coverage under this policy is terminated as of January 12 , 2022 for
~on-pay::ien t of premium due and the policy no longer provides any insuranc e protection .
Sincerely ,
Customer Service Department
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 39 of 134
hN I <1111n h \I Pll R11~ Jf\l) 1 • fi,11.,,h11111 Imv!ll1 1, ~ ( J'l()/0
~11 l \ lJ Ill 11 , Hllll J Ill / Iii/ · HOI '1 Ii IIJOJ (f,1x)
,\q ,,11th! I I 1/111
R,-,i.or.11 (' pnan
1:-~0 \'\ Pi"III, "'trt"'f" Str el W #2109
Atl~nta l,/\ ~('l .~11 g
ERl IF ll [) \'\'I ti Rl l UR RU E IPT RCQUL S T DANO R G ULAR MAIL
#- ~- ~~1600000~01g: B~◄
" E lo.I" tr. ('11U8~ 610
A a res..ilt of \'our ta,lur? to pa · the :.um duo ond owing as called for In the
Note, AgSouth has
~ tl"-0 toe e rc1st- the remedies available to 11 under the Note and related
loan documents
1collect1vel} · Loa n Document ·) and accelera te the full amount of the debt.
Accorot"'lg not,ce 1s hereb given you that the terms of said Note wherein you agree
to pay
reasonable attorney s tees m the event of a default shall be enforced by legal proceed
ings
u"'lless the ful amount of the unpaid principal , accumulated interest, advances, etc.,
in the sum
of $ 36 164 33 together with interest accruing thereon, are fully paid within ten (10)
days from
receipt of this notice as provided in Section 13-1-11 of the Official Code of Georgia
, Annotated.
If you pay the full amount set forth above within ten (10) days, you may consider
your
obllgat1ons under the Loan Documents satisfied . Should you fail to do so , AgSouth
will exercise
the remedies available to it under the Loan Documents and applicable law including
legal action
against you
As a further result of your loan being in default, your "C" Participation Certificates
in the
Association shall be retired in total or partial liquidation of the loan. As of the projected
date of
the retireme nt of your "C" Participation Certificates, your outstanding debt to the
bank will be
your present outstanding debt in the amount of $36,164.33, together with accrued
interest,
attorney's fees and costs, less application of "C" Participation Certificates in the
amount of
$765.00 .
Please note that interest, late fees, and costs continue to accrue; therefore , it is imperati
ve that
you contact me before tendering any sums to obtain a correct figure for payoff.
I look forward to hearing from you.
Sincerely,
//~---
Gene Mccutch en
Special Assets Manage r
NMLS#1071117 Office: (803)532-3841, Ext. 8417 Cell: (803)42 9-7042
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 40 of 134
CANCEL LATION NOTICE NON-PAYMENTOFPREMIUMl
ACCOUNT NUMB En 1360-1997-27
Monlhly Accmmt
1~501!)\):' ~7 11
Ali 17G1r·A97 NOTICE SENT
010242 0007 DUE BEFORE AMOUNT DUE
KENGNE. RAISSA DJUISSl JI\N 24, 2022 FEB 0, 2022 $393.0? __
lZSO W PTREE ST NW APT 2109
ATLANTA GA 10109-3 416 llf\9 IS TUE ONLY CANCELLATION NOTICE YOU WILL RECEIVE.
•1111,1111,111,11111111,11 1111•11111•1 11111!•1111 11 ••1 11111•1 11 •1
We nollced one or more or your paymenls has been late.
Please pay lt1ls nollce llmely to avoid a lapse in coverage.
As always, you can contact your agent wllh quesllons or lo
discuss addltronal bflllng and payment options at State Farm.
The amount due includes the amounl of a retumed payment.
POLICY INFORMATION
State Fi-rm Life Insuran ce Company
NAME POLICY NUMBER DESCRIPTION
BALANCE DUE
KENGNE, RAISSA DJUISSI
LF-3860-0539
1000000 SELECT TERM - 30
$151.38
Coverage may end following lhe grace period of your life policy if we do nol receive your
payment. Any funds received will be applied
according to your policy provisions. Be advised this notice may not reflect the entire premium
communication regarding the premium due for your life policy. due. You may receive additional
Payment of the balance due indicated here does not extend the policy(s) grace period
your policy has lapsed. or waive any reinstatement requirements if
ACCOUNTHOLDER COPY
Agent Wendy Leung
1e\ephone 404-266- Bi i 8 ti 93 5852 7511 Account # 1350-1997-27
Prepared Date JAN 21 2022
IF YOU HAVE MOVED. PLEASE CONT ACT YOUR AGENT. PLEASE RETURN THIS PART WITH YOUR
Stale farm CHECK MADE PAYABLE TO STATE FARM,
NAME KENGNE, RAISSA DJUISSl
A~ ACCOUNT NUMBER 1350-1997-27 Monthly Account
DUE BEFORE
FEB 6, 2022
AMOUNT DUE
I $393.07
- - - - --- - - - - - -
Please disregard this notice ii payment has been
made. Payment required to continue your Insurance
has not been received. Please QilY lhe full amount
due. THIS IS THE ONLY CANCELLATION NOTICE
270920 2053 YOU WILL RECEIVE.
State Farm Insuran ce Compan ies
P.O. Box 588002
North Metro, GA 30029-8 002
l11 1lll1111 1l1l11•i1 1•1 11 ll1 11l•l1 11111 1•11 11111 11111•1 1111 11 111 1
(o1a0B1ad) (o1b081no)
for 0H1ce use only
Prepared JAN 21 2022
ADI
00047 1761-FA97 11 ACCOUNTHOLDER COPY
L SFPP Cancel \ $393.07 0205
700203 600039 307 000135 019972 711327 >
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 41 of 134
STATE OF GEORGIA
) Case No. 1:22.CV-2297
) (Related Case No.
RAISSA DJUISSI KENGNE, ) I :22-CV-2297-SEG)
Applicant, ) (Related Case No.
) 1:22-CV-2263)
V. )
ID.ME,lNC. )
COGENCY GLOBAL INC. )
250 BROWNS HILL CT, )
MIDLOTHIAN, VA, 23114-9510, USA )
)
Respondent. )
EXHIBIT 6
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 42 of 134
Page I of 5
Local Form 239 (Non-Prisoner Cases) (07/09) Application to Proceed in District Co t Without Prepaying
Fees or Costs (Lon& Form) FILED IN CLERK'S OFFICE
UNITE D STATES DISTRICT COUR T JUN O6 2022
for the
Northern District of Georgia
KEVr/..,;.ER,
By; I
Clerk
eputy Clerk
RAISSA DJUISSI KENGNE ) - I
Plaintiff/Petitioner
ID.ME, INC.
v.
1: 22-CV-2237
Defendant/Respondent
APPLICATION TO PROCEED IN DISTRICT COURT WITHOUT PREPAYING FEES OR COSTS
(Long Form)
Affidavit in Support of the Applicati on Instructio ns
I am a plaintiff or petitioner in this case and declare Complete all questions in this application and then sign it.
that I am unable to pay the costs of these proceedings Do not leave any blanks: if the answer to a question is "O,"
and that I am entitled to the re!iefrequested. I declare "none," or "not applicable (NIA)," write that response. If
under penalty of perjury that the infonnatio n below is you need more space to answer a question or to explain your
true and understand that a false statement may result in answer, attach a separate sheet of paper identified with your
a dismissal ofmy claims .~ name, your case's docket number, and the question number.
1 Date: 06/03/20 22
Signed: r
'=~-i.,.-.- - - - - -
'
I. For both you and your spouse estimate the average amount of money received from each of the following
sources during the past 12 months. Adjust any amount that was received weekly, biweekly, quarterly,
semiannually, or annually to show the monthly rate. Use gross amounts, that is, amounts before any deductions
for taxes or otherwise.
Income source Average monthly income Income amount expected
amount during the past 12 next month
months
You Spouse You Spouse
Employment $ 3,750 $ 0 $ 0 $ 0
Self-employment $ 0 $ 0 $ 0 $ 0
Income from real property (such as rental income) $ 0 $ 0 $ 0 $ 0
Interest and dividends $ 0 $ 0 $ 0 $ 0
Gifts $0 $0 $ 0 $0
Alimony $ 0 $ 0 $ 0 $ 0
Child support $ 0 $0 $ 0 $ 0
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 43 of 134
Page 2 of 5
Local Form 239 (Non-Prisoner Cases) (07/09) Application to J'1·ocl'S:d in District Coun Without PrL'paying Fees or Costs (Long Form)
Retirement (.rnch as social security, pensions, annuities, $0
$ 3,750.00 $0 $0
insurance)
Disability {.<iuch as social security, insurance payments).
$0 $0 $0 $0
Unemployment payments $Q
$0 $0 $0
Public-assistance (such as we((are} $0
$0 $0 $0
Other (spec/fy):
$ 0 $ 0 $0 $0
$ 7,500.00 $0 $0 $0
Total monthly income:
2. List your employment history for the r,ast two years, most recent c111ployer first. (Gross mu11th~v plly is before tuxes or
other deductions.)
Employer Address Dates of employment Gross
monthly pay
1100 PEACHTREE ST NE SUITE 700 09/03/2019-11/18/2022
BOO USA, LLP $9,583.00
ATLANTA, GA 30309
GRANT THORNTON 1100 PEACHTREE ST NE SUITE 1200 04/01/2018 - 08/15/2019 $6,666.66
ATLANTA, GA 30309
3. List your spouse's employment history for the past two years, most recent employer first. (Gross monthly pay is he/ore
taxes or other deductions:)
Employer Address Dates of employment Gross
monthlv oav
N/A N/A N/A N/A N/A N/A $ N/A
$
$
4. How much cash do you and your spouse have'! S 800.00
Below, state any money you or your spouse have in bank accounts or in any other financial institution.
Financial institution Type of account Amount you have Amount your
·• soouse has
Truist Checking $ 150.00 $ 0.00
Ameris Bank Checking $ 800.00 $ 0.00
•.
$
$
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 44 of 134
Page 3 of 5
Local Form 239 (Non-Prisoner Cases) (07/09) Application to Pro-:c..::d in District Court Witlwul Prepaying F..::cs or Costs {Long Fonn)
5. List the assets, and their values, which you own or your spouse owns. Do not list clothing and ordinary
household furnishings.
Assets owned by you or your spouse
Home /Value) Condominium $500,000
Other real estate (Value)
Land Lot $55,000
Motor vehicle#/ (Value) $
Make and year:
Model:
Registration #:
Motor vehicle #2 (Value) $
.
Make and year:
Model:
Registration #:
Other assets (Value) Abandoned House $200,000
Other assets (Value) $
. 6. ~tate every person, business, or organization owing you or your spouse money, and the amount owed .
Person owing you or your spouse Amounl owed to you Amount owed to your spouse
monev
Gemini Trust Company, LLC $ 1,683 $ 0
$ $
'
$ $
7. State the persons who rely on you or your spouse for support.
Name (or, if under 18, initials only) Relationship Age
N/A N/A .
N/A
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 45 of 134
Page 4 of 5
Local Form 239 (Non-Pri~oncr Cases) (~7/09) Applkution 10 rro~·ci:d in Dislrict Court \Vilh1H1t Pn·paying Fees or Costs (Long Form)
8. Estimate the average monthly expenses of you and your frtmily. Show separately the amounts paid by your
spouse. Adjust any payments that are made weekly, biweekly. quarterly, semiannually, or annually to show the
monthly rate.
You Your spouse
Rent or home-mortgage payment (indutling !01 ./'( 11tedfor muhi/c /Jome)
3,000.00 $0
1
Are real estate taxes included? 0 Yes □ No $
Is orooertv insurance included? D Yes 0 No
Utilities (electricity, hea1ing/11el. water, sewer, and 1elepho11e) $ 1,000.00 $0
$
Home maintenance (repaif:-, and upkeep) $ 250.00 0
$
Food $1,000.00 0
$
Clothing $ 0.00 0
$
Laundry and dry-cleaning $ 200.00 0
$
Medical and dental expenses $ 25.00 0
$
Transportation (not including motor vehicle payments) $ 150.00 0
$
Recreation, entertainment, newspapers, magazines, etc. $ 0.00 0
Insurance {not deducted.from wages or i11c/11ded in mortgage paymc-111sJ
State Farm $
Homeowner's or renter1s: s 500.00 0
State Farm $
Life: $ 250.00 0
Aetna $
0
Health: $ 800.00
Motor vehicle:
N/A
s 0.00 $0
Other: s 0.00 $0
Taxes (not deducted from 1vages or included in mortgage payments) {spec(Jj1);
$ 0.00 $0
Installment payments
N/A $
Motor vehicle: s 0.00 0
Bank of America and Citi Bank $
Credit card (name): $4,000.00 0
N/A $
Departmenl store (name): $ 0.00 0
h American Express $
0 t er: $ 2,000.00 0
$
Alimony, maintenance, and support paid to others $ 0.00 0
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 46 of 134
Page 5 of 5
Local Fom1 239 (Non-Prisoner Cases) (07/09) Application 10 Proceed in District Court Withoul rrcp:iying recs or Costs (Long Form)
!Regular expenses for operation of business. profession, or farm (arwch detailed $0.00 $0
statement)
Iother (specify): $0,00 $0
$13,125.00 $0
Total monthly expenses:
9. Do you expect any major changes to your monthly income or expenses or in your assets or liabilities during the
next 12 months?
D Yes 0 No If yes, describe on an attached sheet.
I 0. Have you paid - or will you be paying - an attorney any money for services in connection with this case,
including the completion of this form? D Yes 0 No
If yes, how much? $.
If yes, state the attorney's name, address, and telephone number:
11. Have you paid - or will you be paying - anyone other than an attorney (.rnch as a paralegal or a typist) any money
for services in connection with this case, including the completion of this form? D Yes 0 No
If yes, how much? $
If yes, state the person's name, address, and telephone number:
12. Provide any other information that will help explain why you cannot pay the costs of these proceedings.
' the SEC, and tho PCAOB of unethical behaviors that are in v,olalion or SEC regulations and PCAOB standards 8Khibited by Wesley
I left BDO USA after notifying my supervisor,
Freeman, Sco\l Meier, Peter P.oppo, Paul Davidson, Mark Davenport, and Johnson Wong al Iha following public companies and \heir affiliates: Interface, Atlant1cus, BloHonzons
(Henry Schein's subsidiary), Otelco, BlueLinx, NMS SPAR (subsidiary of SPAR). I was retaliated against.
Since I filed a complain! with the SEC and the PCAOB, my home has been broken into. My phones and computers have been hacked. I have been unable to access the llm!led
amount of money I had lnvosle<I on the Gemini platform. Please see "related lawsuit 2022CV365266.
13. Identify the city and state of your legal residence.
Atlanta, Georgia
.Your daytime phone number: 404-932-1651
Your age: 33 Your years of schooling: 18
Last four digits of your social-security number: 1178
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 47 of 134
STATE OF GEORGIA
) Case No. 1:22..CV-2297
) (Related Case No.
RAISSA DJUISSI KENGNE, ) 1:22-CV-2297-SEG)
Applicant, ) (Related Case No.
) I :22-CV-2263)
V.· )
ID.ME,INC. )
COGENCY GLOBAL INC. )
250 BROWNS HILL CT, )
MIDLOTHIAN, VA, 23114-9510, USA )
)
Respondent. )
EXHIBIT 7
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 48 of 134
Case 1:22-cv-02297-SEG Document 4 Filed 06/10/22 Page 1 of 5
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
RAISSA DJUISSI KENGNE,
Plaintiff, CIVIL ACTION FILE
v. NO. 1:22-cv-02297-SEG
GEORGIA POWER COMP ANY,
Defendant.
FINAL REPORT AND RECOMMENDATION
AND ORDER
Plaintiff, proceeding without counsel, seeks leave to file this civil action in
forma pauperis ("IFP"), without prepayment of fees and costs or security therefor,
pursuant to 28 U.S.C. § 1915(a)(l). [Doc. 1, Application]. This is the third lawsuit
that Plaintiff has filed this week seeking permission to proceed IFP. 1
I. Plaintiff's IFP Application
The affidavit ofpoverty submitted by Plaintiff indicates that over the past twelve
months, Plaintiff has earned an average monthly income of $7,500 from her
1
See Case No. 1:22-cv-02237-SEG, Raissa Djuissi Kengne v. ID.me, Inc., et
al., and Case No. 1:22-cv-02263-SEG-CMS, RaissaDjuissi Kengne v. AG South Farm
Credit, et al.
A072A
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 49 of 134
Case 1:22-cv-02297-SEG Document 4 Filed 06/10/22 Page 2 of 5
employment and retirement, which amounts to $90,000 on an annual basis. [Doc. 1
at 1-2]. Before she left her most recent employment, she was earning $9,583.00 per
month. She does not list any children or a spouse that rely on her for support. [Id. at .
3]. She reports that she owns a condominium valued at approximately $500,000,
a land lot worth $55,000, and an abandoned house worth approximately $200,000.
[Id.]. Plaintiff has estimated her total monthly expenses at approximately $13,125.00.
[Id. at 5].
Plaintiffs allegations of poverty are not fully supported by the record. With an
annual income of approximately $90,000, Plaintiff is well above the poverty level.2
Although Plaintiff lists average monthly expenses of $13,125.00, some of the
discretionary amounts for one person seem unnecessarily high, such as $1000 for food,
$200 for laundry and dry cleaning, and $6000 in monthly credit card installment
payments to Bank of America, Citi Bank, and American Express. [Doc. 1 at 4].
Although Plaintiff may have limited funds, and may have other priorities for
those funds, I believe that she is able to pay the required $402 filing fee and should do
so if she wishes to pursue this case. For the reasons stated, I find that Plaintiff has
2
See https://aspe.hhs.gov/poverty-guidelines (last visited June 8, 2022).
2
A072A
/C,..., 0/CI')\
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 50 of 134
Case 1:22-cv-02297-SEG Document 4 Filed 06/10/22 Page 3 of 5
sufficient means to pay the filing fee and incur the costs of these proceedings. Thus,
Plaintiff's request to proceed IFP is DENIED.
If Plaintiff wishes to proceed with this action, she is ORDERED to pay the
appropriate filing fee to the Clerk within 21 days of the date of this Order.
II. Pfafntiff's Complaint
Before she does so, however, the undersigned notes, after reviewing Plaintiff's
proposed complaint and request for injunctive relief and declaratory judgment, that as
currently drafted, Plaintiff's complaint fails to show that this Court has subject matter
jurisdiction over her claims against the defendant, Georgia Power Company.
