E-FILED IN OFFICE - KMG

CLERK OF STATE COURT

GWINNETT COUNTY, GEORGIA
23-C-04803-S3
7/12/2023 10:00 PM
TIANA P. GARNER, CLERK

IN THE STATE COURT OF GWINNETT COUNTY

STATE OF GEORGIA

VICTORIA S. BOWLES, )
)
Plaintiff, )
) CIVIL ACTION 23-C-04803-S3
vs. )
) FILE NUMBER: ____________________
UNIVERSITY OF GEORGIA )
ATHLETIC ASSOCIATION, INC., )
A Georgia Nonprofit Corporation; )
)
JALEN D. CARTER, individually and )
as an agent and employee of )
BREADMAN JALEN, LLC, )
a Florida Limited Liability Company; )
)
BREADMAN JALEN, LLC, a )
Florida Limited Liability Company; )
)
ROBERT W. HUGHES, in his capacity )
as the Court Appointed Personal )
Administrator of the Estate of )
CHANDLER LECROY, deceased; and )
)
JOHN DOE Nos. 1-5. )
)
Defendants. )
_________________________________________ )

COMPLAINT FOR DAMAGES

Comes now Plaintiff, Victoria S. Bowles, and hereby submits her Complaint for Damages

against each named Defendant as follows:

INTRODUCTION

This case involves a high speed vehicle crash in Athens, Georgia that occurred early in the

morning on January 15, 2023 after the UGA Football National Championship Celebration the prior

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day. Defendant Jalen Carter, a University of Georgia football player, and Chandler LeCroy

(deceased) were driving at extreme speeds, with LeCroy, traveling at least 104.2 mph, while engaged

in street racing for 45 seconds or less before the crash (giving the passengers in her vehicle only a

brief amount of time to appreciate the high speed and protest).

The crash resulted in the deaths of University of Georgia football player Devin Willock and

University of Georgia recruiting analyst Chandler LeCroy (“LeCroy”). Plaintiff Victoria S. Bowles

(“Ms. Bowles”), also a University of Georgia recruiting analyst (since 2019), was a backseat

passenger in the large Ford Expedition SUV being driven by LeCroy. The SUV had been rented by

Defendant University of Georgia Athletic Association (“UGA Athletic Association” or

“Association”)1 and had been entrusted to LeCroy as a permissive user.

As a result of the crash, Ms. Bowles sustained multiple debilitating injuries, including:

• Three lumbar “burst fractures,” with a spinal cord injury sufficient to cause leakage of
cerebrospinal fluid;
• Five other fractured vertebrae;
• Approximately ten fractured ribs;
• A fractured clavicle;
• A fractured sacrum;
• Fractured and cracked teeth;
• A kidney laceration;
• A liver laceration:
• A punctured and collapsed lung;
• Intra-abdominal hemorrhaging;
• Facial lacerations and injury to her jaw;
• A closed head injury, and neurological damage, causing severe eye pain;
• Damage to her spinal cord resulting in inflammation of the arachnoid, one of the

1 The UGA Athletic Association is a separate distinct legal entity from the University of Georgia.
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 membranes that surrounds the nerves of the spinal cord, with symptoms including
burning sensations and severe pain in her extremities, and foot drop syndrome; and
• Developed “significant arachnoiditis” according to her neurosurgeon-normally a permanent
neurological condition with no cure, often progressing to permanent paralysis.
Permissive Use

On the evening of the Championship Celebration, LeCroy told Ms. Bowles that she (LeCroy)

had “permission” to keep the SUV “until tomorrow.” The UGA Athletic Association issued a public

statement following the crash contending that “rental vehicles were to be turned in at the immediate

conclusion of recruiting duties." (Emphasis added). Numerous text messages from recruiting staff

supervisors to LeCroy, Ms. Bowles and other staff members (detailed and displayed in this

Complaint; see ¶¶ 54-61) show the Association’s statement is false.2 Recruiting staff were regularly

informed they could leave their personal vehicles overnight at the Butts-Mehre football facility and

permissively use Association rental vehicles through a specified cut-off date and time, unrelated to

their assigned recruiting activity duties.

The UGA Athletic Association made a public statement following the crash that rental

vehicles were available to be used by staff members during "recruiting activities only." Not only

do text communications prior to the crash, as included in their original format in this Complaint,

show otherwise, presumed personal use of the rental vehicle provided to LeCroy was authorized by

UGA Assistant Football Coach Chidera Uzo-Diribe on the evening of the Championship

Celebration, just hours before the crash.

Coach Uzo-Diribe, while at the Sakura restaurant with UGA football recruits/prospects and

their guests during an unofficial recruiting visit, asked Ms. Bowles to obtain $1,000.00 in cash from

2 It is Plaintiff’s understanding that the UGA Athletic Association claims that it has no actual employees. Assuming this
to be true, Plaintiff refers to persons or agents acting on behalf of the Association as “Association staff” and or “staff
members” in this Complaint without taking any legal position as to their actual legal status.
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an ATM. (The specific details, with documentation, follow below; See ¶¶ 29-43). Ms. Bowles and

LeCroy left in LeCroy’s UGA Athletic Association rented SUV to obtain the cash, after an effort at a

next-door convenience store failed.

Since the prospects and prospects’ guests dining at Sakura were on unofficial recruiting visits

to UGA, the use of the SUV to obtain the requested cash was presumably not for “recruiting

activities,” but was for personal use-a personal favor to Coach Uzo-Diribe.

In summary, LeCroy had permission from the UGA Athletic Association to drive the vehicle

at the time of the crash. Moreover, for insurance purposes, a “permissive use of a vehicle cannot

reasonably relate to the particular manner of its operation.” Gaither v. State Farm Fire & Cas. Co.,

229 Ga. App. 330 (1997); Strickland v. Ga. Casualty & Sur. Co., 224 Ga. 487 (1968); Great Am.

Alliance Ins. Co. v. Anderson, 847 F3d. 1327 (2017). In other words, as LeCroy had permission to

drive and use the vehicle in general, the purpose for which the vehicle was driven, and the manner in

which it was driven (even though she may have been legally intoxicated, as was the situation in

Great Am. Alliance Ins. Co.) is not relevant under Georgia law to preclude or bar the Association’s

insurers’ liability coverage.

Negligent Entrustment

Were it not for the UGA Athletic Association’s negligent entrustment of the SUV to LeCroy

on January 15, 2023, the crash would have been avoided. The Association was well aware that

LeCroy’s primary job duty as a recruiting analyst required her to regularly drive UGA football

recruits and their families around Athens. Despite the Association’s public denials since the crash, it

was fully aware, as addressed below, that LeCroy had at least four speeding tickets, which included

two “super speeder” violations under Georgia law.

The UGA Athletic Association would have reasonably concluded that LeCroy regularly

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drove at extreme speeds when law enforcement was not present. While LeCroy may have been

legally intoxicated, the proximate cause of the crash was street racing and extreme speed. The

Association’s negligent entrustment of the large rental SUV to LeCroy, with knowledge that she was

a reckless and habitual speeder, concurs with LeCroy’s primary negligence-traveling 104.2 mph.

LeCroy’s immediate supervisor, Logen Reed, was personally aware of LeCroy’s most recent

“super speeder” ticket that was issued on October 30, 2022 while she was returning to Athens

following the Georgia-Florida game. Ms. Reed was present in LeCroy’s vehicle at the time.