Plaintiff's complaint cites only Georgia state statutes and regulations, and her
allegations chiefly pertain to a billing dispute that she, as a residential customer of
Georgia Power, has with the defendant. She alleges that Georgia Power wrongfully
disconnected her residential electrical service and closed her account for nonpayment.
She asks this Court to order Georgia Power to permit Plaintiff to pay the past due
amounts on her account using the same account number she has had for more than ten
years, and to restore power to Plaintiff's home immediately, due to Georgia Power's
alleged violations of local rules and regulations. She alleges that she never received
a disconnection notice, but she also alleges that her condominium management
3
A072A
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 51 of 134
Case 1:22-cv-02297-SEG Document 4 Filed 06/10/22 Page 5 of 5
amount in controversy exceeds $75,000 and is between citizens of different states.
See id. The pleadings and the civil cover sheet that Plaintiff completed indicate that
both she and the Georgia Power Company are citizens of the State of Georgia.
[Doc. 1-3 at 1]. Plaintiffs allegations also show that the amount in controversy is less
than $1000. Thus,-Plaintiffs complaint fails to show that-the-amountiffcontroversy
exceeds $75,000 and the action is between citizens of different states.
III. Conclusion
For the reasons stated, I RECOMMEND that Plaintiffs complaint be
DISMISSED without prejudice for lack of subject matter jurisdiction, and the case
closed. Plaintiffs application to proceed IFP is DENIED.
IT IS SO RECOMMENDED AND ORDERED, this 10th day of June, 2022.
CATHERINE M. SALINAS
UNITED STATES MAGISTRATE JUDGE
5
A072A
/c,..., 0/CI')\
Case
:M/ECF-GA Northern 1:22-cv-02237-SEG
District Court Document 5-3 Filed 07/05/22 Page 52 of 134
https://gand-ecf.sso.dcn/cgi-bin/Dispatch.pl?623415489814
Other Orders/Judgments
1:22-cv-02297-SEG Kengne v.
Georgia Power CompanY.
4months,CMS
U.S. District Court
Northern District of Georgia
__ Notice o~ Ele_ctronic Fi!!_n~. __ . _
The following transaction was entered on 6/10/2022 at 1:53 PM EDT and filed on 6/10/2022
Case Name: Kengne v. Georgia Power Company
Case Number: 1:22-cv-02297-SEG
Filer:
Document Number:.:!:
Docket Text:
FINAL REPORT AND RECOMMENDATION re [3] Complaint, recommending that Plaintiffs
complaint be DISMISSED without prejudice for lack of subject matter jurisdiction, and the case
closed. Plaintiffs application to proceed IFP is DENIED. Signed by Magistrate Judge Catherine
M. Salinas on 06/10/2022. (rsg)
1:22-cv-02297-SEG Notice has been electronically mailed to:
1:22-cv-02297-SEG Notice has been delivered by other means to:
. Raissa Djuissi Kengne
--s,O-Pkdmw,Ave·N··R'- - - - - - - ---~- ---------
#55166
Atlanta, GA 30308
The following document(s) are associated with this transaction:
Document description:Main Document
Original fdename:n/a
Electronic'document Stamp:
[STAMP dcecfStamp_ID=1060868753 [Date=6/10/2022] [FileNumber=12597928-
0] [675429af51e620be5c4ac91c2fd8ec4379b4e054440fl3235e23762b2c97f2ebbd
a18a1247f24749e5793aedc8c7f46ca8e7ae2f66b914930f274fcbdc2ed3eb]]
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 53 of 134
STATE OF GEORGIA
) Case No. 1 :22-CV-2297
) (Related Case No.
RAISSA DJUISSI KENGNE, ) I :22-CV-2297-SEG)
Applicant, ) (Related Case No.
) l:22-CV-2263)
V. )
ID.ME,INC. )
COGENCY GLOBAL.INC. )
250 BROWNS HILL CT, )
MIDLOTHIAN, VA, 23114-9510, USA )
)
Respondent. )
EXHIBIT 8
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 54 of 134
Case 1:22-cv-02297-SEG Document 5 Filed 06/10/22 Page 1 of 2
IN .THE UNITED STATES 'DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
Plaintiff,
CIVIL ACTION FILE
v.
NO. 1:22-cv-02297-SEG
GEORGIA POWER COMPANY,
Defendant.
ORDER FOR SERVICE OF
REPORT AND RECOMMENDATION
The Report and Recommendation of the undersigned United States Magistrate
Judge made in accordance with 28 U.S.C. § 636(b)(l), FED. R. CIV. P. 72(b),
N.D. Ga. R. 72.l(B), (D), and Standing Otder 18-01 (N.D. Ga. Feb. 12, 2018) has
been filed. The Clerk is. DIRECTED to serve upon counsel for the parties and
directly upon any unrepresented parties a copy of the Report and Recommendation
and a copy of this Order.
Pursuant to 28 U.S.C. § 636(b)(l), each party may file written objections, if any,
to the Report and Recommendation within FOURTEEN (14) DAYS of service of this
Order. Should objections be filed, they shall specify with particularity the alleged
A072A
(Rev.8/82)
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 55 of 134
Case 1:22-cv-02297-SEG Document 5 Filed 06/10/22 Page 2 of 2
error(s) made (including reference by page number to any transcripts if applicable)
and shall be served upon the opposing party. The party filing obj,ections will be
responsible for obtaining and filing the transcript of any evidentiary hearing for review
'
by the District Court. Ifno objections are filed, the Report and Recommendation
may be adopted 2s the opinion 2nd ordler ofthe Distrkt Colllrt, and on appeal, the
Court of Appeals will deem waived any challenge to factual and legal findings to
which there was no objection, subject to interests-of-justice plain error review.
Harrigan v. Metro Dade Police Dep't Station #4, 977 F.3d 1185, 1191-92 (11th Cir.
2020); 11th Cir. R. 3-1 ("A party failing to object to a magistrate judge's findings or
recommendations ... waives the right to challenge on appeal the district court's order
based on unobjected-to factual and legal conclusions if the party was informed of the
time period for objecting and the consequences on appeal for failing to object.").
The Clerk is DIRECTED to submit the Report and Recommendation with
objections, if any, to the District Court after expiration of the above time period.
IT IS SO ORDERED and DIRECTED, this 10th day of June, 2022.
CATHERINE M. SALINAS
UNITED STATES MAGISTRATE JUDGE
2
A072A
(Rev.8/82)
Case
;M/ECF-GA Northern 1:22-cv-02237-SEG
District Court Document 5-3 Filed 07/05/22 Page 56 of 134
https://gand-ecf.sso.dcn/cgi-bin/Dispatch.pl?772812970859
Other Orders/Judgments
1:22-cv-02297-SEG Kengne v.
Georgia Power CompanY.
4months,CMS
U.S. District Court
Northern District of Georgia
Notice of Electronic Filing
The following transaction was entered on 6/10/2022 at 1:55 PM EDT and filed on 6/10/2022
Case Name: Kengne v. Georgia Power Company
• Case Number: 1:22-cv-02297-SEG
Filer:
Document Number: .2.
Docket Text:
ORDER for Service of [4] Final Report and Recommendation,, Order ruling on IFP, by
Magistrate Judge Catherine M. Salinas. Each party may file written objections to the Report &
Recommendation within 14 days of service. If no objections are filed, the Report &
Recommendation may be adopted as the opinion and order of the District Court. Signed by
Magistrate Judge Catherine M. Salinas on 06/10/2022. (rsg)
1:22-cv-02297-SEG Notice has been electronically mailed to:
1:22-cv-02297-SEG Notice has been delivered by other means to:
Raissa Djuissi Kengne
570 Piedmont-Ave NE
#55166
Atlanta, GA 30308
The following document(s) are associated with this transaction:
Document description:Main Document
Original filename:n/a
Electronic document Stamp:
[STAMP dcecfStamp_ID=1060868753 [Date=6/10/2022] [FileNumber=12597950-
0] [77981ce88d7d56a3fb159b8836dc5f4a00da86cf56e4505cf59eba6bcd8223d05d
f4076d92944a4ebbb3dad6819528d9351952d05ab229242251338110925b83]]
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 57 of 134
STATE OF GEORGIA
) Case No. 1 :22-CV-2297
) (Related Case No.
RAISSA DJUISSI KENGNE, ) 1 :22-CV-2297-SEG)
Applicant, ) (Related Case No.
) 1:22-CV-2263)
v. )
ID.ME,INC. )
COGENCY GLOBAL INC. )
250 BROWNS HILL CT, )
MIDLOTHIAN, VA, 23114-9510, USA )
)
Respondent. )
EXHIBIT 9
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 58 of 134
EXHIBIT 9A
UNrt'Ei:f'S1:l'1f'ES~DlS'fmcT ee·~
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
) Case No.
) I :22-CV-2297-SEG
RAIS SA DJUISSI KENGNE, )
Plaintiff, )
)
V. )
GEORGIA POWER COMPANY )
C/O Kristi Dow )
241 Ralph McGill Blvd., BIN 10180 )
Atlanta, GA, 30308, USA )
)
Defendant(s). )
PLAINTIFF'S RESPONSES AND OBJECTIONS TO THE FINAL
REPORT AND RECOMMENDATION AND ORDER ISSUED IN
RELATION TO PLAINTIFF'S ORIGINAL COMPLAINT, INJUNCTION
FOR RELIEF, AND DECLARATORY JUDGMENT AND MOTION TO
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Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 59 of 134
RECONSIDER PLAINTIFF'S INITIAL MOTION TO FILING IN
FORMA PAUPERIS
TO THE HONORABLE JUDGE TO SAID COURT:
PLAINTIFF, RAISSA DJUISSI KENGNE ("Plaintiff' or "Homeowner") hereby submits
her response and objections to the Final Report And Recommendation And Order issued in relation
to the Plaintiffs Original Complaint, Injunction For Relief, And Declaratory Judgment (the
"Report", or "R & R"), filed on June I 0, 2022. United States Magistrate Judge Catherine M.
Salinas, has recommended and ordered as follows:
ORDERED, that Plaintiffs request to proceed IFP is DENIED.
FURTHER ORDERED, that Plaintiffs complaint be DISMISSED without prejudice for
lack of subject matter jurisdiction asserting that Complaint cites only Georgia Statutes and
regulations and that the allegations chiefly pertain to a billing dispute Plaintiff has with Georgia
Power. United Stated Magistrate Judge Catherine M. Salinas also asserts that the Civil Cover Sheet
that Plaintiff completed civil cover sheet to initiate this lawsuit does not contain a federal question
jurisdiction. United Stated Magistrate Judge Catherine M. Salinas also asserts that Pursuant to 28
U.S.C. § 1332, federal district courts have original jurisdiction for all civil actions where the
amount in controversy exceeds $75,000 and is between citizens of different states.
Final Report And Recommendation And Order (filed on June I 0, 2022). The recommended
order must be refused because although not expressly stated on the Civil Cover Sheet, Plaintiffs
causes of action and claims for relief as noted under Plaintiffs Original Complaint, Injunction For
Relief, And Declaratory Judgment in counts I through count 5 fall under the US Constitution 14 th
Amendment and the second paragraph of the United States Declaration of Independence.
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Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 60 of 134
The 14th ' Amendment Section 1 states that "All persons born or naturalized in the United
States, and subject to the jurisdiction thereof, are citizens of the United States and the State wherein
they reside. No State shall make or enforce any law which shall abridge the privileges or
immunities of citizens of the United States; nor shall any State deprive any person of life, liberty,
or property, without due process of law; nor deny to any person within its jurisdiction the equal
protection of the laws. The 14th Amendment governs regulation of business enterprises: rates,
charges, aud conditions of service ''Business Affected With a Public Interest'', Defendant Georgia
Power is a "Business Affected With a Public Interest" as defmed in the Fourteenth Amendment
Rights Guaranteed Privileges And Immunities of Citizenship, Due Process And Equal Protection.
In Munn v, Illinois, the first of the "Granger Cases," in which maximum charges
established by a state legislature for Chicago grain elevator companies were challenged, not as
being confiscatory in character, but rather as a regulation beyond the power of any state agency to
impose, the Court, in an opinion that was largely dictum, declared that the due process clause did
not operate as a safeguard against oppressive rates, that if regulation was permissible, the severity
thereof was within legislative discretion and could be ameliorated only by resort to the polls. Not
much time elapsed, however, before the Court effected a complete withdrawal from this position.
By 1890, it had fully converted the due process clause into a positive restriction which the judicial
branch was duty bound to enforce whenever state agencies sought to impose rates which, in its
estimation, were arbitrary or unreasonable,
Plaintiff asserts in Count 1 through 5, taken together, that the rates that she was charged
were arbitrary and/or unreasonable, due to the fact that the readings were inaccurate and
therefore, the total amount on the Plaintiff's electricity bill was inaccurate; thereby, rendering the
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Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 61 of 134
rate charged to the Plaintiff different from the rates approved by the Public Service Commission
("PSC").
Plaintiff asserts in Count I through 5, taken together, that by wrongfully and/or illegally
disconnecting her service without notice, Defendant Georgia Power violated Plaintiff's due
process rights as mandated and protected by the 14th Amendment.
The 14th Amendment also applies to Health, Safety, and Morals. The Fourteenth
Amendment Rights Guaranteed Privileges And Immunities of Citizenship, Due Process And Equal
Protection states that "Even under the narrowest concept of the police power as limited by
substantive due process, it was generally conceded that states could exercise the power to protect
the public health, safety, and morals.
Plaintiff asserts in Count I through 5, taken together, that Georgia Power violated
Plaintiff's 14th Amendment by wrongfully and illegally disconnecting the electricity. The National
Association for the Advancement of Colored People ("NAACP") recently released a report called
Lights Out in the Cold, Reforming Utility Shut-Off Policies as if Human Rights Matter. Plaintiff's
assertion that electricity and its related services are a basic human right and that access to electricity
is a critical component to the prosperity, safety and general well-being of every human being, is
supported by the NAACP research. The NAACP research report can be found at
https://naacp.org/resources/lights-out-cold. Without electricity, Plaintiff is unable to have access
to adequate food, health, and safety.
The Declaration of Independence (US 1776) states that "We hold these truths to be self-
evident, that all men are created equal, that they are endowed by tbeir Creator with certain
unalienable Rights, that among these are Life, Liberty and the pursuit of Happiness.--That to
secure these rights, Governments are instituted among Men, deriving their just powers from the
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consent of the governed, --That whenever any Form of Government becomes destructive of these
ends, it is the Right of the People to alter or to abolish it, and to institute new Government, laying
its fow1dation on such principles and organizing its powers in such form, as to them shall seem
most likely to effect their Safety and Happiness."
Electricity is required for light, heat, cooling, and cooking. Electricity is also needed to
operate phones, internet, TV, and computer for personal user or professional use. Light, heat,
cooling, and cooking are basic rights that enables the pursuit of happiness, life, and liberty. If
every person is afforded an opportunity to have electricity, a publicly regulated resource, it is
ensured that his or her rights to pursue happiness, life, and liberty are not violated.
Defendant Georgia Power has violated Plaintiffs unalienable rights under the second
paragraph of the American Declaration of Independence by wrongfully and/or illegally
disconnecting electricity at Plaintiffs home, thereby, violating Plaintiffs right to Life, Liberty and
the pursuit of Happiness. Defendant Georgia Power has violated Plaintiffs rights to due process
under the 14th Amendment by wrongfully and/or illegally disconnecting electricity at Plaintiffs
home, thereby, violating Plaintiff's right to Life, Liberty and the pursuit of Happiness.
Plaintiff intends for discovery to provide additional information in order to gain more
understanding into why the events listed below happened.
a. Plaintiff's electricity was disconnected wrongfully and/or illegally.
b. Defendant Georgia Power refuses to allow Plaintiff to pay the past due amount on her
balance on her same account number; thereby, depriving Plaintiff of electricity for approximately
three (3) months. To this date, Plaintiff is still without electricity at her primary residence.
s of 49
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 63 of 134
c. Defendant Georgia Power refuses to re-establish electricity at Plaintiffs primary home
even though Plaintiff is willing to pay for the past due balance on the account she has held for
more than ten (10) years.
d. Plaintiff never received a disconnection notice on her door and the Georgia Power's
agent told Plaintiff that he did not have a disconnection notice and a disconnection notice is no
longer provided and was not sent.
Plaintiffs Prayers for Relief to the Court in Plaintiffs Original Complaint, Injunction For
Relief, And Declaratory Judgment includes, but is not limited to, a Court's request to "Grant any
such additional relief to Plaintiff in law or equity as the Court deems just and proper under the
circumstances." Plaintiffs request includes actual and punitive damages.
ARGUMENT
A. CIVIL COVER SHEET
United Stated Magistrate Judge Catherine M. Salinas asserts in the Final Report And
Recommendation And Order issued in relation to the Plaintiffs Original Complaint, Injunction
For Relief, And Declaratory Judgment that the Civil Cover Sheet that Plaintiff completed to initiate
this lawsuit does not contain a federal question jurisdiction. "In this case, the civil order cover
sheet that Plaintiff completed to initiate this lawsuit indicates that she is asserting federal question
jurisdiction."
Plaintiff did not cite all the U.S. Civil Statute under which Plaintiff was filing. The three
(3) U.S. Civil statutes listed below were omitted from the Civil Cover Sheet to initiate the case.
a. 14th Amendment Section 1,
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Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 64 of 134
b. The Declaration of Independence (US 1776) - Regulation of Business Enterprises:
Rates, Charges, and Conditions of Service "Business Affected With a Public Interest",
c. The Declaration oflndependence (US 1776) - Health, Safety, and Morals.
Plaintiff notes that the Federal Rules of Civil Procedure document dated December I, 2020
does not state that a case must be dismissed if there is an omission on the Civil Cover Sheet.
Furthermore, in evaluating the legal sufficiency of a complaint for purposes of§ 1915(d),
the courts apply the customary standard enunciated in Conley v. Gibson, 355 U.S. 41, 45-46, 78
S.Ct. 99, 101-102, 2 L.Ed.2d 80 (1957), that a complaint should not be dismissed for failure to
state a claim unless it appears beyond doubt that the Plaintiff can prove no set of facts in support
of his or her claim, which would entitle him or her to relief.
Plaintiff can prove to facts to support her claims and has provided evidence to support her
claims.
Plaintiff is hereby requesting that the three (3) U.S. Civil statutes listed above be added to
the Civil Cover Sheet to initiate the case number I :22-CV-02297-SEG.
Plaintiff's case is not a diversity jurisdiction case.