Bryant Gantt (“Gantt”), UGA’s liaison between the UGA football program, law enforcement,

and the court system – who was paid $209,914.61 in 2022 for job duties that directly involved

getting players out of legal trouble - subsequently attempted, in person, to get a county court clerk to

reduce LeCroy’s super speeder charge in November of 2022. Between 2016 and 2023 Gantt was

personally involved in at least 82 separate legal matters involving players. (The UGA Athletic

Association issued a public statement that Gantt’s involvement in the LeCroy ticket “was purely in

his personal capacity as a favor to a friend” in an attempt to distance itself from his actions).

Prior to January 15, 2023, the UGA Athletic Association was aware, based upon its own

public statements, of LeCroy’s previous speeding violations, including “super speeder” violations,

and that LeCroy was a habitually reckless driver. Gantt’s admitted attempt (with LeCroy’s

knowledge) to reduce her October 2022 “super speeder” violation gave LeCroy an understanding

that the Association would continue to intervene on her behalf in relation to future speeding

violations, thus encouraging and facilitating her high speed driving and recklessness conduct.

Events Leading to the Crash

Athens-Clarke County video shows that the narrative conveyed to the public of LeCroy driving

aggressively and at excessive speeds in the downtown Athens area before the crash is incorrect.

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Outside of downtown Athens, and before Barnett Shoals Road, LeCroy did briefly enter a short “no

left turn” lane (in her direction), and subsequently drove at an unsafe speed while following

Defendant Carter-although approximately 22 mph slower than him. Reports of Defendant Carter’s

aggressive and high speed driving are accurate. He was driving a Jeep Cherokee Trackhawk, a

vehicle recognized as a favorite of street racers, and capable of speeds up to 180 mph. (The exact

streets traveled, turns made, driving maneuvers, distances, and speeds detected are detailed in this

Complaint; see ¶¶ 85-120).

LeCroy, just four seconds before impact according to the SUV’s airbag control module, was

traveling 104.2 mph. Defendant Carter’s admissions, in effect, substantiate, along with video and

physical evidence, that he was street racing with LeCroy on Barnett Shoals Road. In a recorded

interview with law enforcement, he stated that near the curve of the crash he slowed his vehicle

while beside the LeCroy vehicle, and she passed him. He admitted he then, while traveling behind

LeCroy, observed her vehicle go off the road and strike a pole, saw the pole falling, and admitted

that a wire from the pole came down on his vehicle-a physical impossibility without him traveling a

similar speed. (Defendant Carter’s statements to law enforcement following the crash: “I was going

an average speed” and “I wasn’t going fast,” must be taken in the context of his normal driving

behavior, as addressed below).

Both LeCroy’s Estate and Defendant Carter are liable to Ms. Bowles for engaging in a grossly

negligent joint enterprise-tandem driving/street racing. See, Price v. Thapa, 323 Ga. App. 638

(2013).

Defendant Carter illegally left the scene without speaking with law enforcement. He did

initially stop at the scene and could see “smoke and the car.” (The SUV was crushed beyond

recognition). Despite LeCroy’s passenger, Warren McClendon, stating to him that he could not

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locate Devin Willock, Defendant Carter left the scene after less than 10 minutes when another UGA

football player at the scene yelled at him: “Yo…hey, JC…you might want to go ahead and go get the

f*** on yo….” As Defendant Carter was aware at the time, he was jointly responsible for the crash,

and had a legal duty to remain on the scene. Instead, in part obviously fearful of bad publicity and

the effect on his NFL draft status, he hoped not to be questioned or take any responsibility for his

actions.

Ms. Bowles was unaware when entering the UGA Athletic Association rented SUV that

LeCroy may have been legally intoxicated. Ms. Bowles likewise had no indication or knowledge (as

no reasonable person would) that LeCroy and Defendant Carter would engage in street racing, at

speeds exceeding 100 mph.

During the 45 seconds or less during which LeCroy and Defendant Carter began street racing

on Barnett Shoals Road, Ms. Bowles verbally protested LeCroy’s speed. LeCroy ignored Ms.

Bowles, and continued racing Defendant Carter at speeds in excess of 100 mph until the crash

occurred. In summary, Ms. Bowles never assumed the specific risk of LeCroy’s high speed driving

in excess of 100 mph, or the risk of LeCroy’s and Defendant Carter’s street racing, when she entered

the rental SUV as a passenger.

PARTIES

1. Defendant University of Georgia Athletic Association, Inc. (“UGA Athletic Association” or

“Association”) is a Georgia Nonprofit Corporation, and it may be served with a copy of Plaintiff’s

Complaint and Summons as follows: University of Georgia Athletic Association, Inc. c/o Ryan

Nesbit, Registered Agent, Business Services Building, 456 East Broad Street, Room 225, Athens,

GA 30602.

2. Defendant UGA Athletic Association is subject to the jurisdiction and venue of this Court.

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 3. Defendant UGA Athletic Association is a nonprofit entity as defined by Georgia law, and it is

not an agency or entity of the State of Georgia. See O.C.G.A. §§ 14-3-101, 14-3-140, 14-3-301 et

seq.; 20-3-78, 20-3-79 & 20-3-80.

4. Defendant UGA Athletic Association has waived its qualified charitable immunity by the

purchase of insurance covering its negligent conduct, and to the extent of income from non-

charitable sources, including, but not limited to, the face value of athletic event tickets (totaling

$37,192,353 in 2022) and rights/licensing income (totaling $77,447,079 in 2022).

5. Defendant UGA Athletic Association has further waived its qualified charitable immunity as a

result of its negligent entrustment of the rented SUV to LeCroy. See, YMCA of Metropolitan Atlanta,

Inc. v. Bailey, 107 Ga. App. 417 (1963).

6. Defendant Robert W. Hughes, named only in his representative capacity as the Court-

Appointed Personal Administrator of the Estate of Chandler LeCroy, may be served with a copy of

Plaintiff’s Complaint and Summons as it relates to the claims asserted against LeCroy under this

Complaint as follows: Robert W. Hughes as the Court-Appointed Personal Administrator of the

Estate of Chandler LeCroy, Robert W. Hughes & Associates, P.C.,

, Lawrenceville, GA 30046-6913.

7. Robert W. Hughes, as the Court-Appointed Personal Administrator of the Estate of Chandler

LeCroy, is subject to the jurisdiction and venue of this Court.

8. Defendant Jalen D. Carter, individually (hereinafter “Defendant Carter”), and as an agent and

employee of Defendant Breadman Jalen, LLC, may be served with a copy of Plaintiff’s Complaint

and Summons as follows: Jalen Da’Quan Carter,

9. Defendant Jalen Carter is subject to the jurisdiction and venue of this Court.

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 10. Defendant Breadman Jalen, LLC (hereinafter “Defendant Breadman LLC”) a Florida Limited

Liability Company, may be served with a copy of the Plaintiff’s Complaint and Summons as

follows: Breadman Jalen, LLC

or Breadman Jalen, LLC

11. Defendant Breadman LLC is subject to the jurisdiction and venue of this Court.

12. The State Court of Gwinnett County has original jurisdiction over this matter because one of

the named Defendants is a resident and citizen of Gwinnett County, State of Georgia, and this action

is not subject to federal jurisdiction or removal to federal court under the provisions of 28 U.S.C. §

1332 because the claims asserted in this action relate to various torts committed in the State of

Georgia and one or more of the parties in interest properly joined and served as a Defendant in this

action are citizens of Georgia, the state in which the action has been brought. See, 28 U.S.C. §

1441(b).

FACTS GIVING RISE TO PLAINTIFF’S CLAIMS

13. Plaintiff hereby incorporates and adopts by reference the previous paragraphs of this

Complaint as if fully and completely set forth herein.

14. On January 14, 2023, the University of Georgia (“hereinafter “UGA”) and/or the UGA

Athletic Association held a parade and Sanford Stadium event (hereinafter “Championship

Celebration” or “Celebration”), in Athens, Georgia to celebrate UGA winning the 2022 College

Football Playoff National Championship.

15. As part of the Championship Celebration activities, Defendant UGA Athletic Association

also hosted a number of football recruits and their families on unofficial visits to the UGA campus.

16. The football recruits and their families taking part in the unofficial visits in connection with

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the Championship Celebration were hosted by UGA football coaches and UGA Athletic Association

staff members, including recruiting analysts, during their visits.3

17. On January 14, 2023 and January 15, 2023, LeCroy was a UGA recruiting analyst who was

assigned to host a football recruit from Texas and his family on an unofficial visit in relation to

various events occurring as part of the Championship Celebration.

18. On January 14, 2023 and January 15, 2023, Plaintiff Victoria S. Bowles was a UGA

recruiting analyst who was assigned to host a football recruit from Georgia on an unofficial visit in

relation to various events occurring as part of the Championship Celebration.

19. Following the parade and events at Sanford Stadium conducted in connection with the

Championship Celebration, Plaintiff Victoria S. Bowles and LeCroy were each issued and provided

with separate rental SUVs by the UGA Athletic Association to use over the course of the

Championship Celebration weekend.

20. The UGA Athletic Association regularly rents a fleet of large SUVs for use in connection

with its recruiting activities that occur at different times throughout the year.

21. The fleet of large SUVs rented by the UGA Athletic Association for use in connection with

its recruiting activities are assigned by staff members to coaches, UGA Athletic Association staff

members, and UGA recruiting analysts for use, including over the course of a weekend.

22. SUV assignments are normally made via text messages, and keys to the rental vehicles are

picked up from the desk of a UGA Athletic Association staff member.

23. Instructions relating to when and where to return the rental vehicles are also normally issued

via text messages sent by UGA Athletic Association staff prior to the end of a recruiting weekend or

3 It is Plaintiff’s understanding that the UGA Athletic Association claims that it has no actual employees. Assuming this
to be true, Plaintiff refers to persons or agents acting on behalf of the Association as “Association staff” and or “staff
members” in this Complaint without taking any legal position as to their actual legal status.
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event.

24. UGA recruiting analysts normally and customarily retained possession and use of their

assigned rental SUVs for the duration of a recruiting event or weekend and were only required to

return their rental SUVs by a deadline established in a text message sent to them by UGA Athletic

Association supervisors and staff.

25. Due to the nature of recruiting visits, UGA recruiting analysts were often on call during the

entire time-period that they were hosting a recruit, or a recruit’s family, until the time that a recruit

or his family ended their visit and left the campus to return home.

26. UGA recruiting analysts were commonly instructed that they could take their assigned rental

SUV’s home overnight, and leave their personal vehicles parked at the UGA Athletic Association

facilities on campus.

27. On the day of the Championship Celebration, at UGA football headquarters, Butts-Mehre,

Assistant Director of Football Operations/Recruiting, Anna Courson, gave LeCroy and Ms. Bowles

each authority to use UGA Athletic Association rented SUVs, which they picked up in the Bones

player cafeteria parking lot.

28. On the day of the Championship Celebration, Plaintiff Victoria Bowles was assigned a large

red SUV by the UGA Athletic Association for her use over the course of the Championship

Celebration weekend.

Events At & From Sakura Restaurant

29. Following the Championship Celebration events at Sanford Stadium and later at the Butts-

Mehre football facility, Ms. Bowles transported, in her assigned red rental SUV, UGA football

Coach Glenn Schumann, as well as her assigned recruit (who was at UGA on an unofficial recruiting

visit) to an unofficial recruiting event/dinner at Sakura restaurant located in “Five Points” in Athens,

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Georgia.

30. Following the Championship Celebration events at Sanford Stadium and later at the Butts-

Mehre football facility, LeCroy also transported, in her assigned black rental SUV, her assigned

recruit (who was also on an unofficial recruiting visit to UGA), along with the recruit’s mother and

aunt, to the same unofficial recruiting event/dinner at Sakura restaurant.

31. Also in attendance at the unofficial recruiting event/dinner at Sakura that evening were

UGA football coaches Chidera Uzo-Diribe and Tray Scott, UGA Graduate Assistant, Carson Hall,

and Director of Recruiting Administration, Christina Harris, as well as an unknown man with the

group.

32. After arriving at the unofficial recruiting event at Sakura, but before being able to eat dinner

herself, Plaintiff was asked by Coach Uzo-Diribeto to take his personal ATM card and obtain

$1,000.00 in cash from a nearby ATM before the end of dinner.

Exhibit A, Screen Shot of Text From Coach Uzo-Diribe to Ms. Bowles, with his (redacted)
ATM Pin Number, sent at 5:41 p.m.
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 33. Plaintiff complied with Coach Uzo-Diribeto’s personal request, and along with LeCroy, left

the unofficial recruiting event at Sakura.

34. LeCroy and Ms. Bowles initially walked to an ATM inside a convenience store next door to

Sakura. Coach Uzo-Diribe’s ATM card was declined for any withdrawal amount.

35. When Coach Uzo-Diribe’s ATM card was declined at the first ATM, LeCroy and Ms.

Bowles walked back to the rental SUV provided to LeCroy by the UGA Athletic Association, and

drove to another convenience store next to the UGA track to use a different ATM. Coach Uzo-

Diribe’s ATM card was again declined for any withdrawal amount.

36. After the second denial, Ms. Bowles decided to use her own personal ATM card to obtain

as much of the requested $1,000.00 in cash as possible.

Exhibit B, Ms. Bowles’ Wells Fargo ATM withdrawal record (card number
redacted) showing at the bottom “WITHDRAWAL AUTHORIZED ON
01/14”(red box added).
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 37. At 6:10 p.m., Coach Uzo-Diribe, aware that his ATM card was not working, used his Venmo

account (a mobile payment application) and transferred $1,000.00 to Ms. Bowles in return for the

$1,000.00 in cash that she was obtaining for him, listing the “Type of Transaction” as “Payment

between friends.”

Exhibit C, The Venmo Receipt (in redacted format).

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 38. Ms. Bowles and LeCroy then used LeCroy’s UGA Athletic Association rental SUV to

obtain the balance of the $1,000.00 in cash requested by Coach Uzo-Diribe. At approximately 6:20

pm they drove to Ms. Bowles’ home, one-and-one-half miles away, to obtain the remainder of the

requested cash (from Ms. Bowles’ babysitting earnings and Christmas gifts).

39. Ms. Bowles, along with LeCroy, after retrieving cash from her home, returned to the

unofficial recruiting event at Sakura, and discreetly provided UGA football Coach Uzo-Diribe with

his requested cash.

40. Upon information and belief, Coach Uzo-Diribe was aware (as Coach Schumann was),

before Ms. Bowles and LeCroy left Sakura on both occasions, that they both initially arrived at

Sakura in UGA Athletic Association rented SUVs.

41. Upon returning to Sakura, Coach Schumann advised Plaintiff that he was taking Plaintiff’s

assigned recruit to go axe throwing at LumberJaxe’s, located on N. Lumpkin Street in Athens,

following the unofficial recruiting dinner.

42. Plaintiff provided Coach Schumann with the keys to her assigned red SUV and subsequently

texted James Ellis (UGA Player Personnel Coordinator), one of the UGA Athletic Association staff

members responsible for coordinating the return of rental SUVs that weekend, that Coach Schumann

now had her red SUV.

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 Exhibit D, Screen Shot of Text from Ms. Bowles to James Ellis addressing transfer of the
SUV keys to Coach Schumann-stating, in part, “Not sure if he planned on taking
it home or switching back into his other rental at the facility. . .”