United Stated Magistrate Judge Catherine M. Salinas asserts in the Final Report And
Recommendation And Order issued in relation to the Plaintiffs Original Complaint, Injunction
For Relief, And Declaratory Judgment that "There are no allegations in Plaintiff's proposed
complaint to support federal question jurisdiction." PlaintiffRaissa Djuissi Kengne disagrees with
this statement.
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Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 65 of 134
Plaintiff asserts in Counts 1 though 5, taken together cover the 14th, Amendment and the
Declaration of Independence. Plaintiffs Original Complaint, Injunction For Relief, And
Declaratory Judgment contains the federal question jurisdiction in the following sections:
a. Under IV. CAUSES OF ACTION AND CLAIMS FOR RELIEF - COUNT
ONE: section 95, "Plaintiff Raissa Djuissi Kengne is in need of intervention by the Court
to settle and afford relief from lack of electricity, uncertainty, and insecurity with respect
to her rights". The law defines "Right" as below.
i. A power or privilege held by the general public as the result of a
constitution, statute, regulation, judicial precedent, or other type of law.
11. A legally enforceable claim held by someone as the result of specific
events or transactions.
m. Loosely, any situation or decision that seems proper or correct by
virtue oflegal, moral, or ethical ideals (i.e., the opposite of wrong.
Plaintiffs Original Complaint, Injunction For Relief, And Declaratory
Judgment refers "to her rights" as understood as her Constitutional and
Fundamental rights and as defined by the law in the three (3) senses of the word
"Right" presented above and obtained from the the Cornell Law Wex Online
Library.
b. under IV. CAUSES OF ACTION AND CLAIMS FOR RELIEF - COUNT
TWO: section 107; "PlaintiffRaissa Djuissi Kengne is in need of intervention by the Court
to settle and afford relief from lack of electricity, uncertainty, and insecurity with respect
to her rights". The law defines "Right" as below.
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Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 66 of 134
1. A power or privilege held by the general public as the result of a
constitution, statute, regulation, judicial precedent, or other type of law.
ii. A legally enforceable claim held by someone as the result of specific
events or transactions.
iii. Loosely, any situation or decision that seems proper or correct by
virtue oflegal, moral, or ethical ideals (i.e., the opposite of wrong.
Plaintiffs Original Complaint, Injunction For Relief, And Declaratory
Judgment refers "to her rights" as understood as her Constitutional and
Fundamental rights and as defined by the law in the three (3) senses of the word
"Right" presented above and obtained from the the Cornell Law Wex Online
Library.
c. Under IV. CAUSES OF ACTION AND CLAIMS FOR RELIEF - COUNT
THREE: section 111; "Plaintiff Raissa Djuissi Kengne is in need of intervention by the
Court to settle and afford relief from lack of electricity, uncertainty, and insecurity with
respect to her rights". The law defines "Right" as below.
1. A power or privilege held by the general public as the result of a
constitution, statute, regulation, judicial precedent, or other type of law.
11. A legally enforceable claim held by someone as the result of specific
events or transactions.
111. Loosely, any situation or decision that seems proper or correct by
virtue of legal, moral, or ethical ideals (i.e., the opposite of wrong.
Plaintiffs Original Complaint, Injunction For Relief, And Declaratory
Judgment refers "to her rights" as understood by her Constitutional and
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Fundamental rights and as defined by the law in the three (3) senses of the word
"Right" presented above and obtained from the the Cornell Law Wex Online
Library.
d. Under IV. CAUSES OF ACTION AND CLAIMS FOR RELIEF - COUNT
FOUR: section 114; "PlaintiffRaissa Djuissi Kengne is in need ofintervention by the Court
to settle and afford relief from lack of electricity, uncertainty, and insecurity with respect
to her rights". The law defines "Right" as below.
1. A power or privilege held by the general public as the result of a
constitution, statute, regulation, judicial precedent, or other type of law.
ii. A legally enforceable claim held by someone as the result of specific
events or transactions.
m. Loosely, any situation or decision that seems proper or correct by
virtue of legal, moral, or ethical ideals (i.e., the opposite of wrong.
Plaintiffs Original Complaint, Injunction For Relief, And Declaratory
Judgment refers "to her rights" as understood as her Constitutional and
Fundamental rights and as defined by the law in the three (3) senses of the word
"Right" presented above and obtained from the the Cornell Law Wex Online
Library.
e. Under IV. CAUSES OF ACTION AND CLAIMS FOR RELIEF - COUNT
FIVE: section 125; "PlaintiffRaissa Djuissi Kengne is in need of intervention by the Court
to settle and afford relief from lack of electricity, uncertainty, and insecurity with respect
to her rights". The law defines "Right" as below.
10 of 49
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 68 of 134
1. A power or privilege held by the general public as the result of a
constitution, statute, regulation, judicial precedent, or other type of law.
11. A legally enforceable claim held by someone as the result of specific
events or transactions.
m. Loosely, any situation or decision that seems proper or correct by
virtue oflegal, moral, or ethical ideals (i.e., the opposite of wrong.
Plaintiffs Original Complaint, Injunction For Relief, And Declaratory
Judgment refers "to her rights" as understood by her Constitutional and
Fundamental rights and as defined by the law in the three (3) senses of the word
"Right" presented above and obtained from the Cornell Law Wex Online Library.
Plaintiff asserts in Counts 1 through 5, taken together, that Georgia Power violated
Plaintiffs 14th Amendment by wrongfully and illegally disconnecting the electricity. The National
Association for the Advancement of Colored People ("NAACP") recently released a report called
Lights Out in the Cold, Reforming Utility Shut-Off Policies as if Human Rights Matter. Plaintiffs
assertion that electricity and its related services are a basic human right and that access to electricity
is a critical component to the prosperity, safety and general well-being of every human being, is
supported by the NAACP research. Without electricity, Plaintiff is unable to have access to
adequate food, healthcare, and safety.
The 14th Amendment also applies to Health, Safety, and Morals. The Fourteenth
Amendment Rights Guaranteed Privileges And Immunities of Citizenship, Due Process And Equal
Protection states that "Even under the narrowest concept of the police power as limited by
11 of 49
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 69 of 134
substantive due process, it was generally conceded that states could exercise the power to protect
the public health, safety, and morals."
The Declaration oflndependence (US 1776) states that "We hold these truths to be self-
evident, that all men are created equal, that they are endowed by their Creator with certain
unalienable Rights, that among these are Life, Liberty and the pursuit of Happiness."
Electricity is required for light, heat, cooling, and cooking. Electricity is also needed to
operate phones, internet, TV, and computer for personal use or professional use. Light, heat,
cooling, and cooking are basic rights that enables the pursuit of happiness, life, and liberty. If every
person is afforded an opportunity to have electricity, a publicly regulated resource, it is ensured
that his or her rights to pursue happiness are not violated.
Defendant Georgia Power has violated Plaintiffs unalienable rights under the second
paragraph of the American Declaration of Independence by wrongfully and/or illegally
disconnecting electricity at Plaintiffs home; thereby, violating Plaintiffs right to Life, Liberty and
the pursuit of Happiness. Defendant Georgia Power has violated Plaintiffs rights to due process
under the 14th Amendment by wrongfully and/or illegally disconnecting electricity at Plaintiffs
home, thereby, violating Plaintiffs right to Life, Liberty and the pursuit of Happiness.
Plaintiff intends for discovery to provide additional information in order to gain more
understanding into why the events listed below happened.
a. Plaintiffs electricity was disconnected wrongfully and/or illegally.
b. Defendant Georgia Power refuses to allow Plaintiff to pay the past due amount on her
balance on her same account number; thereby, depriving Plaintiff of electricity for approximately
three (3) months. To this date, Plaintiff is still without electricity at her primary residence.
12 of 49
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 70 of 134
c. Defendant Georgia Power refuses to re-establish electricity at Plaintiff's primary home
even though Plaintiff is willing to pay for the past due balance on the account she has held for
more than ten (I 0) years.
d. Plaintiff never received a disconnection notice on her door and the Georgia Power's
agent told Plaintiff that he did not have a disconnection notice and a disconnection notice is no
longer provided and was not sent.
B. THE SUBJECT MATTER OF THE CASE AND THE CONTROVERSY
AMOUNT
United States Magistrate Judge Catherine M. Salinas asserts in the Final Report And
Recommendation And Order issued in relation to the Plaintiffs Original Complaint, Injunction
For Relief, And Declaratory Judgment that Plaintiff's "allegations chiefly pertain to a billing
dispute that she as a residential customer of Georgia Power, has with the Defendant Georgia
Power."
Plaintiff asserts that United States Magistrate Judge Catherine M. Salinas misread the
complaint and the complaint does NOT pertain to a simple billing dispute due to the fact that I)
Plaintiff wants to paid the electricity bill and Georgia Power refuses to accept Plaintiffs payment
and thereby depriving Plaintiff to Life, Liberty and the pursuit of Happiness as mandated by the
14th Amendment and 2) Defendant Georgia Power wrongfully and/or illegally disconnected the
service without a notice; thereby, depriving Plaintiff of her rights to due process as well as to Life,
Liberty and the pursuit of Happiness as mandated by the United States 14th Amendment and the
Declaration of Independence.
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Plaintiff's past due balance on her Georgia Power's electricity bill is NOT the controversy
amount and is NOT the subject matter of the Complaint as stated by United States Magistrate
Judge Catherine M. Salinas in the Final Report And Recommendation And Order issued in relation
to the Plaintiff's Original Complaint, Injunction For Relief, And Declaratory Judgment.
The subject matter of the Complaint is the fact that Georgia Power, a utility company that
provides public services and is regulated by the PSC is refusing to allow Plaintiff to pay the past
due amount on her balance on her existing account. Plaintiff is now without electricity for
approximately three (3) months. Plaintiff has experienced the high cold and is experiencing the
high heat of Georgia without cooling and heating. Plaintiff is unable to cook at home due to the
fact that the condominium Plaintiff's lives in does not allow for gas appliances. Defendant Georgia
Power is depriving Plaintiff of her rights under the 14th Amendment and the Declaration of
Independence.
The controversy amount is NOT the past due amount on Plaintiff's electricity bill, but it is
of an intangible nature that is well above $75,000 due to 1) the fact that Georgia Power refuses
to allow Plaintiff to pay for her electricity bill and 2) the nature of the wrongful and/or illegal acts
and the legal standards the wrongful and/or illegal acts fall under. To clarify, the 14th Amendment
and the United States Declaration oflndependence.
The 14th Amendment Section I states that "All persons born or naturalized in the United
States, and subject to the jurisdiction thereof, are citizens of the United States and the State wherein
they reside. No State shall make or enforce any law which shall abridge the privileges or
immunities of citizens of the United States; nor shall any State deprive any person of life, liberty,
or property, without due process of law; nor deny to any person within its jurisdiction the equal
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protection of the laws. The 14th Amendment governs regulation of business enterprises: rates,
charges, and conditions of service "Business Affected-With a Public Interest".
Defendant Georgia Power is a "Business Affected With a Public Interest" as defined in the
Fourteenth Amendment Rights Guaranteed Privileges And Immunities of Citizenship, Due
Process And Equal Protection.
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AMENDMENT 14-RIGHTS GUARANTEED
Regulation of Business Enterprises: Rates, Charges, and
Conditions of Service
"Business Affected With a Public Interest"-ln endeavoring
to measure the Impact of the due process clause upon efforts by the
States to control the charges exacted by various businesses for
their services, the Supreme Court, almost from the inception of the
Fourteenth Amendment, devoted itself to the examination of two
questions: (1) whether the clause precluded that kind of regulation
of cer>tain types of business, and (2) the nature of the restraint, If
any, which this clause imposed on state control of rates in the case
of businesses as to which such control existed. For a brief interval
following the ratification of the Fourteenth Amendment, the Su-
preme Court appears to have underestimated the significance of
the due process clause as a substantive restraint on the power of
States to fix rates chargeable by an industry deemed appropriately
subject to such controls. Thus, in lvfunn v. Illinois, 138 the first of
the "Granger Cases," in which maximum charges established by a
state legislature for Chicago grain elevator companies were chal-
lenged, not as being confiscatory in character, but rather as a regu-
lation beyond the power of any state agency to impose, the Court,
in an opinion that was largely dictum, declared that the due proc-
ess clause did not operate as a safeguard against oppressive rates,
that If regulation was permissible, the severity thereof was within
legislative discretion and could be ameliorated only by resort to the
polls. Not much time elapsed, however, before the Court effected a
complete withdrawal from this position. By 1890 139 it had fully
converted the due process clause into a positive restriction which
the judicial branch was duty bound to enforce whenever state agen-
cies sought to impose rates which, in its estimation, were arbitrary
or unreasonable.
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In contrast to the speed with which the Court arrived at those
above mentioned conclusions, more than fifty years were to elapse
before it developed its currently applicable formula for determining
the propriety of subjecting specific businesses to state regulation of
their prices or charges. Prior to 1934, unless a business was "af-
fected with a public interest," control of its prices, rates, or condi-
tions of service was viewed as an unconstitutional deprivation of
liberty and property without due process of law. During the period
of its application, however, this standard, "business affected with
a public interest," never acquired any precise meaning, and as a
consequence lawyers were never able to identify all those qualities
or attributes which invariably distinguished a business so affected
from one not so affected. The most coherent effort by the Court was
the following classification prepared by Chief Justice Taft. 140 "(1)
Those [businesses] which are carried on under the authority of a
public grant of privileges which either expressly or impliedly im-
poses the affirmative duty of rendering a public service demanded
by any member of the public. Such are the railroads, other common
carriers and public utilities. (2) Certain occupations, regarded as
exceptional, the public interest attaching to which, recognized from
earliest times, has survived the period of arbitrary laws by Par-
liament or Colonial legislatures for regulating all trades and
callings. Such are those of the keepers of inns, cabs and grist mills .
. . . (3) RusinP.<;sps whir.h thnngh not puhlk at thPir inrPption may
be fairly said to have risen to be such and have become subject in
consequence to some government regulation. They have come to
hold such a peculiar relation to the public that this is super-
imposed upon them. In the language of the cases, the owner by de-
voting his business to the public use, in effect grants the public an
interest in that use and subjects himself to public regulation to the
extent of that interest although the property continues to belong to
its private owner and to be entitled to protection accordingly."
Through application of this now outmoded formula the Court
found it possible to sustain state laws regulating charges made by
grain elevators, 1 41 stockyards, 142 and tobacco warehouses, 143 and
fire insurance rates 144 and commissions paid to fire insurance
agents. 145 Voided, because the businesses sought to be controlled
In Munn v. Illinois, the first of the "Granger Cases," in which maximum charges
established by a state legislature for Chicago grain elevator companies were challenged, not as
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being confiscatory in character, but rather as a regulation beyond the power of any state agency to
impose, the Court, in an opinion that was largely dictum, declared that the due process clause did
not operate as a safeguard against oppressive rates, that ifregulation was permissible, the severity
thereof was within legislative discretion and could be ameliorated only by resort to the polls. Not
much time elapsed, however, before the Court effected a complete withdrawal from this position.
By 1890, it had fully converted the due process clause into a positive restriction which the judicial
branch was duty bound to enforce whenever state agencies sought to impose rates which, in its
estimation, were arbitrary or unreasonable.
Plaintiff asserts in Counts I though 5, taken together, that the rates that she was charged
were arbitrary and/or unreasonable, due to the fact that the readings were inaccurate and
therefore, the total amount on the Plaintiffs electricity bill was inaccurate; thereby, rendering the
rate charged to the Plaintiff different from the rates approved by the Public Service Commission
("PSC").
The total kWh used on Plaintiffs electricity bill for the month of November 2022 was 390
kWh. The total kWh used on Plaintiffs electricity bill for the month of December 2022 was 723
kWh. There is a difference of85.34%. The usage on the bill increased by 85.34% or 333 between
November 2022 and December 13, 2022. Regardless of the formula that is been used, ifa reading
or kwh used is inaccurate, then the total amount is also inaccurate, which makes the rate applied
and used to calculate the electricity bill also inaccurate. Therefore, if the rate applied and used is
inaccurate, Plaintiff has a claim to bring this lawsuit to the Court under the 14th Amendment -
Regulation of Business Enterprises: Rates, Charges, and Conditions of Service' 'Business Affected
With a Public Interest''. Defendant Georgia Power is a "Business Affected With a Public Interest"
as defined in the Fourteenth Amendment Rights Guaranteed Privileges And Immunities of
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Citizenship, Due Process And Equal Protection. The relevant exhibits are included in the Notice
of Filing.
The total kWh used on Plaintiffs electricity bill for the month of January dated January
13rd, 2022 was 736 kWh. The total kWh used on Plaintiffs electricity bill for the month of
February dated February 11th, 2022 was 538 kWh. There is a difference of 26.90%. The usage on
the bill decreased by 26.90% or 333 between January 13rd, 2022 and February 11th, 2022.
Regardless of the formula that is being used, if a reading or kWh used is inaccurate, then the total
amount is also inaccurate, which makes the rate applied and used to calculate the electricity bill is
also inaccurate. Regardless of the formula that is been used, ifa reading or kwh used is inaccurate,
then the total amount is also inaccurate, which makes the rate applied and used to calculate the
electricity bill is also inaccurate. Therefore, if the rate applied and used is inaccurate, Plaintiff has
a claim to bring this lawsuit to the Court under the 14th Amendment - Regulation of Business
Enterprises: Rates, Charges, and Conditions of Service "Business Affected With a Public
Interest''. Defendant Georgia Power is a "Business Affected With a Public Interest" as defined in
the Fourteenth Amendment Rights Guaranteed Privileges And Immunities of Citizenship, Due
Process And Equal Protection. The relevant exhibits are included in the Notice of Filing.
Plaintiff asserts in Counts 1 though 5, taken together, that the rates that she was charged
were arbitrary and/or unreasonable, due to the fact that the readings were inaccurate and
therefore, the total amount on the Plaintiffs electricity bill was inaccurate; thereby, rendering the
rate charged to the Plaintiff different from the rates approved by the Public Service Commission
("PSC"). The 14th Amendment governs the Regulation of Business Enterprises: Rates, Charges,
and Conditions of Service '' Business Affected With a Public Interest''. Defendant Georgia Power
is a "Business Affected With a Public Interest" as defined in the Fourteenth Amendment Rights
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Guaranteed Privileges And Immunities of Citizenship, Due Process And Equal Protection. Plaintiff
has a claim to bring this lawsuit to the Federal District Court under the 14th Amendment.
The 14th Amendment also applies to Health, Safety, and Morals. The Fourteenth
Amendment Rights Guaranteed Privileges And Immunities of Citizenship, Due Process And Equal
Protection states that "Even under the narrowest concept of the police power as limited by
substantive due process, it was generally conceded that states could exercise the power to protect
the public health, safety, and morals.