43. The recruits/prospects and their guests dining at Sakura were on unofficial recruiting visits

to UGA, and there were no official recruiting visits to Athens during the Championship Celebration

weekend. Accordingly, the use of the UGA Athletic Association rental SUV to obtain the requested

$1,000.00 in cash was presumably not for “recruiting activities,” but, was for personal use - a

personal favor to Coach Uzo-Diribe.

44. Because Ms. Bowles no longer had any means of transportation, she asked LeCroy if she

could ride along with LeCroy, her prospect, and his family in LeCroy’s rental SUV. LeCroy agreed.

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 45. When Plaintiff and LeCroy returned to the unofficial recruiting event/dinner at Sakura from

the personal errand to obtain Coach Uzo-Diribe’s cash, the recruiting event was concluding. Their

meals were provided to them in to-go boxes.

46. Following the unofficial recruiting event at Sakura, Plaintiff rode with LeCroy back to Butts-

Mehre to drop off LeCroy’s prospect’s family members.

47. After dropping LeCroy’s prospect’s family members off at the football facility, LeCroy, with

Plaintiff riding along, then took LeCroy’s assigned prospect back to the Hampton Inn located at

2220 W. Broad Street, over one mile from campus, where the prospect and his family were staying.

48. LeCroy’s prospect went inside to change clothes. While LeCroy and Plaintiff waited for the

prospect to return, they ate their to-go food from Sakura’s in the drop off area immediately in front

of the Hampton Inn while in the black rental SUV.

49. When LeCroy’s prospect came downstairs from his hotel room at approximately 8:24 pm,

they drove the prospect to UGA’s East Campus Village to be dropped off with his UGA player host

at the McWhorter Hall dorm. Prior to being dropped off, the prospect asked LeCroy and Plaintiff to

photograph him posing in front of the SUV using the East Campus Village parking deck as a

backdrop. LeCroy and Plaintiff complied with the request and the prospect eventually entered the

player host’s East Campus Village dorm at approximately 9:09 pm.

50. After dropping the prospect off at the East Campus Village dorm, LeCroy and Ms. Bowles

then returned to Butts-Mehre so that LeCroy could obtain her purse out of her personal car.

51. While at Butts-Mehre, LeCroy informed Plaintiff that she had been given permission by the

UGA Athletic Association to keep her black rental SUV until the following day.

52. LeCroy’s statement to Plaintiff at Butts-Mehre that “I was told that I could keep [the SUV]

until tomorrow” was consistent with Ms. Bowles’ own prior experience and instructions given to her

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by her UGA Athletic Association supervisors regarding the use of Association rental SUVs by

recruiting analysts.

53. Plaintiff had, prior to the night of the crash, herself specifically inquired as to whether

recruiting analysts could keep UGA Athletic Association rental SUVs overnight, and had been told

that it was permissible for recruiting analysts to do so.

54. True and accurate copies of some of the actual text messages sent to Plaintiff and other staff

members by UGA Athletic Association supervisors confirming that it was permissible for UGA

recruiting analysts to keep rental SUVs overnight, while leaving their personal vehicles at the

football facility, are set forth in paragraphs 55-61 below.

55. On Friday, December 13, 2019, Logen Reed, Ms. Bowles’ immediate supervisor, sent Ms.

Bowles a text message that stated: “Haley said you’re good! And you can take your car home if you

need to.” Ms. Bowles responded: “Wait just making sure you mean I can take the SUV with Me.”

Ms. Reed responded: “Yes! Take it home.”

Exhibit E, December 13, 2019 Text Message.

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 56. “Haley” referred to in the December 13, 2019 text message is Haley Schaafsma, who was

Director of Recruiting Operations at the time the text was sent.

57. On Saturday March 19, 2022, Anna Courson, the Assistant Director of Football

Operations/Recruiting, copied Ms. Bowles and others on a text message that she sent to LeCroy

wherein Courson informed LeCroy that LeCroy could return her UGA Athletic Association rental

vehicle “by 11 AM tomorrow!” (i.e. on Sunday).

Exhibit F, March 19 & 20, 2022 Text Messages (name redacted).

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 58. Anna Courson was in charge of allocating UGA Athletic Association rental vehicles to UGA

Athletic Association recruiting analysts and other staff.

59. On April 16, 2022, Ms. Courson sent a text message to eight staff members, including

LeCroy and Ms. Bowles, stating: “These [keys] will be handed out post game…We MUST have

your keys back by 11 AM tomorrow!!!”

Exhibit G, April 16, 2022 Text Message.

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 60. A text message dated Friday May 20, 2022 from Ms. Courson, sent to approximately 25

staff members, states: “All keys will need to be returned by 11 AM Sunday.”

Exhibit H, May 20, 2022 Text Message.

61. A text message dated July 30, 2022 from Ms. Courson to six staff members, directed staff

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members to return UGA Athletic Association vehicles by “tomorrow morning.”

Exhibit I, July 30, 2022 Text Message (individual phone numbers redacted).

62. LeCroy expressly told Ms. Bowles on the evening of the Championship Celebration that

she [LeCroy] had permission to keep the vehicle “until tomorrow.”

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 63. Plaintiff had previously left her personal vehicle at the football facility overnight on

multiple occasions.

64. Plaintiff is personally aware of multiple prior occasions where UGA Athletic Association

vehicles were used for personal purposes by UGA staff, as well as at UGA Athletic Association

sponsored events where alcohol was served.

65. Plaintiff and LeCroy, after dropping off the recruit at the McWhorter Hall dorm and

subsequently arriving at Butts-Mehre on January 14, 2023, then left Butts-Mehre in the black rental

SUV to return to LeCroy’s apartment. They stayed at LeCroy’s apartment for approximately one

hour before traveling to downtown Athens in the black rental SUV to join in the ongoing

Championship Celebration.

66. Plaintiff and LeCroy arrived in downtown Athens after 10:00 pm on the evening of January

14, 2023, and parked the SUV near the front entrance of Starland, at 145 E. Clayton Street.

67. Plaintiff and LeCroy almost immediately encountered UGA Athletic Association staff

member Anna Courson, the supervisor who had assigned LeCroy the black rental SUV earlier that

day.

68. After speaking with Anna Courson, LeCroy and Plaintiff then proceeded to several locations

including various crowded downtown establishments, where they encountered friends, UGA fans

and players.

69. Plaintiff and LeCroy walked to various locations that evening together downtown, but they

were often separated. While Plaintiff did observe LeCroy drink limited amounts of alcohol that

evening, when they were together she did not observe LeCroy consume enough alcohol to lead

Plaintiff to reasonably believe that LeCroy may have been legally intoxicated or in any way

impaired.

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 70. During the course of that evening, Plaintiff and LeCroy encountered UGA football players

Devin Willock and Warren McClendon, among others, who at a point in time while Plaintiff was

away from the group, invited LeCroy to join them at Toppers International Show Bar (“Toppers”).

LeCroy then told Plaintiff that she was going to Toppers with Devin Willock and Warren

McClendon and others.

71. Plaintiff had met and interacted with Willock and McClendon at the football facility

previously, but did not know either player well.

72. Because LeCroy was Ms. Bowles’ ride and Ms. Bowles did not want to be left downtown

alone that evening, she decided to go with the group to Toppers.

73. At the time Plaintiff and LeCroy arrived at Toppers, Plaintiff had no reasonable basis to

believe that LeCroy was intoxicated or impaired by alcohol, based upon the limited amount of

alcohol that Plaintiff had observed LeCroy consume over the course of the evening.

74. Once inside Toppers, Plaintiff separated from LeCroy. Plaintiff joined a group of UGA

football players’ girlfriends and students associated with the football recruiting program, who had

gathered immediately inside the main entrance of Toppers. Because Plaintiff and LeCroy separated

when they entered Toppers, Plaintiff has limited knowledge of LeCroy’s activities inside Toppers.

75. Plaintiff did not spend any appreciable amount of time with LeCroy inside of Toppers and

had no basis to know or appreciate the amount of alcohol that LeCroy may have consumed at

Toppers between the time they arrived together and the time they left Toppers.

76. When Toppers closed, LeCroy, who was with UGA football players Devin Willock, Warren

McClendon and others, found Plaintiff near the main entrance.

77. Plaintiff, who had no basis to know or appreciate what amount of alcohol that LeCroy may

have consumed at Toppers, left with LeCroy, Willock and McClendon.

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 78. Athens-Clarke County video surveillance (hereinafter “ACC video”) shows Ms. Bowles

walking a considerable distance away from LeCroy and UGA football players Warren McClendon

and Devin Willock after they all had exited Toppers.

79. ACC video shows LeCroy walked normally, and she did not appear intoxicated.

80. LeCroy, Ms. Bowles, Warren McClendon and Devin Willock walked to the UGA Athletic

Association rental SUV- which, as previously stated, was parked near the front entrance of Starland

on E. Clayton Street.

81. Ms. Bowles entered the LeCroy SUV, as LeCroy was her ride home.

82. Ms. Bowles got into the back seat passenger side of the black rental SUV, where she stayed

until the subject crash occurred.

83. When entering as a backseat passenger in the black rental SUV, Plaintiff was unaware that

LeCroy may have been legally intoxicated, that LeCroy would be engaging in street racing in

concert with Defendant Carter, or that LeCroy would be driving the rental SUV in excess of 100

mph.

84. Warren McClendon and Devin Willock also entered the LeCroy SUV, and LeCroy agreed

to take the occupants to a Waffle House.

Events of the Fatal Trip

85. After leaving the parking space near Starland, both LeCroy and Defendant Carter traveled

on E. Clayton Street (a two-lane, one-way street) heading towards N. Thomas Street (which was less

than 0.20 miles away).

86. ACC video shows Defendant Carter, in the left lane, and the LeCroy SUV, in the right lane,

stopped at a traffic light at the intersection of E. Clayton Street and College Avenue (a very short

one-half block away from Starland.

25
 87. ACC video shows that Defendant Carter aggressively accelerated into the intersection of E.

Clayton Street and College Avenue.

88. ACC video shows that the LeCroy SUV subsequently moved into the intersection at a slow

speed.

89. ACC video then shows, a very short block away, Defendant Carter stopped in the right lane

of E. Clayton Street, at a traffic light, at the intersection of E. Clayton Street and Jackson Street, with

the LeCroy SUV stopped behind him.

90. ACC video shows that Defendant Carter then aggressively accelerated into the E. Clayton

Street and Jackson Street intersection and sped away at an excessive speed, and then aggressively,

without signaling, moved into the left lane and passed a vehicle that was stopped in the right lane of

E. Clayton Street.

91. ACC video shows that the LeCroy SUV, on E. Clayton Street, moved into the E. Clayton

Street and Jackson Street intersection at a slow speed, and subsequently, after initiating her left-turn

signal, passed the vehicle that was stopped in the right lane of E. Clayton Street.

92. ACC video shows that Defendant Carter made a right turn, without stopping and at a fast

pace, onto N. Thomas Street.

93. ACC video shows that after turning, Defendant Carter traveled into the “left-turn only” lane

on N. Thomas Street, and stopped behind several vehicles, which were waiting to turn left onto

Oconee Street at the N. Thomas Street/E. Broad Street intersection.

94. ACC videos show that the LeCroy vehicle stopped at the above E. Clayton Street turn

location, and seventeen seconds after Defendant Carter made his right turn, after signaling, made a

slow turn and traveled into the “left-turn only” lane of N. Thomas Street (which was then slowly

moving) and traveled behind a vehicle following Defendant Carter.

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 95. ACC video shows that Defendant Carter and the LeCroy vehicle followed a line of vehicles

that were slowly turning onto Oconee Street (also known as the “Lexington Highway”).

96. University of Georgia video shows Defendant Carter, at approximately .175 miles after

turning onto Oconee Street, approaching a vehicle in front of him at a high rate of speed, and passing

that vehicle at a fast speed in a “left-turn only” lane of travel (in his direction).

97. The “left-turn only” lane turned into Hickory Street.

98. At the end of the brief “left-turn only” lane, Defendant Carter, without signaling,

immediately pulled back into his original lane of travel behind a slow moving vehicle.

99. University of Georgia video shows the LeCroy SUV, at a slower speed and four seconds

after Defendant Carter entered the “left-turn only” lane of travel, entered the “left-turn only” lane at

a slower pace, and passed, it appears, two or three vehicles, and then, after signaling, pulled back

into her lane behind a slow-moving vehicle. (There were no on-coming vehicles when she crossed

over into the dedicated “left-turn only” lane).

100. At a distance of approximately one-half mile from the end of the “left-turn only” lane,

Defendant Carter, law enforcement determined through video surveillance, passed a Dairy Queen

while traveling 100 mph.

101. Law enforcement determined, through video surveillance, that the LeCroy SUV, behind

Defendant Carter, passed the Dairy Queen at 78 mph.

102. After passing the Dairy Queen, Defendant Carter and the LeCroy rental SUV traveled

approximately 0.3 miles before turning into the Waffle House on Oconee Street at approximately

2:41:12 a.m.

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 103. Defendant Carter arrived first at the Waffle House located on Oconee Street and parked in

a parking space. LeCroy pulled into the Waffle House after Defendant Carter and stopped her SUV

behind his parked SUV.

104. In the Waffle House parking lot, Defendant Carter exited his vehicle, walked to the

LeCroy SUV and spoke to someone inside the vehicle on the driver’s side.

105. Defendant Carter and LeCroy agreed to go to another nearby Waffle House on Barnett

Shoals Road in Athens.

106. No one but Defendant Carter exited either of the two vehicles while they were at the

Oconee Street Waffle House.

107. After the conversation between someone in the LeCroy SUV and Defendant Carter in the

parking lot of the Oconee Street Waffle House, LeCroy left the Waffle House ahead of Defendant

Carter to go to a Waffle House located on Barnett Shoals Road, which was only a short distance

away.

108. At 2:42:16 a.m., LeCroy’s SUV exited the Oconee Street Waffle House parking lot onto

the Grove Street Extension, traveling a short distance before making a right turn onto Oconee Street,

followed by Defendant Carter, who exited the parking lot at 2:42.23 a.m.

109. Accordingly, Defendant Carter and LeCroy were at the Oconee Street Waffle House for

approximately 71 seconds.

110. During the brief amount of time between LeCroy leaving downtown Athens driving the

black rental SUV and the time LeCroy and Defendant Carter both stopped at the Waffle House

located on Oconee Street, LeCroy did not engage in any driving maneuvers that Plaintiff, as a

backseat passenger, perceived as being dangerous or placing her at risk of being injured in a crash as

the result of LeCroy losing control of the rental SUV due to excessive speed.

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 111. From the Oconee Street Waffle House, both subject SUVs traveled approximately 0.3

miles to the intersection of Oconee Street and Barnett Shoals Road, encountering three separate

traffic signals, before turning right onto Barnett Shoals Road.

112. UGA football player Jamon Dumas-Johnson informed law enforcement that while stopped

at the traffic light at the intersection of Oconee Street and Barnett Shoals Road he spoke with

Defendant Carter while both were in their vehicles stopped at the light-a point in time before

Defendant Carter and LeCroy began their street racing.