Plaintiff asserts in Counts 1 though 5, taken together, that Georgia Power violated
Plaintiffs 14th Amendment by wrongfully and illegally disconnecting the electricity. The National
Association for the Advancement of Colored People ("NAACP") recently released a report called
Lights Out in the Cold, Reforming Utility Shut-Off Policies as if Human Rights Matter. Plaintiffs
assertion that electricity and its related services are a basic human right. and that access to
electricity is a critical component to the prosperity, safety and general well-being of every human
being is supported by the NAACP research. Without electricity, Plaintiff is unable to have access
to adequate food, healthcare, and safety. The NAACP research report can be found at
https://naacp .org/resources/lights-out-co Id.
The Declaration of Independence (US 1776) states that "We hold these truths to be self-
evident, that all men are created equal, that they are endowed by their Creator with certain
unalienable Rights, that among these are Life, Liberty and the pursuit ofHappiness.--That to secure
these rights, Governments are instituted among Men, deriving their just powers from the consent
of the governed, --That whenever any Form of Government becomes destructive of these ends, it
is the Right of the People to alter or to abolish it, and to institute new Government, laying its
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foundation on such principles and organizing its powers in such form, as to them shall seem most
likely to effect their Safety and Happiness."
Electricity is required for light, heat, cooling, and cooking. Electricity is also needed to
operate phones, internet, TV, and computer for personal user or professional use. Light, heat,
cooling, and cooking are basic rights that enables the pursuit of happiness, life, and liberty. If every
person is afforded an opportunity to have electricity, a publicly regulated resource, it is ensured
that his or her rights to pursue happiness are not violated.
Memphis Light, Gas Water Division v. Kraft, 436 U.S. 1, 98 S. Ct. 1554, 56 L.Ed.2d 30
(1978), requires municipal utilities not to terminate service without procedural due process
protection for those with a property interest in such services.
Defendant Georgia Power has violated Plaintiffs unalienable rights under the second
paragraph of the American Declaration of Independence by wrongfully and/or illegally
disconnecting electricity at Plaintiffs home, thereby, violating Plaintiffs rights to due process and
to Life, Liberty and the pursuit of Happiness.
Plaintiffs Prayers for Relief to the Court in Plaintiffs Original Complaint, Injunction For
Relief, And Declaratory Judgment includes, but is not limited to, a Court request to "Grant any
such additional relief to Plaintiff in law or equity as the Court deems just and proper under the
circumstances." Plaintiffs request includes actual and punitive damages.
Plaintiff notes that the Federal Rules Of Civil Procedure document dated December I, 2020
does not state that a case must be dismissed ifthere is an omission on the Civil Cover Sheet.
In evaluating the legal sufficiency of a complaint for purposes of§ 1915(d), the courts apply
the customary standard enunciated in Conley v. Gibson, 355 U.S. 41, 45-46, 78 S.Ct. 99, 101-102,
2 L.Ed.2d 80 (I 957), that a complaint should not be dismissed for failure to state a claim unless it
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appears beyond doubt that the Plaintiff can prove no set of facts in support of his or her claim,
which would entitle him or her to relief.
Plaintiff is hereby requesting that the three (3) U.S. Civil statutes listed under "A. Civil
Cover Sheet" section above be added to the Civil Cover Sheet to initiate the case number I :22-
CV-02297-SEG.
C. FEDERAL JURISDICTION AND CONTROVERSY AMOUNT
United Stated Magistrate Judge Catherine M. Salinas asserts in the Final Report And
Recommendation And Order issued in relation to the Plaintiffs Original Complaint, Injunction
For Relief, And Declaratory Judgment that "Pursuant to 28 U.S.C. § I 332, federal district courts
have original jurisdiction for all civil actions where the amount in controversy exceeds $75,000
and is between citizens of different states."
Plaintiff's case is not a diversity jurisdiction case.
Plaintiff did not cite all the U.S. Civil Statutes under which Plaintiff was filing. The three
(3) U.S. Civil statutes listed below were omitted from the Civil Cover Sheet to initiate the case.
a. 14th Amendment Section I,
b. The Declaration of Independence (US 1776) - Regulation of Business Enterprises:
Rates, Charges, and Conditions of Service ''Business Affected With a Public Interest'',
c. The Declaration of Independence (US 1776) - Health, Safety, and Morals.
Plaintiff notes that the FEderal Rules Of Civil Procedure document dated December I,
2020 does not state that a case must be dismissed if there is an omission on the Civil Cover Sheet.
In evaluating the legal sufficiency of a complaint for purposes of§ J9 J 5(d), the courts apply
the customary standard enunciated in Conley v. Gibson, 355 U.S. 41, 45-46, 78 S.Ct. 99, 101-102,
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2 L.Ed.2d 80 (1957), that a complaint should not be dismissed for failure to state a claim unless it
appears beyond doubt that the Plaintiff can prove no set of facts in support of his or her claim,
which would entitle him or her to relief.
Plaintiff is hereby requesting that the three (3) U.S. Civil statutes listed under "A. Civil
Cover Sheet" section above be added to the Civil Cover Sheet to initiate the case number I :22-
CV-02297-SEG.
Plaintiff's past due balance on her Georgia Power's electricity bill, which is less than
$1,000.00 is NOT the controversy amount as stated by United States Magistrate Judge Catherine
M. Salinas in the Final Report And Recommendation And Order issued in relation to the Plaintiffs
Original Complaint, Injunction For Relief, And Declaratory Judgment.
The controversy amount is NOT the past due amount on Plaintiff's electricity bill, rather it
is of an intangible nature that is well above $75,000 due to I) the fact that Georgia Power refuses
to allow Plaintiff to pay for her electricity bill on her existing account and 2) the nature of the
wrongful and/or illegal acts and the legal standards the wrongful and/or illegal acts fall under. To
clarify, the 14th Amendment and the United States Declaration ofindependence.
The 14th Amendment Section I states that "All persons born or naturalized in the United
States, and subject to the jurisdiction thereof, are citizens of the United States and the State wherein
they reside. No State shall make or enforce any law which shall abridge the privileges or
immunities of citizens of the United States; nor shall any State deprive any person oflife, liberty,
or property, without due process of law; nor deny to any person within its jurisdiction the equal
protection of the laws." The 14th Amendment governs regulation of business enterprises: rates,
charges, and conditions of service ''Business Affected With a Public Interest''. Defendant Georgia
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Power is a "Business Affected With a Public Interest" as defined in the Fourteenth Amendment
Rights Guaranteed Privileges And Immunities of Citizenship, Due Process And Equal Protection.
In Munn v. Illinois, the first of the "Granger Cases," in which maximum charges
established by a state legislature for Chicago grain elevator companies were challenged, not as
being confiscatory in character, but rather as a regulation beyond the power of any state agency to
impose, the Court, in an opinion that was largely dictum, declared that the due process clause did
not operate as a safeguard against oppressive rates, that if regulation was permissible, the severity
thereof was within legislative discretion and could be ameliorated only by resort to the polls. Not
much time elapsed, however, before the Court effected a complete withdrawal from this position.
By 1890, it had fully converted the due process clause into a positive restriction which the judicial
branch was duty bound to enforce whenever state agencies sought to impose rates which, in its
estimation, were arbitrary or unreasonable."
Plaintiff asserts in Counts I though 5, taken together, that the rates that she was charged
were arbitrary and/or unreasonable, due to the fact that the readings were inaccurate and
therefore, the total amount on the Plaintiff's electricity bill was inaccurate; thereby, rendering the
rate charged to the Plaintiff different from the rates approved by the Public Service Commission
("PSC") and making these rates arbitrary and/or unreasonable.
The 14th Amendment also applies to Health, Safety, and Morals. The Fourteenth
Amendment Rights Guaranteed Privileges And Immunities of Citizenship, Due Process And Equal
Protection states that "Even under the narrowest concept of the police power as limited by
substantive due process, it was generally conceded that states could exercise the power to protect
the public health, safety, and morals."
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Plaintiff asserts in Counts 1 through 5, taken together, that Georgia Power violated
Plaintiffs 14th Amendment by wrongfully and illegally disconnecting the electricity. The National
Association for the Advancement of Colored People ("NAACP") recently released a report called
Lights Out in the Cold, Reforming Utility Shut-Off Policies as if Human Rights Matter. Plaintiff's
assertions that electricity and its related services are a basic human right is supported by the
NAACP research. Plaintiff asserts that access to electricity is a critical component to the
prosperity, safety and general well-being of every human being, which is also supported by the
NAACP's research. Without electricity, Plaintiff is unable to have access to adequate food, health,
and safety. The NAACP research report can be found at https://naacp.org/resources/lights-out-
cold.
The Declaration of Independence (US 1776) states that "We hold these truths to be self-
evident, that all men are created equal, that they are endowed by their Creator with certain
unalienable Rights, that among these are Life, Liberty and the pursuit of Happiness.--That to
secure these rights, Governments are instituted among Men, deriving their just powers from the
consent of the governed, --That whenever any Form of Government becomes destructive of these
ends, it is the Right of the People to alter or to abolish it, and to institute new Government, laying
its foundation on such principles and organizing its powers in such form, as to them shall seem
most likely to effect their Safety and Happiness."
Electricity is required for light, heat, cooling, and cooking. Electricity is also needed to
operate phones, internet, TV, and computer for personal user or professional use. Light, heat,
cooling, and cooking are basic rights that enables the pursuit of happiness, life, and liberty. If every
person is afforded an opportunity to have electricity, a publicly regulated resource, it is ensured
that his or her rights to pursue happiness are not violated.
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Defendant Georgia Power has violated Plaintiffs unalienable rights under the second
paragraph of the American Declaration of Independence by wrongfully and/or illegally
disconnecting electricity at Plaintiff's home, thereby, violating Plaintiff's rights to due process and
to Life, Liberty and the pursuit of Happiness.
D. REQUIRED NOTICE OF DISCONNECTION
United Stated Magistrate Judge Catherine M. Salinas asserts in the Final Report And
Recommendation And Order issued in relation to the Plaintiff's Original Complaint, Injunction
For Relief, And Declaratory Judgment that Plaintiff "alleges that she never received a
disconnection notice, but she also alleges that her condominium management withheld her mail
access during the relevant period and that the mail issue is part of a lawsuit that she has filed in the
Superior Court of Fulton County."
Plaintiff asserts that United States Magistrate Judge Catherine M. Salinas misread the
complaint and the analysis is flawed.
The Notice of Disconnection should be left on the customer door. PlaintiffRaissa Djuissi
Kengne was at home when the electricity was disconnected; the Georgia Power's agent told
Plaintiff that he did not have a disconnection notice and a disconnection notice is no longer
provided and was not sent. The Georgia Power's agent further stated that he was ordered to turn
off the electricity at Plaintiffs primary home. The service disconnection happened when the
temperature was in the seasonal hold.
Plaintiff asserts that the termination without notice violates Plaintiffs procedural due
process right and that Defendant Georgia Power, by presuming charges for services not furnished
or rendered, violated Plaintiffs substantive due process right.
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Defendant Georgia Power has violated Plaintiffs due process rights under the 14th
Amendment and unalienable rights under the second paragraph of the American Declaration of
Independence by wrongfully and/or illegally disconnecting electricity at Plaintiffs home, thereby,
violating Plaintiffs rights to due process and Life, Liberty and the pursuit of Happiness.
Plaintiff intends for discovery to provide additional information in order to gain more
understanding into why the events listed below happened.
a. Plaintiff's electricity was disconnected wrongfully and/or illegally.
b. Defendant Georgia Power refuses to allow Plaintiff to pay the past due
amount on her balance on her same account number; thereby, depriving Plaintiff of
electricity for approximately three (3) months. To this date, Plaintiff is still without
electricity at her primary residence.
c. Defendant Georgia Power refuses to re-establish electricity at Plaintiff's
primary home even though Plaintiff is willing to pay for the past due balance on the account
she has held for more than ten (I 0) years.
d. Plaintiff never received a disconnection notice on her door and the Georgia
Power's agent told Plaintiff that he did not have a disconnection notice and a disconnection
notice is no longer provided and was not sent.
Plaintiff asserts in Connts I through 5, taken together, that the rates that she was charged
were arbitrary and/or unreasonable, due to the fact that the readings were inaccurate and therefore,
the total amount on the Plaintiffs electricity bill was inaccurate; thereby, rendering the rate
charged to the Plaintiff different from the rates approved by the Public Service Commission
("PSC"). The inaccurate readings gave rise to an inaccurate total amount on the electricity bill and
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an inaccurate rate, which led Georgia Power to disconnect Plaintiff's electricity wrongfully and/or
illegally violating Plaintiff's rights to Life, Liberty and the pursuit of Happiness. In addition, by
preventing and refusing Plaintiff to make a payment on her existing Geogia Power account,
Georgia Power is also refusing to provide electricity services to Plaintiff and is, thereby, violating
Plaintiff's rights to Life, Liberty and the pursuit of Happiness. Furthermore, by refusing to
reconnect electricity service to Plaintiff's primary home, Georgia Power is also violating Plaintiff's
rights to Life, Liberty and the pursuit of Happiness and is exhibiting a lack of Morals in view of
their continued refusal to acknowledge their error and their act of depriving Plaintiff of electricity
without a rightful, lawful, and legal reason since Plaintiff is willing to pay her past due electricity
bill under her existing account number.
Defendant Georgia Power has violated Plaintiffs unalienable rights under the 14th
Amendment and under the second paragraph of the American Declaration of Independence by
wrongfully and/or illegally disconnecting electricity at Plaintiffs home, thereby, violating
Plaintiffs rights to due process and to Life, Liberty and the pursuit of Happiness.
E. 14TH AMENDMENT AND THE DECLARATION OF INDEPENDANCE
The 14th Amendment - governs regulation of business enterprises: rates, charges, and
conditions of service ''Business Affected With a Public Interest''.
Plaintiff re-alleges and incorporates each and every paragraph of this PLAINTIFF'S
RESPONSE AND OBJECTIONS TO THE FINAL REPORT AND RECOMMENDATION,
ORDER ISSUED IN RELATION TO PLAINTIFF'S ORIGINAL COMPLAINT, INJUNCTION
FOR RELIEF, AND DECLARATORY JUDGMENT, AND MOTION TO RECONSIDER
MOTION TO PROCEED IN FORMA PAUPERIS as well as the PLAINTIFF'S ORIGINAL
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COMPLAINT, INJUNCTION FOR RELIEF, AND DECLARATORY JUDGMENT (case
number 1:22-CV-2297) and the facts as if set forth here in full for all purposes.
The 14th Amendment Section 1 states that "All persons born or naturalized in the United
States, and subject to the jurisdiction thereof, are citizens of the United States and the State wherein
they reside. No State shall make or enforce any law which shall abridge the privileges or
immunities of citizens of the United States; nor shall any State deprive any person of life, liberty,
or property, without due process of law; nor deny to any person within its jurisdiction the equal
protection of the laws. The 14th Amendment governs regulation of business enterprises: rates,
charges, and conditions of service '' Business Affected With a Public Interest''. Defendant Georgia
Power is a "Business Affected With a Public Interest" as defined in the Fourteenth Amendment
Rights Guaranteed Privileges And Immunities of Citizenship, Due Process And Equal Protection.
In Munn v. Illinois, the first of the "Granger Cases," in which maximum charges
established by a state legislature for Chicago grain elevator companies were challenged, not as
being confiscatory in character, but rather as a regulation beyond the power of any state agency to
impose, the Court, in an opinion that was largely dictum, declared that the due process clause did
not operate as a safeguard against oppressive rates, that if regulation was permissible, the severity
thereof was within legislative discretion and could be ameliorated only by resort to the polls. Not
much time elapsed, however, before the Court effected a complete withdrawal from this position.
By 1890, it had fully converted the due process clause into a positive restriction which the judicial
branch was duty bound to enforce whenever state agencies sought to impose rates which, in its
estimation, were arbitrary or unreasonable.
Plaintiff asserts in Counts 1 through 5, taken together, that the rates that she was charged
were arbitrary and/or unreasonable, due to the fact that the readings were inaccurate and therefore,
29 of 49
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the total amount on the Plaintiff's electricity bill was inaccurate; thereby, rendering the rate
charged to the Plaintiff different from the rates approved by the Public Service Commission
("PSC"). The inaccurate readings gave rise to an inaccurate total amount on the electricity bill and
an inaccurate rate, which led Georgia Power to disconnect Plaintiff's electricity wrongfully and/or
illegally violating Plaintiff's rights to Life, Liberty and the pursuit of Happiness. In addition, by
preventing and refusing Plaintiff to make a payment on her existing Geogia Power account,
Georgia Power is also refusing to provide electricity services to Plaintiff and is, thereby, violating
Plaintiffs rights to Life, Liberty and the pursuit of Happiness. Furthermore, by refusing to
reconnect electricity service to Plaintiffs primary home, Georgia Power is also violating Plaintiffs
rights to Life, Liberty and the pursuit of Happiness.
Defendant Georgia Power has violated Plaintiffs unalienable rights under the second
paragraph of the American Declaration of Independence by wrongfully and/or illegally
disconnecting electricity at Plaintiffs home; thereby, violating Plaintiffs right to Life, Liberty and
the pursuit of Happiness. ·
The 14th Amendment - Public Health, Safety, and Morals
Plaintiff re-alleges and incorporates each and every paragraph of this PLAINTIFF'S
RESPONSE AND OBJECTIONS TO THE FINAL REPORT AND RECOMMENDATION,
ORDER ISSUED IN RELATION TO PLAINTIFF'S ORIGINAL COMPLAINT, INJUNCTION
FOR RELIEF, AND DECLARATORY JUDGMENT, AND MOTION TO RECONSIDER
MOTION TO PROCEED IN FORMA PAUPERIS as well as the PLAINTIFF'S ORIGINAL
COMPLAINT, INJUNCTION FOR RELIEF, AND DECLARATORY JUDGMENT (case
number I :22-CV-2297) and the facts as if set forth here in full for all purposes.
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The 14th Amendment also applies to Health, Safety, and Morals. The Fourteenth
Amendment Rights Guaranteed Privileges And Immunities of Citizenship, Due Process And Equal
Protection states that "Even under the narrowest concept of the police power as limited by
substantive due process, it was generally conceded that states could exercise the power to protect
the public health, safety, and morals.