113. At some point along the route between the Oconee Street Waffle House and the intended

Waffle House destination on Barnett Shoals Road, Defendant Carter pulled alongside the left side of

LeCroy’s black rental SUV and rolled down his passenger side windows.

114. On Barnett Shoals Road, Defendant Carter and LeCroy began street racing.

115. On Barnett Shoals Road, the subject SUVs passed a “76” convenience store, a distance of

approximately 0.7 miles from the turn onto Barnett Shoals Road.

116. Video surveillance at the “76” convenience store shows the subject SUVs traveling side-

by-side at approximately 2:46:01 a.m., with the LeCroy SUV determined by law enforcement to be

traveling 99.472 mph (59.472 mph over the 40 mph posted speed limit), with Defendant Carter

traveling at a nearly identical speed.

117. As LeCroy’s speed increased on Barnett Shoals Road, Ms. Bowles became alarmed and

verbally expressed her concern that LeCroy should slow down.

118. LeCroy failed to heed Ms. Bowles’ request to slow down.

119. LeCroy’s rental SUV, approximately 0.3 miles past the “76” convenience store, and on a

curve while traveling in excess of 100 mph, left the roadway on the right side of the road, hit a utility

pole cutting it in half; struck a tree; struck a light pole cutting it in two pieces; hit more trees;

29
slammed into the side of an apartment building damaging a brick wall; and then rotated

counterclockwise into the building where it came to rest.

120. LeCroy, four seconds before impact, was traveling 104.20 mph (64.20 mph over the 40

mph posted speed limit), according to the LeCroy SUV’s airbag control module.

121. Defendant Carter, in effect, admits to street racing with Ms. LeCroy - despite his prior

denials-as he stated to law enforcement during a February 10, 2023 recorded interview that near the

curve of the crash he slowed his vehicle while beside the LeCroy vehicle, and she passed him.

122. Defendant Carter admitted in the interview that he then, while traveling behind LeCroy,

observed her vehicle go off the road and strike a pole, saw the pole falling, and stated that a wire

from the pole came down on his vehicle.

123. Athens-Clarke County Police determined that Defendant Carter’s roof had scrape marks

consistent with hitting falling power lines.

124. Defendant Carter could not have been further than approximately 0.1 miles (528 feet)

from the LeCroy SUV impact area when he observed the crash as a vehicle approaching the area in

his direction of travel would have a line of sight of the impact area of approximately 0.1 miles (528

feet), and even less from where LeCroy started leaving the roadway.

125. Defendant Carter’s admissions, stated in paragraphs 121-122 above, as well as scrape

marks on his SUV, and video at the “76” convenience store, establish that at the moment of the crash

he was traveling behind LeCroy at a speed similar to her extreme speed.

126. Defendant Carter stated in law enforcement interviews: “I was going an average speed”

and “I wasn’t going fast.”

127. The UGA Athletic Association rented SUV driven by LeCroy was extensively damaged

in the crash beyond recognition.

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Exhibit J, Photograph of damaged LeCroy SUV

Exhibit K, Stock Photograph of An Identical 2021 Ford Expedition SUV.

31
 128. The subject crash resulted in the death of LeCroy and the death of Devin Willock, who

was a backseat passenger on the driver’s side of the black rental SUV.

Permissive Use

129. Neither the UGA Athletic Association nor LeCroy’s supervisors placed any limits or

restrictions on the use of her assigned SUV during the day of the Championship Celebration or the

morning of January 15, 2023.

130. At the time of the crash, LeCroy was operating the subject rental SUV with the permission

of the UGA Athletic Association.

131. The UGA Athletic Association issued a public statement following the crash stating that

rental vehicles were available to be used by staff members during "recruiting activities only."

132. The UGA Athletic Association issued a public statement following the crash stating:

"Policies and expectations that were well understood by athletics staff dictated that such rental

vehicles were to be turned in at the immediate conclusion of recruiting duties." (Emphasis added).

133. Ms. Bowles was never informed by UGA Athletic Association supervisors/staff that

vehicles rented by the UGA Athletic Association had to be turned in at “the immediate conclusion of

recruiting duties" or could only be used for “recruiting activities.”

134. Ms. Bowles, as well as LeCroy and other UGA Athletic Association staff, were allowed on

numerous occasions prior to the subject crash to permissively use the UGA Athletic Association

rental vehicles for personal use during down time between scheduled recruiting activities, as well as

take the SUV’s home overnight after the conclusion of their recruiting activities.

135. Ms. Bowles is aware of other occasions prior to the subject crash where staff members

used UGA Athletic Association vehicles for personal use.

136. The subject crash, which was proximately caused by Defendant Carter’s and LeCroy’s

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joint enterprise and concerted act of tandem street racing, resulted in Plaintiff Victoria S. Bowles

suffering multiple significant and debilitating injuries which included, but are not limited to: three

lumbar “burst fractures,” with a spinal cord injury in the lumbar spine area sufficient to cause the

leakage of cerebrospinal fluid. She developed “significant arachnoiditis”- damage to the spinal cord

resulting in inflammation of the arachnoid, one of the membranes that surrounds the nerves of the

spinal cord. Her symptoms include burning sensations and severe pain in her extremities, and foot

drop syndrome. Arachnoiditis is normally a permanent neurological condition with no cure, often

progressing to permanent paralysis.

137. Ms. Bowles also sustained five other fractured vertebrae; approximately ten fractured ribs;

a punctured and collapsed lung; a fractured clavicle; a fractured sacrum; laceration of her kidney;

laceration of her liver; intra-abdominal hemorrhaging; facial lacerations; fractured and cracked teeth;

and injury to her jaw. Ms. Bowles sustained a closed head injury, and neurological damage, causing

severe eye pain.

UGA Athletic Association’s Knowledge of LeCroy’s Prior Reckless Driving

138. The UGA Athletic Association was fully aware of LeCroy’s pattern of reckless driving

well before entrusting her with the subject black rental SUV on January 14 and 15, 2023.

139. LeCroy was cited for speeding (69 mph in a 55 mph zone) in Wilkes County, Georgia on

October 20, 2016. Less than six weeks later, on December 8, 2016, in Jenkins County, Georgia,

LeCroy received a “super speeder” ticket, pursuant to O.C.G.A. § 40-6-189, as she was traveling 88

mph in a 65 mph zone.

140. LeCroy was cited, on October 22, 2020, for traveling 64 mph in a 40 mph zone in Clarke

County, Georgia. On October 30, 2022 (77 days before the subject crash), LeCroy was cited in

Morgan County, Georgia for another “super speeder” offense-traveling 77 mph in a 55 mph zone.

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 141. LeCroy’s supervisor, Ms. Logen Reed, Associate Director of Recruiting Operations for

the UGA Athletic Association, was in the vehicle with LeCroy at the time of the October 30, 2022

violation-as they were returning to Athens from the UGA/Florida football game in Jacksonville,

Florida.

142. Prior to the subject crash, the UGA Athletic Association’s “Program Coordinator

II/Director of Player Support and Operations,” Bryant Gantt (“Gantt”), attempted, in person, to get a

Morgan County, Georgia court clerk to reduce LeCroy’s October 30, 2022 “super speeder” ticket.

143. Gantt was at the time and remains, upon information and belief, the UGA Athletic

Association’s liaison between the UGA Athletic Association and law enforcement-with a 2022

salary of $209,914.61.

144. Addressing her conversation with Gantt concerning the “super speeder” ticket, the

Morgan County court clerk, Salisha Sanders, stated in an interview with the Atlanta Journal

Constitution in relation to Gantt’s attempts to reduce LeCroy’s charge: “’Based on her [LeCroy’s]

history, I said, ‘No, not at all,’” Ms. Sanders further stated: “I’m his go-to in Morgan County.”

145. According to an Atlanta Journal-Constitution report, between 2016 and 2023 Gantt,

although not licensed to practice law, was personally involved in at least 82 separate legal matters

involving UGA football players.

146. The UGA Athletic Association made a public statement following the subject crash stating

that Gantt’s involvement with LeCroy’s ticket “was purely in his personal capacity as a favor to a

friend based on his knowledge of traffic court proceedings.”

147. The UGA Athletic Association made a public statement following the subject crash stating:

“The university conducted a background check on LeCroy when she was hired full time in 2021, and

its insurance carrier performed a routine check of her driving history in June 2022.”

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 148. The UGA Athletic Association had actual knowledge of at least four of LeCroy’s speeding

violations, including two “super speeder” violations, prior to the subject crash.

149. Actual knowledge of all four of LeCroy’s known speeding violations prior to the subject

crash can be inferred to the UGA Athletic Association by Ms. Reed’s knowledge, Gantt’s

knowledge, and the background checks performed by UGA and the UGA Athletic Association’s

insurer. See, CGL Facility Mgmt. v. Wiley, 328 Ga. App. 727 (2014) and Ed Sherwood Chevrolet v.

McAuley, 164 Ga. App. 798 (1982).

Defendant Carter’s Driving Conduct Prior To The Day of The Championship Celebration

150. On July 23, 2022, Defendant Carter was cited in the State of Florida for speeding.

151. In 2022, before Defendant Carter received the delivery of the Cherokee Trackhawk

(described below), an Ohio dealership provided him with a 2020 Dodge Charger, equipped with a

SRT Hellcat V-8 engine capable of speeds of up to 180 mph. “SRT Hellcat” engines are a favorite

among illegal street racers.

152. The “SRT” acronym stands for “Street and Racing Technology.”

153. On September 2, 2022, Defendant Carter was pulled over by Athens Clarke County Police

for speeding and running a redlight, but was only cited by police for running a redlight. On October

13, 2022, with the assistance of Gantt, Defendant Carter pled guilty to the offense and Gantt paid his

fine with cash at the counter of the Clerk’s office.

154. Between September 2, 2022 and September 22, 2022, the same Ohio dealership provided

Defendant Carter with a 2021 Jeep Cherokee Trackhawk (curb weight of over 5,300 lbs.) equipped

with a 6.2 Liter, SRT, Supercharged 707 Horsepower “Hellcat” V-8 engine with a top speed of 180

mph, and capable of 0 to 60 mph in 3.5 seconds.

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 155. On September 22, 2022, less than three weeks after Defendant Carter received a ticket for

running a redlight, he was again ticketed, in Athens, Georgia, for speeding in his recently acquired

Cherokee Trackhawk-89 mph in 45 mph zone. He also received two tickets for illegal dark tint on

both his windshield and front door windows.

156. The Athens-Clarke County police officer citing Defendant Carter on September 22, 2022-as

can be heard and seen from the officer’s body camera-told him on the scene: “You need to slow

down . . . you’re not going to jail, that’s your break.”

157. On October 31, 2022, Defendant Carter pled guilty to the September 22, 2022 offenses.

158. By traveling 89 mph in a 45 mph zone on September 22, 2022, Defendant Carter

committed a “super speeder” violation, pursuant to O.C.G.A. § 40-6-189.

159. On November 7, 2022 the State of Florida suspended Defendant Carter’s driver’s license

due to his failure to complete a defensive driving course for the ticket issued on July 23, 2022, and

his license remained suspended at the time of the subject crash on January 15, 2023.

Defendant Jalen Carter Illegally Left the Scene of the Crash

160. Defendant Carter, who had no valid driver’s license at the time of the crash, initially

stopped at the scene and could see “smoke and the car.”

161. Despite LeCroy’s passenger, Warren McClendon, stating to Defendant Carter that he could

not locate Devin Willock, Defendant Carter left the scene after less than 10 minutes when a UGA

player at the scene yelled at him: “Yo…hey, JC…you might want to go ahead and go get the f*** on

yo….” (as can be heard in the background of Willock’s iPhone automated “911” call).

162. While Defendant Carter has maintained that he was cleared to leave the scene, his criminal

attorney, Kim T. Stephens, (in a media interview), stated: “It was somebody who he knew to have

authority . . . I don’t know if it was directly from law enforcement.”

36
 163. Defendant Carter did not return to the scene of this fatal crash until more than an hour and a

half after it occurred, and only when Gantt, UGA Athletic Association’s liaison between the UGA

football program and law enforcement, from the crash scene, called and/or texted him and

summoned him back to the scene of the crash at the request of the Athens-Clarke County Police

Department.

164. Gantt not only came to the scene of the subject crash shortly after it occurred but also, even

though not an attorney, was present when law enforcement officials interviewed various UGA

football players about the events of the crash.

165. Defendant Carter violated O.C.G.A. § 40-6-270 (which can qualify as a felony offense) by

leaving the scene of the crash and knowingly failing to render any aid or assistance to Ms. LeCroy,

Mr. Willock or Ms. Bowles, each of whom would have been expected to suffer significant bodily

injuries, if not death, as a result of the high speed crash.

166. Defendant Carter committed an additional offense under O.C.G.A. § 40-6-270 by leaving

the scene of the crash without providing his name, address, his vehicle registration number, and his

driver’s license.

167. Defendant Carter, at the time of leaving the scene, recognized that being publicly implicated

in a street racing event resulting in severe injuries and the likely deaths of crash victims would

negatively impact his NFL draft status and, therefore, his financial future.

Plaintiff Victoria S. Bowles Was Not Negligent

168. Plaintiff Victoria S. Bowles was not negligent in any manner to causing said crash.

169. At some point after the LeCroy SUV turned onto Barnett Shoals Road, Ms. Bowles became

concerned about LeCroy’s excessive speed-which was not initially readily appreciable to her due to

her backseat position in the large SUV and outside darkness.

37
 170. Ms. Bowles expressed concern about LeCroy’s driving, but her concern was ignored.

171. The distance between the turn onto Barnett Shoals Road and the scene of the crash was

approximately one mile.

172. As LeCroy’s SUV and Defendant Carter’s SUV were side-by-side when they reached the

“76” station on Barnett Shoals Road, their average speed to the “76” station from the turn onto

Barnett Shoals Road would have been nearly identical.

173. While the exact speeds of LeCroy’s and Defendant Carter’s vehicles are not known

between their turn onto Barnett Shoals Road and before reaching the “76” station (at which point

they were traveling over 99 mph), with estimated speed/distance calculations, LeCroy’s SUV would

have traveled on Barnett Shoals Road an estimated 45 seconds or less before the crash.

174. Ms. Bowles had only a brief time to react and protest (which she did) once LeCroy’s large

SUV reached a dangerous speed on Barnett Shoals Road.

Injuries, Disability and Damages Sustained by Plaintiff Victoria S. Bowles

175. As a direct and proximate result of the subject crash, Plaintiff Victoria S. Bowles sustained

approximately twenty fractures, including: fracture of the transverse process of a cervical vertebra;

fracture of the C-6 vertebra; fracture of transverse process of a thoracic vertebra; a “burst fracture”

of the fifth lumbar vertebra; a “burst fracture” of the fourth lumbar vertebra; a “burst fracture” of the

second lumbar vertebra; fracture of transverse process of a lumbar vertebra; a wedge compression

fracture of the T-12 vertebra; fracture of the left clavicle; fracture of the sacrum (a bone important, in

part, for hip stability); and approximately ten bilateral rib fractures.