Plaintiff asserts in Counts I though 5, taken together, that Georgia Power violated
Plaintiffs 14th Amendment by wrongfully and illegally disconnecting the electricity. The National
Association for the Advancement of Colored People ("NAACP") recently released a report called
Lights Out in the Cold, Reforming Utility Shut-Off Policies as if Human Rights Matter. Plaintiff's
assertions that electricity and its related services are a basic human right is supported by the
NAACP research. Plaintiff asserts that access to electricity is a critical component to the
prosperity, safety and general well-being of every human being, which is also supported by the
NAACP's research. Without electricity, Plaintiff is unable to have access to adequate food, health,
and safety. The NAACP research report can be found at https://naacp.org/resources/lights-out-
cold.
Plaintiff asserts in Counts I through 5, taken together, that the rates that she was charged
were arbitrary and/or unreasonable, due to the fact that the readings were inaccurate and therefore,
the total amount on the Plaintiffs electricity bill was inaccurate; thereby, rendering the rate
charged to the Plaintiff different from the rates approved by the Public Service Commission
("PSC"). The inaccurate readings gave rise to an inaccurate total amount on the electricity bill and
an inaccurate rate, which led Georgia Power to disconnect Plaintiff's electricity wrongfully and/or
illegally violating Plaintiff's rights to Life, Liberty and the pursuit of Happiness. In addition, by
preventing and refusing Plaintiff to make a payment on her existing Geogia Power account,
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Georgia Power is also refusing to provide electricity services to Plaintiff and is, thereby, violating
Plaintiff's rights to Life, Liberty and the pursuit of Happiness. Furthermore, by refusing to
reconnect electricity service to Plaintiff's primary home, Georgia Power is also violating Plaintiff's
rights to Life, Liberty and the pursuit of Happiness and is exhibiting a lack of Morals in view of
their continued refusal to acknowledge their error and depriving Plaintiff of electricity without
reason since Plaintiff is willing to pay her past due electricity bill under her existing account.
Defendant Georgia Power has violated Plaintiff's unalienable rights under the second
paragraph of the American Declaration of Independence by wrongfully and/or illegally
disconnecting electricity at Plaintiff's home, thereby, violating Plaintiff's right to Life, Liberty and
the pursuit of Happiness.
The United States Declaration oflndependence
Plaintiff re-alleges and incorporates each and every paragraph of this PLAINTIFF'S
RESPONSE AND OBJECTIONS TO THE FINAL REPORT AND RECOMMENDATION,
ORDER ISSUED IN RELATION TO PLAINTIFF'S ORIGINAL COMPLAINT, INJUNCTION
FOR RELIEF, AND DECLARATORY JUDGMENT, AND MOTION TO RECONSIDER
MOTION TO PROCEED IN FORMA PAUPERIS as well as the PLAINTIFF'S ORIGINAL
COMPLAINT, INJUNCTION FOR RELIEF, AND DECLARATORY JUDGMENT (case
number 1:22-CV-2297) and the facts as if set forth here in full for all purposes.
The Declaration of Independence (US 1776) states that "We hold these truths to be self-
evident, that all men are created equal, that they are endowed by their Creator with certain
unalienable Rights, that among these are Life, Liberty and the pursuit ofHappiness.--That to secure
these rights, Governments are instituted among Men, deriving their just powers from the consent
of the governed, --That whenever any Form of Government becomes destructive of these ends, it
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is the Right of the People to alter or to abolish it, and to institute new Government, laying its
foundation on such principles and organizing its powers in such form, as to them shall seem most
likely to effect their Safety and Happiness."
Plaintiff asserts in Counts I through 5, taken together, that the rates that she was charged
were arbitrary and/or unreasonable, due to the fact that the readings were inaccurate and therefore,
the total amount on the Plaintiffs electricity bill was inaccurate; thereby, rendering the rate
charged to the Plaintiff different from the rates approved by the Public Service Commission
("PSC"). The inaccurate readings gave rise to an inaccurate total amount on the electricity bill and
an inaccurate rate, which led Georgia Power to disconnect Plaintiff's electricity wrongfully and/or
illegally violating Plaintiff's rights to Life, Liberty and the pursuit of Happiness. In addition, by
preventing and refusing Plaintiff to make a payment on her existing Geogia Power account,
Georgia Power is also refusing to provide electricity services to Plaintiff and is, thereby, violating
Plaintiff's rights to Life, Liberty and the pursuit of Happiness. Furthermore, by refusing to
reconnect electricity service to Plaintiff's primary home, Georgia Power is also violating Plaintiff's
rights to Life, Liberty and the pursuit of Happiness and is exhibiting a lack of Morals in view of
their continued refusal to acknowledge their error and depriving Plaintiff of electricity without
reason since Plaintiff is willing to pay her past dne electricity bill nnder her existing account.
Defendant Georgia Power has violated Plaintiff's unalienable rights under the second
paragraph of the American Declaration of Independence by wrongfully and/or illegally
disconnecting electricity at Plaintiff's home, thereby, violating Plaintiff's right to Life, Liberty and
the pursuit of Happiness.
Violation of the 14th Amendment and the Declaration of Independence
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Plaintiff re-alleges and incorporates each and every paragraph of this PLAINTIFF'S
RESPONSE AND OBJECTIONS TO THE FINAL REPORT AND RECOMMENDATION,
ORDER ISSUED IN RELATION TO PLAINTIFF'S ORIGINAL COMPLAINT, INJUNCTION
FOR RELIEF, AND DECLARATORY JUDGMENT, AND MOTION TO RECONSIDER
MOTION TO PROCEED IN FORMA PAUPERIS as well as the PLAINTIFF'S ORIGINAL
COMPLAINT, INJUNCTION FOR RELIEF, AND DECLARATORY JUDGMENT (case
number l:22-CV-2297) and the facts as if set forth here in full for all purposes.
Electricity is required for light, heat, cooling, and cooking. Electricity is also needed to
operate phones, internet, TV, and computer for personal user or professional use. Light, heat,
cooling, and cooking are basic rights that enables the pursuit of happiness, life, and liberty. If every
person is afforded an opportunity to have electricity, a publicly regulated resource, it is ensured
that his or her rights to pursue happiness are not violated.
Plaintiff asserts in Counts I through 5, taken together, that the rates that she was charged
were arbitrary and/or unreasonable, due to the fact that the readings were inaccurate and therefore,
the total amount on the Plaintiffs electricity bill was inaccurate; thereby, rendering the rate
charged to the Plaintiff different from the rates approved by the Public Service Commission
("PSC"). The inaccurate readings gave rise to an inaccurate total amount on the electricity bill and
an inaccurate rate, which led Georgia Power to disconnect Plaintiffs electricity wrongfully and/or
illegally violating Plaintiffs rights to Life, Liberty and the pursuit of Happiness. In addition, by
preventing and refusing Plaintiff to make a payment on her existing Geogia Power account,
Georgia Power is also refusing to provide electricity services to Plaintiff and is, thereby, violating
Plaintiffs rights to Life, Liberty and the pursuit of Happiness. Furthermore, by refusing to
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reconnect electricity service to Plaintiff's primary home, Georgia Power is also violating Plaintiff's
rights to Life, Liberty and the pursuit of Happiness.
Defendant Georgia Power has violated Plaintiffs unalienable rights under the second
paragraph of the American Declaration of Independence by wrongfully and/or illegally
disconnecting electricity at Plaintiffs home, thereby, violating Plaintiffs right to Life, Liberty and
the pursuit of Happiness.
F. JURISDICTION AND VENUE
The Plaintiffs case falls under the following U.S. Civil Statutes.
a. State of Georgia Subject 515-3-2 Residential Electric And Gas Utility
Service Disconnections
b. State of Georgia Rule 515-3-2-.02 Limitations on Disconnection,
c. State of Georgia Rule 515-3-2-.04 Seasonal Restrictions,
d. State of Georgia Rule 515-3-2-.06 Right of the Customer,
e. 14th Amendment Section 1,
f. The Declaration of Independence (US 1776) - Regulation of Business
Enterprises: Rates, Charges, and Conditions of Service "Business Affected With a Public
Interest'',
g. The Declaration ofindependence (US 1776) - Health, Safety, and Morals.
The jurisdiction and venue are appropriate for the reasons listed below and as restated from
the Plaintiffs Original Complaint, Injunction For Relief, And Declaratory Judgement.
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27. This Court has subject matter jurisdiction over this case because the Plaintiffs
claims arise under the laws of the State of Georgia and the United States. [t has jurisdiction over
the Plaintiffs state law and regulations claims because they are so closeJy related to the federal
claims as. to form part of lhe same case or controversy. The Northern District of Georgia consists
of four (4) divisions as outlined and described in 28 U.S.C. § 90. The Atlanta Division comprises
the counties of Cherokee, Clayton, Cobb. DeKalb, Douglas, Fulton, Gwinnett, Henry, Newlon~
and Rockdale.
28. Pursuant to 28 U.S. Code§ 1391. a civil action may be brought in ajudicial district
in which a substantial part of the events or omissions giving rise to the claim occurred, or a
substantial part of property that is the subject of the aclion is situated. Georgia Power provides
electricity service to PlainliIT in Fulton County, Atlanta, GA 30309.
29. Pursuant lo 28 U.S. Code § 1391, for purposes of venue in a Stale, which has more
than one judicial district and in which a defendanl that is a corporation is subject lo personal
jurisdiction at the time an action is commenced, such corporation shall be deemed to reside in any
district in that S1a[e within which its contacts would be sufficient to subject it to personal
jurisdiction if that district were a sepamte State, and, if there is no such district, the corpomtion
shall be deemed to reside in the district within which it has the most significant contacts.
9of31
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30. Pm~u,ut 1018 U.!.. C.;,lt § 1343, CMI t'i~ilt. a11J cl~tiv~ frllilcil~, rli~ Nortlicr11
Dillrict Court of tlw: S!ati: of Goo1gl3 has autllOrity~
(I) To sCCO\'Ct' dai~uge:s lfa-: injmy co bl:i pcrsoi~ at' pro.p.::rt),\ or bcCil11SC oftlLt::
tkpri-.:atfor:1 of sny dgbt or privikse: .-of a dtizcn of tll.c United St:it-es~ by any act done In
futthcroncc of 2.ny •COJtif!it.::icy uw:ullo1L<:d in section 1985 of T:itf,c 41:
(2} To 1cco\'.l!f .daruaigcs from an:i,i p~rsm1 who fails ~o ptt\'ctlt 01 to aid in
p.rcVi.!:..ILti1~s. any ,•uongs me.utim1cd in s0i::1ioo 1985 of Title 42 wlbic1, he had l:nowlOO_g-c
"\\iett about to occur and power w p1cv~11t_~
(3) To t1.Wc-.z. tlLC d-cptivatio11~ lllukt co.Jar of any State law~ s:tattnl!', airdilianc-c.
1cgttla•lo1~~ i:iust\'.un or USi!i_gc-. of any right, privikgc DL' immwhity SCl-."'1tl'---d by 1hc Cm1ssitu.tiou
of the United States or by ;:u~y Act' of Con!lJn.':ii pro•;jdfog fot -=-41.t:J.I righll.S of dtizcns or of
aU persons 'tvithin tlK:jurt:idiction of the Uuhcd Sutc~
(4) To recover dama£:,teS ~ to sc-cunl i:quirabk or ol:11.Cr L'dic:f wl.det ;111y A<:lof
Cangn::ss providi1lg for 1hc protection of dvH rights~ irn!luding tli.c rig.ha to vote;
(5) To cxo,ci,e SU<b otlm powoJS, oot con~"')' 10 tbo Constitutioll, as ore or
m.:ly be given to sul!h courts b:• la,.,.~
3 l. Venue ti proper in 1.his Cowt boo:1;11:S,(! all or n :,.ub.i.tan:tial part of:lhc corlducn ~md
1-o·iola.1.fons gj\•iug rise to 1hc daims i.tt Llte .ca;e occum..~ LR 11hc:- s.1:1tc of Ocorgia... Se~ O.C.G.A §
14'2-SlO, O.C.G.A ~ 9-10-91, O.C.G.A ~ 9--I0-93, O.C.G.A § 9-10-31, ~ndO.C.G.A § 9-ID-34.
32. Tltis Coun bas. personal jurisdletton .ovc.- Dt::fc:rtd:nn Georgia Power t.i«ausc::
O.::fondarit G~orgja Pov.•ct~ 1ttrough it:i a_g-tDIS oomm1utcd tile: ilCl!I !ba.1 a,,e nhe subject n11St~t' of
titis !awsuil in tlte State ofGoorgia. S"' O.C.G.A § 14-2-5!0, 0.C.G.A § 9--W-!ll. O.C.GA ! 9-
10-93, 0.C.G.A § 9--l0-31, and O.C.G.A § 9-10-34.
10of3-1
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]]. TI,is Court bas pct,ooal jmisdtdton o,,,,., Thfotdani Georgia Powct lliceahlsc
Ix:fci:1dan1 Georgia Power and its. agents. arul cmplo)'C'{:S, bavc ou_goiug.~uid sys11!matic ccntactts
Wllll lM :illllCO('JOOl]!,I~, lll:lllllllUI£ llC\llaguancr cmccs In UL'.! :;me UfCiCQtJ;l3, :mu rc.Jac In UlC
State of Gc-ac_gi!l.~ :llld'll!l\'C' 001ruuim::d the a.,cts that at~ a.he subject .1bUlttc1· of this lawsuit ins 1be
stale of Georgia.
J4. Venue is proper in tl,is Court be-cause Th::fcu,&mt G<:orgia Pow,,., is heodquartcl'l."'11
surl its principal plac~ afblliini:» is ku::atcd in Fulton County: Alkiuta:. Georgia.
35. Venue is proper in tbt:i Co11.rt bccal1.i.C Dcfcn.dant Georgia Pm\•ct•s L--OndJJ:(:l'i
substantial bttSincss ii, Fulton Cowlly, Atlanta, Georgia.
J6. Plaintiff Rais,a Djuissi IKcllJlll< lt:Ls standing to bring tl1isComptniat io Court
hcca:usc she \1,·il) be adversely :rlftttcd by the actions oft11c:: 0.cfatdiml :.md \\o·ill I>.! liubj~t lo
u.11.duc hillm ifDcfcndaJLt docs not rcsto1cckct.sicity at Plaintitr's under Plai111iff's a-croWli
numbc.r· 93437-55009. Pl:till'l1lff doL!S Jt.ot want a ,~~· numb~.
37. Acoo1di11gly, VCIIUO is properpurstt3nl lO 2R u_s.c. § 90, 28 lJ.S. Code§ 1391. 28
U.S. CO<!c § B43, and Grorsi• CML Prncticc and CotJ)OtalioJti, Perm,rship,. And Associaliou.s
Code§ [5-6-8. o_c.G.A § 14-2-510, O.C.G.A § 9-10-91. O.C.G.A § 9-l0-93, O.C.G.A § 9-!0-
31, O.C.G_A § 9-10-3-1.
G. IN FORMA PAUPERIS ("IFP")
Objections, Responses, and Arguments to Statement of Analysis I:
United Stated Magistrate Judge Catherine M. Salinas asserts in the Final Report And
Recommendation And Order issued in relation to the Plaintiff's Original Complaint, Injunction
For Relief, And Declaratory Judgment that "The affidavit of poverty submitted by Plaintiff
indicates that over the past twelve months, Plaintiff, has earned an average monthly income of
$7,500 from her employment and retirement, which amounts to $90,000 on an annual basis."
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The information and interpretations presented in the Report related to the Plaintiff's
financial situation are incomplete and are therefore not facts. Plaintiff's monthly income over the
past seven and a half(7.5) months is $0.00.
Plaintiff did not leave her job; Plaintiff was constructively discharged. The Occupational
Safety and Health Administration ("OSHA") defines Constructively Discharged as "quitting when
an employer makes working conditions intolerable due to the employees' protected activity)",
which Plaintiff performed as a Whistleblower and rendered a service to the community. Plaintiff
has opened a complaint with OSHA.
In addition, Plaintiff has provided in Exhibit I herein evidence showing that her home was
broken into, she was blacklisted from her industry, and prevented to find a job in line with her
qualifications due to the subject matter of case number 2022CV365268 filed in Fulton County
Superior Court.
Plaintiff has utilized all her retirement savings in order to pay for the security and safety of
her family, which is also related to the subject matter of case number 2022CV365268 filed in
Fulton County Superior Court. Therefore, the average monthly income of $7,500 from Plaintiff's
employment and retirement, does not reflect the fact that the money was used for safety and
security expenses in view of the threats Plaintiff and her family were faced with. Plaintiff's
priorities were and are perfectly aligned to the law of God and the thought process of any
reasonable person. In view of the subject matter in case number 2022CV365268, Plaintiff's family
came first and she spent a considerable amormt of money to ensure their security and safety.
Further, Plaintiff has provided in Exhibits 2 and 3 herein evidence that she was not able to
receive unemployment benefits since her constructive discharge on November 18th, 2022. The
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Plaintiff's lawsuit against ID.Me, Inc. is to allow Plaintiff to receive her unemployment benefits.
The Plaintiff lawsuit against ID.ME, Inc. is documented in case file number l:22-CV-2237.
Based on the information provided above, Plaintiff is unable to pay the legal filing fees
because she does not have any income and is being blacklisted from the industry she works in.
Objections, Responses, and Arguments Statement of Analysis 2:
United Stated Magistrate Judge Catherine M. Salinas asserts in the Final Report And
Recommendation And Order issued in relation to the Plaintiffs Original Complaint, Iajunction
For Relief, And Declaratory Judgment that "Before she left her most recent employment, she was
earning $9,583.00 per month."
The information and interpretations presented m the Report related to the Plaintiffs
financial situation are incomplete and are, therefore, not facts.
Plaintiff did not leave her job; Plaintiff was constructively discharged. The Occupational
Safety and Health Administration ("OSHA") defines Constructively Discharged as "quitting when
an employer makes working conditions intolerable due to the employees' protected activity)",
which Plaintiff perfonned as a Whistleblower and rendered a service to the community. Plaintiff
has filed a complaint with OSHA.
Plaintiffs monthly income over the past seven and a half(7.5) months is $0.00.
Plaintiff has utilized all her retirement savings, including her income she earned prior to
being constructively discharged, in order to pay for the security and safety of her family, which is
also related to the subject matter of case number 2022CV365268 filed in Fulton County Superior
Court. Therefore, the average monthly income of $7,500 from Plaintiff's employment and
retirement, does not reflect that the money was used for safety and security in view of the threats
Plaintiff and her family were facing. Plaintiff's priorities were and are perfectly aligned to the law
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of God and the thought process of any reasonable person. In view of the subject matter in case
number 2022CV365268, Plaintiffs family came first and she spent a considerable amount of
money to ensure their security and safety.
Further, Plaintiff has provided in Exhibits 2 and 3 herein evidence showing that she was
not able to receive unemployment benefits since her constructive discharge on November 18th,
2022. The Plaintiffs lawsuit against ID.Me, Inc. is to allow Plaintiff to receive her unemployment
benefits.
Based on the information provided above, Plaintiff is unable to pay the legal filing fees
because she does not have any income and is being blacklisted from the industry she works in.
Objections, Responses, and Arguments Statement of Analysis 3:
United Stated Magistrate Judge Catherine M. Salinas asserts in the Final Report And
Recommendation And Order issued in relation to the Plaintiffs Original Complaint, Injunction
For Relief, And Declaratory Judgment that Plaintiff "owns a condominium valued at
approximately $500,000, a land lot worth $55,000, and an abandoned house worth approximately
$200,000."
The facts presented in the Report related to the Plaintiffs financial situation are
incomplete. Plaintiffs liabilities on the properties listed, particularly the condominium, the land,
and the abandoned house as well as the state of pre-foreclosure on certain of the said properties
were not taken into consideration by the Judge of the Magistrate Conrt. Plaintiff does not have
significant equity in the land and the house. Due to the foreclosure process, Plaintiff may not
receive any funds from the sale of those properties.
Plaintiff has provided in Exhibit 4 herein evidence showing that the said properties are at
risk of foreclosure. The abandoned and inhabitable house worth approximately $200,000 is
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mortgaged with Delta Community Credit Union. The land lot worth approximately $55,000 is
mortgaged with AGSOUTH Farm Credit, ACA. Both properties are under foreclosure notices as
shown in Exhibit 4.
Plaintiffs main asset is the condominium with a value of approximately $500,000, which
is Plaintiffs primary residence and is subject to a mortgage that Plaintiff is also unable to pay due
to the subject matter of case number 2022CV365268 filed in Fulton County Superior Court.
In addition, Plaintiff has provided in Exhibit 2 herein evidence showing that her home was
broken into, she was blacklisted from her industry, and prevented to find a job in line with her
qualifications due to the subject matter of case number 2022CV365268 filed in Fulton County
Superior Court.
Further, Plaintiff has provided in Exhibits 2 and 3 herein evidence showing that she was
not able to receive unemployment benefits since her constructive discharge on November 18th,
2022. The Plaintiffs lawsuit against ID.Me, Inc. is to allow Plaintiff to receive her unemployment
benefits.
Based on the information provided above, Plaintiff is unable to pay the legal filing fees
because she does not have any income and is being blacklisted from the industry she works in.
Objections, Responses, and Arguments Response To Statement of Analysis 4:
United Stated Magistrate Judge Catherine M. Salinas asserts in the Final Report And
Recommendation And Order issued in relation to the Plaintiffs Original Complaint, Injunction
For Relief, And Declaratory Judgment that "Plaintiffs allegations of poverty are not fully
supported by the record. With an annual income of approximately $90,000, Plaintiff is well above
the poverty level."
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The information and interpretations presented in the Report related to the Plaintiffs
financial situation are incomplete and are therefore not facts. Plaintiffs monthly income over the
past seven and a half (7.5) months is $0.00.
Plaintiff did not leave her job; Plaintiff was constructively discharged. The Occupational
Safety and Health Administration ("OSHA") defines Constructively Discharged as "quitting when
an employer makes working conditions intolerable due to the employees' protected activity)",
which Plaintiff performed as a Whist!eblower and rendered a service to the community. Plaintiff
has filed a complaint with OSHA.
In addition, Plaintiff has provided in Exhibit 2 herein evidence showing that her home was
broken into, she was blacklisted from her industry, and prevented to find a job in line with her
qualifications due to the subject matter of case number 2022CV365268 filed in Fulton Cow1ty
Superior Court.
Plaintiff has utilized all her retirement savings in order to pay for the security and safety of
her family, which is also related to the subject matter of case number 2022CV365268 filed in
Fulton County Superior Court. Therefore, the average monthly income of $7,500 from Plaintiff's
employment and retirement, does not reflect that the money was used for safety and security in
view of the threats Plaintiff and her family were faced with. Plaintiff's priorities were and are
perfectly aligned to the law of God and the thought process of any reasonable person. In view of
the subject matter in case number 2022CV365268, Plaintiff's family came first and she spent a
considerable amount of money to ensure their security and safety.
Further, Plaintiff has provided in Exhibits 2 and 3 herein evidence that she was not able to
receive unemployment benefits since her constructive discharge on November 18th, 2022. The
Plaintiff's lawsuit against ID.Me, Inc. is to allow Plaintiff to receive her unemployment benefits.
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Based on the information provided above, Plaintiff is unable to pay the legal filing fees
because she does not have any income and is being blacklisted from the industry she works in.
Objections, Responses. and Arguments To Statement of Analysis 5:
United Stated Magistrate Judge Catherine M. Salinas asserts in the Final Report And
Recommendation And Order issued in relation to the Plaintiffs Original Complaint, Injunction
For Relief, And Declaratory Judgment that "Although Plaintiff lists average monthly expenses of
$13,125.00, some of the discretionary amounts for one person seem unnecessarily high, such as
$1,000 for food, $200 for laundry and dry cleaning, and $6,000 in monthly credit card installment
payments to Bank of America, Citi Bank, and American Express. Although Plaintiff may have
limited funds and may have other priorities for those funds, I believe that she is able to pay the
required $402 filing fee and should do so of she wishes to pursue this case. For the reasons stated,
I find thar Plaintiff has sufficient means to pay the filing fee and incur the costs of these
proceedings. Thus, Plaintiff's request to proceed IFP is DENIED."
Plaintiff $1,000 for food would include all her grocery items, including toilet paper and
cleaning products, which is not uncommon in the city where Plaintiff lives.
Plaintiff's expense for laundry and dry-cleaning amounting to approximately $200 was
prior to her constructive discharge on November 18th, 2022 as shown in Exhibit 3. Since then,
Plaintiff has focused her efforts into ensuring the security and safety of her family. Plaintiff is now
looking for justice for herself and her family.
Plaintiffs monthly income over the past seven and a half (7.5) months is $0.00.
Plaintiff did not leave her job; Plaintiff was constructively discharged. The Occupational
Safety and Health Administration ("OSHA") defines Constructively Discharged as "quitting when
an employer makes working conditions intolerable due to the employees' protected activity)",
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which Plaintiff performed as a Whistleblower and rendered a service to the community. Plaintiff
has opened a complaint with OSHA. Plaintiff has filed a complaint with OSHA.
In addition, Plaintiff has provided in Exhibit 2 herein evidence showing that her home was
broken into, she was blacklisted from her industry, and prevented to find a job in line with her
qualifications due to the subject matter of case number 2022CV365268 filed in Fulton County
Superior Court.
Plaintiff has utilized all her retirement savings in order to pay for the security and safety of
her family, which is also related to the subject matter of case number 2022CV365268 filed in
Fulton County Superior Court. Therefore, the average monthly income of $7,500 from Plaintiff's
employment and retirement, does not reflect that the money was used for safety and security in
view of the threats Plaintiff and her family were faced with. Plaintiff's priorities were and are
perfectly aligned to the law of God and the thought process of any reasonable person. In view of
the subject matter in case number 2022CV365268, Plaintiff's family came first and she spent a
considerable amount of money to ensure their security and safety.
Further, Plaintiff has provided in Exhibit 3 herein evidence that she was not able to receive
unemployment benefits since her constructive discharge on November 18th, 2022. The Plaintiff's
lawsuit against ID.Me, Inc. is to allow Plaintiff to receive her unemployment benefits. Based
on the information provided above, Plaintiff is unable to pay the legal filing fees because she does
not have any income and is being blacklisted from the industry she works in.
Objections, Responses, and Arguments To Statement of Analysis 6:
United Stated Magistrate Judge Catherine M. Salinas asserts in the Final Report And
Recommendation And Order issued in relation to the Plaintiff's Original Complaint, Injunction
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For Relief, And Declaratory Judgment that "Before she left her most recent employment, she was
earning $9,583.00 per month."
The information and interpretations presented in the Report related to the Plaintiffs
financial situation are incomplete and are, therefore, not facts.
Plaintiff did not leave her job; Plaintiff was constructively discharged. The Occupational
Safety and Health Administration ("OSHA") defines Constructively Discharged as "quitting when
an employer makes working conditions intolerable due to the employees' protected activity)",
which Plaintiff performed as a Whistleblower and rendered a service to the community. Plaintiff
has opened a complaint with OSHA.
Plaintiffs monthly income over the past seven and a half(7.5) months is $0.00.
Plaintiff has utilized all her retirement savings, including her income she earned prior to
being constructively discharged, in order to pay for the security and safety of her family, which is
also related to the subject matter of case number 2022CV365268 filed in Fulton County Superior
Court. Therefore, the average monthly income of $7,500 from Plaintiff's employment and
retirement, does not reflect that the money was used for safety and security in view of the threats
Plaintiff and her family were facing. Plaintiff's priorities were and are perfectly aligned to the law
of God and the thought process of any reasonable person. In view of the subject matter in case
number 2022CV365268, Plaintiff's family came first and she spent a considerable amount of
money to ensure their security and safety.
Further, Plaintiff has provided in Exhibit 3 herein evidence that she was not able to receive
unemployment benefits since her constructive discharge on November 18th, 2022. The Plaintiff's
lawsuit against ID.Me, Inc. is to allow Plaintiff to receive her unemployment benefits.
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On December 6, 2019, the Second Circuit (Calabresi, Pooler, Park) issued a published per
curiam decision in United States v. Kosic (Nunez), concerning the defendant-appellant's motion
for in forma pauperis ("IFP") status in his direct criminal appeal. The appellant's motion arose
from a district court order denying his IFP motion based on a finding that the appeal would be
frivolous pursuant to 28 U.S.C. §1915. In its published decision, the Second Circuit granted the
motion and held that it is proper to consider only the defendant's financial eligibility-and not the
merits-when deciding motions for IFP status and appointment of counsel under the Criminal
Justice Act ("CJA") in a direct criminal appeal.
As the Court explained, a litigant seeking IFP status on appeal generally must first seek a
ruling in the district court. If the district court denies the motion and finds that an appeal cannot be
taken in good faith, then the defendant may seek an IFP determination from the appellate court.
When the appellate court reviews such motions, it applies different standards depending on
whether the case is civil or criminal. In the civil context, the Court considers the merits of an
appeal.
Plaintiff has provided in Exhibit 5 evidence showing her expenses and that she could no
longer draw from her credit cards.
Plaintiff has provided herein evidence that her request to proceed in IFP was not frivolous
or malicious. Based on the information and documents provided herein, Plaintiff is unable to pay
the legal filing fees because she does not have any income and is being blacklisted from the
industry she works in.
Plaintiffs Request Related To Her Motion To Proceed in Forma Pauperis
Plaintiff hereby requests that her motion to proceed in IFP be reconsidered by the Court
for her case against Georgia Power (I :22-CV-2297) as well as her cases against ID.ME, Inc. (case
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file number 1:22-CV-2237), and AGSOUTH FARM CREDIT, ACA (case file number l:22-CV-
2263).
CERTIFICATION
Under Federal Rule of Civil Procedure 11, I certify to the best of my knowledge,
information, and belief that this complaint: (I) is not being presented for an improper purpose,
such as to harass, cause unnecessary delay, or needlessly increase the cost of litigation; (2) is
supported by existing law or by a nonfrivolous argument for extending, modifying, or reversing
existing law; (3) the factual contentions have evidentiary support or, if specifically so identified,
will likely have evidentiary support after a reasonable oppo~nity for further investigation or
discovery; and (4) the complaint otherwise complies with the requirements of Rule 11.
I agree to provide the Clerk's Office with any changes to my address where case related
papers may be served. I understand that my failure to keep a current address on file with the Clerk's
Office may result in the dismissal of my case.
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CONCLUSION
For the foregoing reasons, the referenced Final Report And Recommendation And Order
issued in relation to the Plaintiffs Original Complaint, Injunction For Relief, And Declaratory
Judgment should not be adopted to the extent it recommends that Plaintiffs complaint be
dismissed for lack of subject matter jurisdiction.
Dated: June 21, 2022
Respectfully submitted,
Physical Address: Raissa Djuissi Kengne
1280 W. Peachtree ST NW. Unit 2109 Pro Se
Atlanta, GA 30309
Mailing Address:
Telephone: (404) 932-1651 570 Piedmont Ave. NE #55166
Email: cianeseya2022@gmail.com Atlanta, GA 30308
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R.EO 11C CW!K'S OFFICE
U.S.O,C. -Al\a!lta
EYlklllt ~~
UNITED STATES DISTRICT COURT JUL O\ 2022
FOR THE NORTHERN DISTRICT OF GEORG A
ATLANTA DIVISION
) Case No. 1:22-CV-2297
)
RAISSA DJUISSI KENGNE, )
Plaintiff, )
)
v. )
ID.ME,INC. )
COGENCY GLOBAL INC. )
250 BROWNS HILL CT, )
MIDLOTHIAN, VA, 23114- 9510, USA )
)
Defendant. )
PLAINTIFF'S MOTION FOR RECONSIDERATION OF PLAINTIFF'S
MOTION TO PROCEED IN FORMA PAUPERIS
TO THE HONORABLE ITJDGE OF SAID COURT:
Comes Now, PLAINTIFF, RAISSA DJUISSI KENGNE ("Plaintiff'') who files this Plaintiff's
Motion For Reconsideration of Plaintiffs Motion To Proceed In Forma Pauperis ("IFP"), and
moves this Court to reconsider its denying of the Plaintiffs motion to proceed in IFP.
A motion for reconsideration is not a form of relief explicitly recognized by the Federal Rules of
Civil Procedure. While not specifically mentioned in the Rules, motions seeking to have the court
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reconsider an earlier ruling typically are considered pursuant to Federal Rule of Civil Procedure
59 and/or 60. Plaintiff, therefore, requests that the Court reconsiders Plaintiffs Motion to Proceed
in IFP pursuant to Rule 59, 60, and 24 of the Federal Rules of Civil Procedure. The Court, in
rendering its order, has overlooked the material facts in the record presented herein.
OBJECTIONS, RESPONSES, AND ARGUMENTS TO IN FORMA PAUPERIS ("IFP")
DECISION
Objections, Responses, and Arguments to Statement of Analysis 1:
United Stated Magistrate Judge Catherine M. ]3alinas asserts in the Final Report And
Recommendation And Order issued in relation to the Plaintiffs Original Complaint, Injunction
For Relief, And Declaratory Judgment that "The affidavit of poverty submitted by Plaintiff
indicates that over the past twelve months, Plaintiff, has earned an average monthly income of
$7,500 from her employment and retirement, which amounts to $90,000 on an annual basis."
The information and interpretations presented in the Report related to the Plaintiffs
financial situation are incomplete and are therefore not facts. Plaintiffs monthly income over the
past seven and a half (7.5) months is $0.00.
Plaintiff did not leave her job; Plaintiff was constructively discharged. The Occupational
Safety and Health Administration ("OSHA") defines Constructively Discharged as "quitting when
an employer makes working conditions intolerable due to the employees' protected activity)",
which Plaintiff performed as a Whistleblower and rendered a service to the community. Plaintiff
has opened a complaint with OSHA.
In addition, Plaintiff has provided in Exhibit I herein evidence showing that her home was
broken into, she was blacklisted from her industry, and prevented to find a job in line with her
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qualifications due to the subject matter of case number 2022CV365268 filed in Fulton County
Superior Court.
Plaintiff has utilized all her retirement savings in order to pay for the security and safety of
her family, which is also related to the subject matter of case number 2022CV365268 filed in
Fulton County Superior Court. Therefore, the average monthly income of $7,500 from Plaintiff's
employment and retirement, does not reflect the fact that the money was used for safety and
security expenses in view qf the threats Plaintiff and her family were faced with. Plaintiffs
priorities were and are ·perfectly aligned to the law of God and the thought process of any
reasonable person. In view of the subject matter in case number 2022CV365268, Plaintiffs family
came first and she spent a considerable amount of money to ensure their security and safety.
Further, Plaintiff has provided in Exhibits 2 and 3 herein evidence that she was not able to
receive unemployment benefits since her constructive discharge on November I 8th, 2022. The
Plaintiff's lawsuit against ID.Me, Inc. is to allow Plaintiff to receive her unemployment benefits.
The Plaintiff lawsuit against ID.ME, Inc. is documented in case file number l:22-CV-2237.
Based on the information provided above, Plaintiff is unable to pay the legal filing fees
because she does not have any income and is being blacklisted from the industry she works in.
Objections, Responses, and Arguments Statement of Analysis 2:
United Stated Magistrate Judge Catherine M. Salinas asserts in the Final Report And
Recommendation And Order issued in relation to the Plaintiffs Original Complaint, Injunction
For Relief, And Declaratory Judgment that "Before she left her most recent employment, she was
earning $9,583.00 per month."
The information and interpretations presented in the Report related to the Plaintiffs
financial situation are incomplete and are, therefore, not facts.
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Plaintiff did not leave her job; Plaintiff was constructively discharged. The Occupational
Safety and Health Administration ("OSHA") defines Constructively Discharged as "quitting when
an employer makes working conditions intolerable due to the employees' protected activity)",
which Plaintiff performed as a Whistleblower and rendered a service to the community. Plaintiff
has filed a complaint with OSHA.
Plaintiffs monthly income over the past seven and a half(7.5) months is $0.00.
Plaintiff has utilized all her retirement savings, including her income she earned prior to
being constructively discharged, in order to pay for the security and safety of her family, which is
also related to the subject matter of case number 2022CV365268 filed in Fulton County Superior
Court Therefore, the average monthly income of $7,500 from Plaintiff's employment and
retirement, does not reflect that the money was used for safety and security in view of the threats
Plaintiff and her family were facing. Plaintiff's priorities were and are perfectly aligned to the law
of God and the thought process of any reasonable person. In view of the subject matter in case
number, 2022CV365268, Plaintiff's family came first and she spent a considerable amount of
money to ensure their security and safety.
Further, Plaintiff has provided in Exhibits 2 and 3 herein evidence showing that she was
not able to receive unemployment benefits since her constructive discharge on November 18th,
2022. The Plaintiff's lawsuit against ID.Me, Inc. is to allow Plaintiff to receive her unemployment
benefits.
Based on the information provided above, Plaintiff is unable to pay the legal filing fees
because she does not have any income and is being blacklisted from the industry she works in.
Objections, Responses, and Arguments Statement of Analysis 3:
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United Stated Magistrate Judge Catherine M. Salinas asserts in the Final Report And
Recommendation And Order issued in relation to the Plaintiffs Original Complaint, Injunction
For Relief, And Declaratory Judgment that Plaintiff "owns a condominium valued at
approximately $500,000, a land lot worth $55,000, and an abandoned house worth approximately
$200,000."
The facts presented in the Report related to the Plaintiffs financial situation are
incomplete. Plaintiffs liabilities on the properties listed, particularly the condominium, the land,
and the abandoned house as well as the state of pre-foreclosure on certain of the said properties
were not taken into consideration by the Judge of the Magistrate Court. Plaintiff does not have
significant equity in the land and the house. Due to the foreclosure process, Plaintiff may not
receive any funds from the sale of those properties.
Plaintiff has provided in Exhibit 4 herein evidence showing that the said properties are at
risk of foreclosure. The abandoned and inhabitable house worth approximately $200,000 is
mortgaged with Delta Community Credit Union. The land lot worth approximately $55,000 is
mortgaged with AGSOUTH Farm Credit, ACA. Both properties are under foreclosure notices as
shown in Exhibit 4.
Plaintiff's.main asset is the condominium with a value of approximately $500,000, which
is Plaintiff's primary residence and is subject to a mortgage that Plaintiff is also unable to pay due
to the subject matter of case number 2022CV365268 filed in Fulton County Superior Court.
In addition, Plaintiff has provided in Exhibit 2 herein evidence showing that her home was
broken into, she was blacklisted from her industry, and prevented to find a job in line with her
qualifications due to the subject matter of case number 2022CV365268 filed in Fulton County
Superior Court.
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Further, Plaintiff has provided in Exhibits 2 and 3 herein evidence showing that she was
not able to receive unemployment benefits since her constructive discharge on November 18th,
2022. The Plaintiff's lawsuit against ID.Me, Inc. is to allow Plaintiff to receive her unemployment
benefits.
Based on the information provided above, Plaintiff is unable to pay the legal filing fees
because she does not have any income and is being blacklisted from the industry she works in.
Objections, Responses, and Arguments Response To Statement of Analysis 4:
United Stated Magistrate Judge Catherine M. Salinas asserts in the Final Report And
Recommendation And Order issued in relation to the Plaintiffs Original Complaint, Injunction
For Relief, And Declaratory Judgment that "Plaintiff's allegations of poverty are not fully
supported by the record. With an annual income of approximately $90,000, Plaintiff is well above
the poverty level."
The information and interpretations presented in the Report related to the Plaintiff's
financial situation are incomplete and are therefore not facts. Plaintiffs monthly income over the
past seven and a half (7.5}months is $0.00.
Plaintiff did not leave her job; Plaintiff was constructively discharged. The Occupational
Safety and Health Administration ("OSHA") defines Constructively Discharged as "quitting when
an employer makes working conditions intolerable due to the employees' protected activity)",
which Plaintiff performed as a Whistleblower and rendered a service to the community. Plaintiff
has filed a complaint with OSHA.
In addition, Plaintiff has provided in Exhibit 2 herein evidence showing that her home was
broken into, she was blacklisted from her industry, and prevented to find a job in line with her
6 of 19
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 113 of 134
qualifications due to the subject matter of case number 2022CV365268 filed in Fulton County
Superior Court.
Plaintiff has utilized all her retirement savings in order to pay for the security and safety of
her family, which is also related to the subject matter of case number 2022CV365268 filed in
Fulton County Superior Court. Therefore, the average monthly income of $7,500 from Plaintiff's
employment and retirement, does not reflect that the money was used for safety and security in
view of the threats Plaintiff and her family were faced with. Plaintiff's priorities were and are
perfectly aligned to the law of God and the thought process of any reasonable person. In view of
the subject matter in case number 2022CV365268, Plaintiff's family came first and she speµt a
considerable amount of money to ensure their security and safety.
Further, Plaintiff has provided in Exhibits 2 and 3 herein evidence that she was not able to
receive unemployment benefits since her constructive discharge on November 18th, 2022. The
Plaintiff's lawsuit against ID.Me, Inc. is to allow Plaintiff to receive her unemployment benefits.
Based on the information provided above, Plaintiff is unable to pay the legal filing fees
because she does not have any income and is being blacklisted from the industry she works in.
Objections, Responses, and Arguments To Statement of Analysis 5:
United Stated Magistrate Judge Catherine M. Salinas asserts in the Final Report And
Recommendation And Order issued in relation to the Plaintiffs Original Complaint, Injunction .
For Relief, And Declaratory Judgment that "Although Plaintiff lists average monthly expenses of
$13,125.00, some of the discretionary amounts for one person seem unnecessarily high, such as
$1,000 for food, $200 for laundry and dry cleaning, and $6,000 in monthly credit card installment
payments to Bank of America, Citi Bank, and American Express. Although Plaintiff may have
limited funds and may have other priorities for those funds, I believe that she is able to pay the
7 of 19
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required $402 filing fee and should do so of she wishes to pursue this case. For the reasons stated,
I find thar Plaintiff has sufficient means to pay the filing fee and incur the costs of these
proceedings. Thus, Plaintiff's request to proceed IFP. is DENIED."
Plaintiff $1,000 for food would include all her grocery items, including toilet paper and
cleaning products, which is not uncommon in the city where Plaintiff lives.
Plaintiff's expense for laundry and dry-cleaning amounting to approximately $200 was
prior to her constructive discharge on November 18th, 2022 as shown in Exhibit 3. Since then,
Plaintiff has focused her efforts into ensuring the security and safety of her family. Plaintiff is now
looking for justice for herself and her family.
Plaintiffs monthly income over the past seven and a half(7.5) months is $0.00.
Plaintiff did not leave her job; Plaintiff was constructively discharged. The Occupational
Safety and Health Administration ("OSHA") defines Constructively Discharged as "quitting when
an employer makes working conditions intolerable due to the employees' protected activity)",
which Plaintiff performed as a Whistleblower and rendered a service to the community. Plaintiff
has opened a complaint with OSHA. Plaintiff has filed a complaint with OSHA.
In addition, Plaintiff has provided in Exhibit 2 herein evidence showing that her home was
broken into, she was blacklisted from her industry, and prevented to find a job in line with her
qualifications due to the subject matter of case number 2022CV365268 filed in Fulton County
Superior Court.
Plaintiff has utilized all her retirement savings in order to pay for the security and safety of
her family, which is also related to the subject matter of case number 2022CV365268 filed in
Fulton County Superior Court. Therefore, the average monthly income of$7,500 from Plaintiff's
employment and retirement, does not reflect that the money was used for safety and security in
8 of 19 .
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 115 of 134
view of the threats.Plaintiff and her family were faced with. Plaintifrs priorities were and are
perfectly aligned to the law of God and the thought process of any reasonable person. In view of
the subject matter in case number 2022CV365268, Plaintifrs family came first and she spent a
considerable amount of money to ensure their security and safety.
Further, Plaintiff has provided in Exhibit 3 herein evidence that she was not able to receive
unemployment benefits since her constructive discharge on November 18th, 2022. The Plaintifrs
lawsuit against ID.Me, Inc. is to allow Plaintiff to receive her unemployment benefits. Based
on the information provided above, Plaintiff is unable to pay the legal filing fees because she does
not have any income and is being blacklisted from the industry she works in.
Objections, Responses, and Arguments To Statement of Analysis 6:
United Stated Magistrate Judge Catherine M. Salinas asserts in the Final Report And
Recommendation And Order issued in relation to the Plaintiffs Original Complaint, Injunction
For Relief, And Declaratory Judgment that "Before she left her most recent employment, she was
earning $9,583.00 per month."
The information and interpretations presented in the Report related to the Plaintiffs
financial situation are incomplete and are, therefore, not facts.
Plaintiff did not leave her job; Plaintiff was constructively discharged. The Occupational
Safety and Health Administration ("OSHA") defines Constructively Discharged as "quitting when
an employer makes working conditions intolerable due to the employees' protected activity)",
which Plaintiff performed as a Whistleblower and rendered a service to the community. Plaintiff
has opened a complaint with OSHA.
Plaintiffs monthly income over the past seven and a half (7.5) months is $0.00.
9 of 19
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 116 of 134
Plaintiff has utilized all her retirement savings, including her income she earned prior to
being constructively discharged, in order to pay for the security and safety of her family, which is
also related to the subject matter of case number 2022CV365268 filed in Fulton County Superior
Court. Therefore, the average monthly income of $7,500 from Plaintiffs employment and
retirement, does not reflect that the money was used for safety, and security in view of the threats
Plaintiff and her family were facing. Plaintiffs priorities were and are perfectly aligned to the law
of God and the thought process of any reasonable person. In view of the subject matter in case
number 2022CV365268, Plaintiffs family came first and she spent a considerable amount of
money to ensure their security and safety.
Further, Plaintiff has provided in Exhibit 3 herein evidence that she was not able to receive
unemployment benefits since her constructive discharge on November 18th, 2022. The Plaintiffs
lawsuit against ID.Me, Inc. is to allow Plaintiff to receive her unemployment benefits.
On December 6, 2019, the Second Circuit (Calabresi, Pooler, Park) issued a published per
curiarn decision in United States v. Kosic (Nunez), concerning the defendant-appellant's motion
for in forma pauperis ("IFP") status in his direct criminal appeal. The appellant's motion arose
'
from a district court order denying his IFP motion based on a finding that the appeal would be
frivolous pursuant to 28 U.S.C. §1915. In its published decision, the Second Circuit granted the
motion and held that it is proper to consider only the defendant's financial eligibility-and not the
merits-when deciding motions for IFP status and appointment of counsel under the Criminal
Justice Act ("CJA") in a direct criminal appeal.
As the Court explained, a litigant seeking IFP status on appeal generally must first seek a
ruling in the district court. If the district court denies the motion and finds that an appeal cannot be
taken in good faith, then the defendant may seek an IFP determination from the appellate court.
10 of 19
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 117 of 134
When the appellate court reviews such motions, it applies different standards depending on
whether the case is civil or criminal. In the civil context, the Court considers the merits of an
appeal.
Plaintiff has provided in Exhibit 5 evidence showing her expenses and that she could no
longer draw from her credit cards.
Plaintiff has provided herein evidence that her request to proceed in IFP was not frivolous
or malicious. Based on the information and documents provided herein, Plaintiff is unable to pay
the legal filing fees because she does not have any income and is being blacklisted from the
industry she works in.
Plaintiffs Request Related To Her Motion To Pr?ceed in Forma Pauperis
Plaintiff hereby requests that her motion to proceed in IFP be reconsidered by the Court
for her case against ID.Me, Inc. (1 :22-CV-2297) as well as her cases against ID.ME, Inc. (case file
number l:22-CV-2237), and AGSOUTH FARM CREDIT, ACA (case file number l:22-CV-
2263).
Plaintiffs Additional Filing
Plaintiff filed a corresponding Plaintiffs Motion For Reconsideration of Plaintiffs Motion
to Proceed in Format Pauperis under case number l:22-CV-2297 in June 21'1, 2022 titled
"OBJECTIONS to 4 Report and Recommendation" along with attachments and exhibits that were
entered on 06/22/2022.
11 of 19
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 118 of 134
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ARGUMENTS AND CITATIONS TO AUTHORITY
The 14th Amendment- Title I
Plaintiff re-alleges and incorporates each and every paragraph of this PLAINTIFF' S
COMPLAlNT AND REQUEST FOR INJUNCTION (case number l:22-CY-2237) and the facts
as if set forth here in full for all purposes.
The 14th Amendment Section 1 states that "All persons born or naturalized in the United
States, and subject to the jurisdiction thereof, are citizens of the United States and the State wherein
they reside. No State shall make or enforce any law which shall abridge the privileges or
immunities of citizens of the United States; nor shall any State deprive any person of life, liberty,
or property, without due process of law; nor deny to any person within its jurisdiction the equal
protection of the laws.
Plaintiff asserts in her Complaint and Request For Injunction that preventing Plaintiffs
access to unemployment benefits will cause "irreparable harm" because Plaintiff will not be able
to pay for her food, her mortgage, healthcare, and safety.
Plaintiff was constructively discharged from BDO USA, her former employment, because
of her status as a whistleblower and the retaliatory practices she faced after notifying her
supervisor, the SEC, and the PCAOB of unethical behaviors that are in violation of SEC
12 of 19
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regulations and PCAOB standards exhibited by Wesley Freeman, Scott Meier, Peter Poppo, Paul
Davidson, Mark Davenport, and Johnson Wong at the following public companies and their
affiliates: Interface, Atlanticus, BioHorizons (Henry Schein's subsidiary), Otelco, BlueLinx, NMS
SPAR (subsidiary of SPAR).
Since Plaintiff filed a complaint with the SEC and the PCAOB, her home has been broken
into. Her phones and computers have been hacked. (Case No. 2022CV365268) Also,
Plaintiff has been unable to access the limited amount of money she had invested on the
Gemini platform.
Furthermore, the ·economy has not yet fully recovered and Plaintiff is dealing with a
complex set of issues such as non-existent income due to being blacklisted in the industry as well
as ongoing concerns about the pandemic.
Because of the delay and refusal to provide Plaintiff with an ID.Me account, ID.Me has
contributed to Plaintiff not being able to receive income from her unemployment and has rendered
more difficult the current financial hardship experienced by Plaintiff, including but not limited to
the ability to pay for food, mortgage and healthcare.
A loss of housing or medical care and the inability to provide food, shelter and adequate
healthcare constitute irreparable harm and are not adequately compensable by an award of
damages.
If every person is afforded an opportunity to have food, shelter, and adequate healthcare,
it is ensured that his or her rights to pursue happiness, life, and liberty are not violated. By delaying
and preventing Plaintiff to have access to her ID.Me account, ID.Me, is wrongfully, illegally,
and/or unlawful depriving Plaintiff of food, shelter, and adequate healthcare.
13 of 19
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 120 of 134
Defendant ID.Me has violated Plaintiff's unalienable rights under the 14th Amendment
Title I by delaying and preventing Plaintiff to have access to her ID.Me account; thereby, violating
Plaintiff's right to Life, Liberty and the pursuit of Happiness as well as due process.
The 14th Amendment - Public Health, Safety, and Morals
Plaintiff re-alleges and incorporates each and every paragraph of this PLAINTIFF'S
COMPLAINT AND REQUEST FOR INJUNCTION (case number l:22-CV-2237) and the facts
as if set forth here in full for all purposes.
The 14th Amendment also applies to Health, Safety, and Morals. The Fourteenth
Amendment Rights Guaranteed Privileges And Immunities of Citizenship, Due Process And Equal
Protection states that "Even under the narrowest. concept of the police power as limited by
substantive due process, it was generally conceded that states could exercise the power to protect
the public health, safety, and morals.
Plaintiff asserts in her Complaint and Request For Injunction that ID.Me violated Plaintiff's
14th Amendment by delaying and preventing Plaintiff's access to her ID.Me account. Food,
shelter, and healthcare are basic human rights. Plaintiff asserts that access to food, shelter, and
healthcare are critical component to the prosperity, safety and general well-being of every human
being. Without her ID.Me account, Plaintiff is not able to pay for adequate food, healthcare,
shelter, and safety.
Defendant ID.Me has violated Plaintiff's unalienable rights under the second paragraph of
the American Declaration of Independence by delaying and preventing Plaintiff's access to her
ID.Me account, thereby, violating Plaintiff's rights to Life, Liberty and the pursuit of Happiness,
to due process, and to Health, Safety, and Morals.
Claim
14 of 19
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 121 of 134
In ~valuating the legal sufficiency ofa complaint for purposes of§ 19 i 5(d), the courts apply
the customary standard enunciated in Conley v. Gibson, 355 U.S. 41, 45-46, 78 S.Ct. 99, 101-102,
2 L.Ed.2d 80 (1957), that a complaint should not be dismissed for failure to state a claim unless it
appears beyond doubt that the Plaintiff can prove no set of facts in support of his or her claim,
which would entitle him or her to relief. Plaintiff can prove to facts to support her claims and has
provided evidence to support her claims.
Plaintiff's Prayers for Relief to the Court in Plaintiff's Complaint and Request For
Injunction include, but is not limited to, a Court's request to "Grant any such additional relief to
Plaintiff in law or equity as the Court deems just and proper under the circumstances." Plaintiff's
request includes actual and punitive damages.
JURISDICTION AND VENUE
The Plaintiff's case falls under the following U.S. Civil Statutes.
a. 42 U.S.C. § 1104 Unemployment Trust Fund
b. 26 U.S.C. 3301 et seq. Federal Unemployment Tax Act
c. O.C.G.A. § 34-8-45 Supplemental unemployment benefits
d. 14th Amendment Section I.
This Court has subject matter jurisdiction over this case because the Plaintiff's claims arise
under the laws of the State of Georgia and the United States. It has jurisdiction over the Plaintiffs
state law and regulations claims because they are so closely related to the federal claims as to
form part of the same case or controversy. The Northern District of Georgia consists of four (4)
divisions as outlined and described in 28 U.S.C. § 90. The Atlanta Division comprises the counties
of Cherokee, Clayton, Cobb, DeKalb, Douglas, Fulton, Gwinnett, Henry, Newton, and Rockdale.
15 of 19
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 122 of 134
Pursuant'to 28 U,S, Code § 1391, a civil action may be brought in a judicial district in
which a substantial part of the events or omissions giving rise to the claim occurred, or a substantial
part of property that is the subject of the action is situated.
Pursuant to 28 U.S. Code§ 1391, for purposes of venue in a State, which has more than
one judicial district and in which a defendant that is a corporation is subject to personal jurisdiction
at the time an action is commenced, such corporation shall be deemed to reside in any district in
'
that State within which its contacts would be sufficient to subject it to personal jurisdiction if that
district were a separate State, and, if there is no such district, the corporation shall be deemed to
reside in the district within which it has the most significant contacts.
Pursuant to 28 U.S. Code § 1343, Civil rights and elective franchise, the Northern District
Court of the State of Georgia has authority:
(1)° To recover damages for injury to his person or property, or because of the
deprivation of any right or privilege of a citizen of the United States, by any act done in
furtherance of any conspiracy mentioned in section 1985 of Title 42;
(2) To recover damages from any person who fails to prevent or to aid in
preventing any wrongs mentioned in section 1985 of Title 42 which he had knowledge
were about to occur and power to prevent;
(3) To redress the deprivation, under color of any State law, statute, ordinance,
regulation, custom or usage, of any right, privilege or immunity secured by the Constitution
of the United States or by any Act of Congress providing for equal rights of citizens or of
all persons within the jurisdiction of the United States;
(4) To recover damages or to secure equitable or other relief under any Act of
Congress providing for the protection of civil rights, including the right to vote;
16 of 19
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 123 of 134
(5) To exercise such other powers, not contrary to the Constitution, as are or
may be given to such courts by law.
Venue is proper in this Court because all or a substantial part of the conduct and
violations giving rise to the claims in the case occurred in the State of Georgia. See O.C.G.A §
14-2-510, O.C.G.A § 9-10-91, O.C.G.A § 9-10-93, O.C.G.A § 9-10-31, and O.C.G.A § 9-10-34.
This Court has personal jurisdiction over Defendant ID.ME, Inc. because Defendant
ID.Me, Inc, through its agents committed the acts that are the subject matter of this lawsuit in the
State of Georgia. See O.C.G.A § 14-2-510, O.C.G.A § 9-10-91, O.C.G.A § 9-10-93, O.C.G.A §
9-10-31, and O.C.G.A § 9-10-34.
This Court has personal jurisdiction over Defendant ID.Me, Inc. because Defendant
ID.Me, Inc. and its agents and employees, have ongoing and systematic contacts with the State
of Georgia, maintains headquarter offices in the State of Georgia, and reside in the State of
Georgia, and have committed the acts that are the subject matter of this lawsuit in the state of
Georgia.
Venue is proper in this Court because Defendant ID.Me, Inc.'s conducts substantial
business in Fulton County, Atlanta, Georgia.
Plaintiff Raissa Djuissi Kengne has standing to bring this Complaint in Court because she
will be adversely affected by the actions of the Defendant and will be subject to undue harm if
Defendant does not allow Plaintiff to have access to her ID.Me account.
Accordingly, venue is proper pursuant to 28 U.S.C. § 90, 28 U.S. Code§ 1391, 28 U.S.
Code § 1343, and Georgia Civil Practice and Corporations, Partnerships, And Associations Code
§ 15-6-8, O.C.G.A § 14-2-510, O.C.G.A § 9-10-91, O.C.G.A § 9-10-93, O.C.G.A § 9-10-31,
17 of 19
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 124 of 134
O.C.G.A § 9-10-34.
CERTIFICATION
Under Federal Rule of Civil Procedure 11, I certify to the best ofmy knowledge, information, and
belief that this complaint: (1) is not being presented for an improper purpose, such as to harass,
cause unnecessary delay, or needlessly increase the cost oflitigation; (2) is suppof\ed by existing
law or by a nonfrivolous argument for extending, modifying, or reversing existing law; (3) the
factual contentions have evidentiary support or, if specifically so identified, will likely have
evidentiary support after a reasonable opportunity for further investigation or discovery; and (4)
the complaint otherwise complies with the requirements of Rule 11.
~ I agree to provide the Clerk's Office with any changes to my address where case related papers
may be served. I understand that my failure to keep a current address on file with the Clerk's Office
may result in the dismissal of my case.
CONCLUSION
For the foregoing reasons, the referenced Final Report And Recommendation And Order issued in
relation to the Plaintiffs Original Complaint, Injunction For Relief, And Declaratory Judgment
should not be adopted to the extent it recommends that Plaintiffs complaint be dismissed for lack
of subject matter jurisdiction.
Dated: July O1, 2022
Respectfully submitted,
18 of 19
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 125 of 134
Physical Address: Raissa Djuissi Kengne
1280 W. Peachtree ST NW. Unit 2109 Pro Se
Atlanta, GA 30309
Telephone: (404) 932-1651 570 Piedmont Ave. NE #55166
Email: cianeseya2022@gmail.com Atlanta, GA 30308
19 of 19
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 126 of 134
) Case No. I :22-CV-2297
) (Related Case No.
RAISSA DJUISSI KENGNE, ) I :22-CV-2297-SEG)
Applicant, ) (Related Case No.
) I :22-CV-2263)
v. )
ID.ME.INC. )
COGENCY GLOBAL INC. )
250 BROWNS HILL CT, )
MIDLOTHIAN, VA, 23114-9510, USA )
)
Respondent. )
EXHIBIT 10
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 127 of 134
Pro Se 2 (Rev. 12/16) Complaint and Request for Injunction
RECEIVED IN CLERK'S OFFICE
U,S.O.C. -AUanta lJNITRP~fTES WsWCl' C,QURT
for the
f, HI l!,ITAO
JUN O6 2022 Northern District of Georgia El
YEIMER, Clerk Atlanta Division
K~~~P,
By: I "" Deputy C1er1(
< -
__,
RAISSA DJUISSI KENGNE
570 PIEDMONT AVE NE #55166
ATLANTA, GA 30308
)
)
Case No. t : 22-CV- 2 237
(to be filled in by the Clerk's Office)
)
)
P/aintiff(s)
(Wn'te the full name of each plaintiff who is filing this complaint.
)
If the names ofall the plaintiffs cannot.fit in the space above, )
please write "see attached" in the space and attach an additional )
page with the fall list of names.)
)
-Y-
)
ID.ME, INC. )
COGENCY GLOBAL INC. )
250 Browns Hill Ct,
Midlothian, VA, 23114- 9510, USA )
)
Defendant(s)
)
(Write the full name of each defendant who is being sued. If the
names ofall the defendants cannot fit in the space above, please )
write "see attached" in the space and attach an additional page
with the Ju// list ofnames.)
COMPLAINT AND REQUEST FOR INJUNCTION
I. The Parties to This Complaint
A. The Plaintiff(s)
Provide the information below for each plaintiff named in the complaint. Attach additional pages if
needed.
Name RAISSA DJUISSI KENGNE
Street Address 570 PIEDMONT AVE NE #55166
City and County ATLANTA, FULTON COUNTY
State and Zip Code GA 30308
Telephone Number 404-932-1651
E-mail Address CIANESEYA2022@GMAIL.COM
B. The Defendant(s)
Provide the information below for each defendant named in the complaint, whether the defendant is an
individual, a government agency, an organization, or a corporation. For an individual defendant,
include the person's job or title (lfknown). Attach additional pages if needed.
Page 1 of 6
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 128 of 134
Pro Sc 2 (Rev. 12/16) Complaint and Request for Injunction
Defendant No. I
Name ID.ME, INC. (Registered Agent: COGENCY GLOBAL INC.)
Job or Title (i/'k11ow11)
Street Address 250 Browns Hill Ct. ·--·------- - - - - - - - - -
City and County Midlothian, CHESTERFIELD COUNTY
State and Zip Code VA, 23114 - 9510
Telephone Number
E-mail Address (ifk11ow11)
Defendant No. 2
Name Not Applicable
Job or Title (!(known)
Street Address
City and County
State and Zip Code
Telephone Number
E-mail Address (ifknmrn)
Defendant No. 3
Name
Job or Title (if known)
Street Address
City and County
State and Zip Code
Telephone Number
E-mail Address (iflmow11)
Defendant No. 4
Name Not Applicable
Job or Title ({/'knoll'n)
Street Address
City and County
State and Zip Code
Telephone Number
E-mail Address (//'k11uw11)
Page2of6
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 129 of 134
Pro Sc 2 (Rev, 12/16) Complaint and Rcgucsl for Injunction
II. Basis for Jurisdiction
Federal courts are courts of limited jurisdiction (limited power). Generally, only two types of cases can be
heard in federal court: cases involving a federal question and cases involving diversity of citizenship of the
parties. Under 28 U.S.C. § 1331, a case arising tmder the United States Constitution or federal laws or treaties
is a federal question case. Under 28 U.S.C. § 1332. a case in which a citizen of one State sues a citizen of
another State or nation and the amount at stake is more than $75,000 is a diversity of citizenship case. In a
diversity of citizenship case, no defendant may be a citizen of the same State as any plaintiff.
What is the basis for federal court juris<liction 9 (check all th,11 app(i-)
[i2]Federal question [;2J Diversity of citizenship
Fill out the paragraphs in this section that apply to this case.
A. If the Basis for Jurisdiction Is a Federal Question
List the specific federal statutes, federal treaties, and/or provisions of the United States Constitution that
are at issue in this case.
42 U.S.C. § 1104 Unemploym ent Trust Fund
26 U.S.C. 3301 et seq. Federal Unemployme nt Tax Act
O.C.G.A. § 34-8-45 Supplementa l unemployme nt benefits
B. If the Basis for Jurisdiction Is Diversity of Citizenship
I. The Plaintiff(s)
a. If the plaintiff is an individual
The plaintiff'. /name) RAISSA DJUISSI KENGNE , is a citizen of the
State of /name) GEORGIA
b. If the plaintiff is a corporation
The plaintiff, (name) Not Applicable , is incorporated
under the laws of the State of /name) Not Applicable
and has its principal place of business in the State of (namf!)
Not Applicable
(If more than one plainliffis named in the complaint, at/ach an additional page providing the
same information.for each additional plaintiff.)
2. The Defendant(s)
a. If the defendant is an individual
The defendant, (,iame) Not Applicable , is a citizen of
the State of (name) Not Applicable Or is a citizen of
(foreign 11atio11) Not Applicable
Page 3 of 6
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 130 of 134
Pro Sc 2 (Rev, 12/16) Complaint and Request for Injunction
b. lfthe defendant is a corporation
The defendant, (name! ID.ME, INC. , is incorporated under
the laws of the State of (name) VIRGINIA , and has its
principal place of business in the State of (name) GEORGIA
==='------------
0 r is incorporated under the laws of /foreign nation) Not Applicable
and has its principal place of business in /name) Not Applicable
(Jfrnore than one defendant is named in the complaint, attach an additional page providing the
same information/or each additional defendant.)
3. The Amount in Controversy
The amount in controversy-the amount the plaintiff claims the defendant owes or the amount at
stake-is more than $75,000, not counting interest and costs of court, because (explain):
The amount in the controversy cannot be easily estimated. Defendant refuses to provide access
to Plaintiffs account on ID.Me's website in order for Plaintiff to receive unemployment benefits
causing Plaintiff to live without income. In addition, Plaintiff is experiencing foreclosure, which
can be avoided by ID.ME providing access to Plaintiffs account. Plaintiff is unable to use her
unemployment benefits to pay her mortgage.
III. Statement of Claim
Write a short and plain statement of the claim. Do not make legal arguments. State as briefly as possible the
facts showing that each plaintiff is entitled to the injunction or other relief sought. State how each defendant
was involved and what each defendant did that caused the plaintiff harm or violated the plaintiffs rights,
including the dates and places of that involvement or conduct. If more than one claim is asserted, number each
claim and write a short and plain statement of each claim in a separate paragraph. Attach additional pages if
needed.
A. Where did the events giving rise to your claim(s) occur''
The events giving rise to Plaintiffs claim occurred in Atlanta, GA - Fulton County.
B. What date and approximate time did the events giving rise to your claim(s) occur9
Plaintiff signed up for an ID.me account on 04/22/2022 at Georgia DOL to receive unemployment
benefits. Plaintiff was unable to create an ID.Me account and contacted ID.Me customer support on May
16th, 2022. Plaintiff received an email from ID.Me stating that "A Member Support Representative will be
reaching out as soon as possible with assistance. For your records, your ticket number is 10770653."
Plaintiff received additional emails from Shamora (Member Support Associate) on May 17th, 2022 and
nothing since then despite several emails from Plaintiff. Plaintiff received an email from John (Member
Support Associate) on May 27th, 2022 and shortly thereafter, had a video conference call with John to
validate Plaintiffs identity. Plaintiff is still not able to access her account on ID.Me in order to receive
1ini:=imnlnvmi=>nt hPnPfit~
Page4of6
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 131 of 134
Pro Sc 2 (Rev. 12/161 Complaint and Request !'or lnjunc1ion
C. What arc the facts underlying your claim(s)? (For example: What happened to you? Who did what?
Was anyone else involved? Who else sow what happenl'd?J
Plaintiff signed up for an ID.me account on 04/22/2022 at Georgia DOL to receive unemployment
benefits.
Plaintiff was unable to create an ID.Me account and contacted ID.Me customer support on May 16th,
2022. Plaintiff received an email from ID.Me stating that "A Member Support Representative will be
reaching out as soon as possible with assistance. For your records, your ticket number is 10770653."
Plaintiff received additional emails from Shamora (Member Support Associate) on May 17th, 2022 and
nothing since then despite several emails from Plaintiff.
Plaintiff received an email from John (Member Support Associate) on May 27th, 2022 and shortly
thereafter, had a video conference call with John to validate Plaintiffs identity.
Plaintiff is still not able to access her account on ID.Me in order to receive unemployment benefits.
IV. Irreparable Injury
Explain why monetary damages at a later time would not adequately compensate you for the injuries you
sustained, arc sustaining, or will sustain as a result of the events described above, or why such compensation
could not be measured.
Preventing Plaintiffs access to unemployment benefits will cause "irreparable harm" because Plaintiff will not be
able to pay for housing or food. In addition, Plaintiff left BOO USA, her former employment, because of retaliation
after notifying her supervisor, the SEC, and the PCAOB of unethical behaviors that are in violation of SEC
regulations and PCAOB standards exhibited by Wesley Freeman, Scott Meier, Peter Poppo, Paul Davidson,
Mark Davenport, and Johnson Wong at the following public companies and their affiliates: Interface, Atlanticus,
Bio Horizons (Henry Schein's subsidiary), Otelco, BlueLinx, NMS SPAR (subsidiary of SPAR). Since Plaintiff filed
a complaint with the SEC and the PCAOB, her home has been broken into. Her phones and computers have
been hacked. (Case No. 2022CV365268) Also, Plaintiff has been unable to access the limited amount of money
she had invested on the Gemini platform. Furthermore, the economy has not yet fully recovered and Plaintiff is
dealing with a complex set of issues such as non-existent income due to being blacklisted in the industry and
ongoing concerns about the pandemic.
~ lp~s_q_(housing or rne_c!iqal_ c~re_ar,d_the inability to provide food,.shelter and ad~quate_child_caLeJor_~J.a.rnJly_c_qn_s_@J_t~~ __
irreparable harm pending resolution of this cause of action and are not adequately compensable by an award of damages.
V. Relief
State briefly and precisely what damages or other relief the plaintiff asks the court to order. Do not make legal
arguments. Include any basis for claiming that the wrongs alleged are continuing at the present time. Include
the amounts of any actual damages claimed for the acts alleged and the basis for these amounts. Include any
punitive or exemplary damages claimed, the amounts. and the reasons you claim you are entitled to actual or
. punitive monex damages.
WHEREFORE, Plaintiff respectfully requests this Court that Defendant be cited to appear and answer herein;
that, on final hearing, the Court enters judgment against Defendant in Plaintiff's favor and grants relief to Plaintiff
against the Defendant as follows:
1. Declare that the Defendant violated the law as set forth above;
2. Order Defendant, ID.Me, Inc, to give Plaintiff access to her account in order for Plaintiff to claim her
unemployment benefits as stipulated under 2 U.S.C. § 1104 Unemployment Trust Fund, 26 U.S.C. 3301 et seq.
Federal Unemployment Tax Act, and O.C.G.A. § 34-8-45 Supplemental unemployment benefits;
3. Award the Plaintiff reasonable attorneys' fees and costs and/or pro se fees and costs for her investigation and
prosecution of this action; and
4. Grant any such additional relief to Plaintiff in law or equity as the Court deems just and proper under the
circumstances.
Page 5 of 6
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 132 of 134
Pro Sc 2 (Rev. 12/16) Complaint and Request for Injunction
VI. Certification and Closing
Under Federal Rule of Civil Procedure 11, by signing below, 1 certify to the best ofmy knowledge, infonnation,
and belief that this complaint: (1) is 110I being presented for an improper purpose, such as to harass, cause
unnecessary delay, or needlessly increase the cost of litigation; (2) is supported by existing law or by a
nonfrivolous argument for extending, modifying, or reversing existing law; (3) the factual contentions have
evidentiary support or, if specifically so identified, will likely have evidentiary support after a reasonable
opportunity for further investigation or discovery; and (4) the complaint otherwise complies with the
requirements of Rule 11.
A. For Parties Without an Attorney
I agree to provide the Clerk's Office with any changes to my address where case-related papers may be
served. I understand that my failure to keep a current address on file with the Clerk's Office may result
in the dismissal of my case.
Date of signing: 06/03/2022
Signature of Plaintiff
Printed Name of Plaintiff RAISSA DJUISSI KENGNE
B. For Attorneys
Date of signing:
Signature of Attorney
Printed Name of Attorney
Bar Number
Name of Law Finn
Street Address
State and Zip Code
Telephone Number
E-mail Address
Page 6 of 6
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 133 of 134
IN THE COURT OF APPEALS
STATE OF GEORGIA
) Case No. I :22-CV-2297
) (Related Case No.
RAISSA DJUISSI KENGNE, ) I :22-CV-2297-SEG)
Applicant, ) (Related Case No.
) I :22-CV-2263)
V. )
ID.ME,INC. )
COGENCY GLOBAL INC. )
250 BROWNS HILL CT, )
MIDLOTHIAN, VA, 23114-9510, USA )
)
Respondent. )
EXHIBIT 11
Case 1:22-cv-02237-SEG Document 5-3 Filed 07/05/22 Page 134 of 134
STATE OF GEORGIA
AFFIDAVIT
) Case No. l:22-CV-2237
) (Related Case No.
RAISSA DJUISSI KENGNE, ) I :22-CV-2297-SEG)
Applicant, ) (Related Case No.
) l:22-CV-2263)
v. )
ID.ME,INC. )
COGENCY GLOBAL INC. )
250 BROWNS HILL CT, )
MIDLOTHIAN, VA, 23114-9510, USA )
Respondent. )
Before me, the undersigned authority personally appeared, Raissa Djuissi Kengne, who being by me first duly sworn
on her oath, deposed as follows:
I am RAISSA DJUISSI KENGNE, the Plaintiff and Appellant in the above and foregoing I) PLAINTIFF RAISSA
DJUISSI KENGNE'S APPLICATION FOR APPELLATE REVIEW, 2) PLAINTIFF'S MOTION FOR
RECONSIDERATION OF PLAINTIFF'S MOTION TO PROCEED IN FORMA PAUPERIS, and 3)
PLAINTIFF'S COMPLAINT AND REQUEST FOR INJUNCTION. All statements of fact therein are within my
t:
personal knowledge and are true and correct. It is my assertion that I am entitled to redress for the issues noted in the
above filed '5~ents.
Date: July _5_', 2022 . Signature: ._2, . ~·
..l__ I
Name: Raissa Djuissi Kengne
Address I: 570 PIEDMONT AVE NE #55166
Address 2: ATLANTA, GA 30308
Telephone: 404-932-1651
Sworn to and subscribed before me, this:.;!!}_ day of Juty-, ,2oa~
ublic SEAL
Jocelyn Algarin
NOTARY PUBLIC
Cobb County, GEORGIA
My Commission Expires 03/08/2026