176. According to medical literature, a burst fracture is a traumatic spinal injury in which a

vertebra breaks from a high-energy axial load (e.g. a high speed vehicle crash), with shards of

vertebra (being pushed backwards) penetrating surrounding tissues. The term “burst” implies that the

38
margins of the vertebral body are spread out in all directions. A burst fracture results in a permanent

decrease in anterior height and possible changes in neurological signal intensity with possible

deterioration over time. By crushing the entire margin of the vertebral body, the spine is much less

stable than following a compression fracture.

177. As a direct and proximate result of the subject crash, and, upon information and belief, as

the result of her numerous spinal fractures, Plaintiff Victoria S. Bowles’ medical records establish

that she sustained “complex dural injuries throughout the lumbar spine with significant

arachnoiditis, CSF extravasation [leakage of cerebrospinal fluid].”

178. Arachnoiditis, according to medical literature, is a rare pain disorder caused by damage to

the spinal cord resulting in inflammation of the arachnoid, one of the membranes that surrounds the

nerves of the spinal cord. The condition is associated with neurological symptoms, with severe pain,

including severe stinging and “burning pain,” and foot drop syndrome, all of which Ms. Bowles has

sustained. There is no cure for arachnoiditis, which is normally classified as being a chronic and

permanent lifelong condition, which may be progressive.

179. According to medical literature, when arachnoiditis progresses, it can lead to the formation

of scar tissue and cause the spinal nerves to stick together and malfunction. This leads to “chronic

adhesive arachnoiditis.” Many people with this condition eventually need to use a wheelchair due to

paralysis.

180. As a direct and proximate result of the subject crash, Plaintiff Victoria S. Bowles further

sustained, including but not limited to, a kidney laceration; a liver laceration; a pneumothorax

(collapsed lung) of her left lung; traumatic hemoperitoneum (intra-abdominal hemorrhage); facial

lacerations; fractured and cracked teeth; and injury to her jaw.

181. As a direct and proximate result of the subject crash, Plaintiff Victoria S. Bowles also

39
sustained a closed head injury, and neurological damage, causing eye pain.

182. As a direct and proximate result of the subject crash, Plaintiff Victoria S. Bowles has

incurred medical expenses to date in an amount not less than $171,595.08, and will continue to incur

future and ongoing expenses for medical treatment, rehabilitation, and attendant care as a result of

the subject crash.

183. At the time of the crash, Plaintiff Victoria S. Bowles was paid $429.33 bi-weekly (less

than $12,000.00 per year) as an UGA recruiting analysist. (LeCroy worked nearly identical bi-

weekly hours as Ms. Bowles, and according to the UGA Athletic Association’s statement (see

paragraph 147) was “full-time”). As a direct and proximate result of the subject crash, to date Ms.

Bowles has lost income totaling at least $3,434.00, and remains unable to work.

184. As a direct and proximate result of the subject crash, upon information and belief, Plaintiff

Victoria S. Bowles has suffered a diminution in earnings capacity due to her likely permanent

disability, and will sustain future lost wages.

185. As a direct and proximate result of the subject crash, Plaintiff Victoria S. Bowles has

sustained physical and emotional pain and suffering, and will continue to sustain physical and

emotional pain and suffering likely for the remainder of her life.

COUNT I

NEGLIGENCE: UGA ATHLETIC ASSOCIATION

186. Plaintiff hereby incorporates and adopts by reference the previous paragraphs of this

Complaint as if fully and completely set forth herein.

187. Defendant UGA Athletic Association, prior to entrusting the subject black rental SUV to

LeCroy on January 14, 2023, was aware that LeCroy’s customary activities while using UGA

Athletic Association vehicles involved the transport of UGA football program staff, UGA football

40
program recruits/prospects, including recruits/prospects under the age of eighteen, as well as their

families and others, on a regular basis at all hours of the day during official and unofficial

recruitment visits.

188. Defendant UGA Athletic Association, prior to entrusting the subject black rental SUV to

LeCroy for use over the Championship Celebration weekend, was aware through its own periodic

review of her driving history, as well as the actual knowledge of its agents Gantt and Logen Reed, of

LeCroy’s deplorable driving history and habitual operation of motor vehicles at high and unsafe

speeds.

189. Defendant UGA Athletic Association, prior to entrusting the subject black rental SUV to

LeCroy over the Championship Celebration weekend, had knowledge that LeCroy had received

multiple speeding tickets, including at least two “super speeder” tickets, one of which was issued to

LeCroy on October 30, 2022 while returning from the Georgia-Florida Game with her direct

supervisor in the vehicle.

190. Based upon UGA Athletic Association’s “Program Coordinator II/Director of Player

Support and Operations,” Bryant Gantt’s, attempt to intervene to reduce LeCroy’s October 2022

“super speeder” traffic ticket, LeCroy was left with the understanding that the Association would

continue to intervene on her behalf in an attempt to reduce the consequences of future high speed

driving that endangered the public.

191. Defendant UGA Athletic Association was negligent in entrusting the subject black rental

SUV to LeCroy on January 14, 2023, and expressly granting her permission to have possession and

use of the subject vehicle on January 15, 2023 at the time of the crash.

192. Based upon its negligent entrustment of the subject black rental SUV, Defendant UGA

Athletic Association is liable to Plaintiff Victoria S. Bowles for the injuries and damages that she

41
sustained as a result of the high speed crash that occurred on January 15, 2023 while the vehicle was

permissively entrusted to LeCroy for her use over the course of the weekend of the Championship

Celebration.

193. Plaintiff is entitled to recover against all Defendants for her special and general damages

which include, medical expenses totaling at least $171,595.08 through the time of filing of this

Complaint, future medical expenses, lost wages totaling at least $3,434.00 through the time of filing

of this Complaint, future lost wages, damages due to diminished capacity to work or labor, physical

disability, past, present and future mental and physical pain and suffering, and bad faith damages (for

Plaintiff’s attorney’s fees and expenses of litigation) pursuant to O.C.G.A. § 13-6-11, as well as all

other damages permitted by law, in an amount to be proven at trial.

COUNT II

NEGLIGENCE & GROSS NEGLIGENCE: DEFENDANT JALEN CARTER

194. Plaintiff hereby incorporates and adopts by reference the previous paragraphs of this

Complaint as if fully and completely set forth herein.

195. Defendant Jalen Carter is liable to Plaintiff Victoria S. Bowles for failing to exercise

ordinary care and diligence and was careless and grossly negligent in the following respects,

including but not limited to:

(a) By engaging in reckless driving, and tandem driving/street racing with LeCroy (a grossly

negligent joint enterprise) on Barnett Shoals Road, a public highway in Athens-Clarke County,

Georgia. (See, Price v. Thapa, 323 Ga. App. 638 (2013); a driver is liable even if his vehicle was

not directly involved in the crash if his negligence is so closely related to the other driver’s

negligence as to speed);

(b) By driving at dangerous and extraordinarily high speeds (59 mph or greater over the

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posted speed limit) during the street race that occurred on Barnett Shoals Road while in route to the

Waffle House on Barnett Shoals Road;

(c) By pursuing LeCroy while she was driving the UGA Athletic Association rental SUV

while engaged in a street race with LeCroy on Barnett Shoals Road; and

(d) In driving too fast for conditions during the street race.

196. Plaintiff is entitled to recover against Defendant Carter for special and general damages,

which includes medical expenses totaling at least $171,595.08 through the time of filing this

Complaint, lost wages totaling at least $3,434.00 through the time of filing this Complaint, future lost

income, damages due to diminished capacity to work or labor, physical disability, past, present and

future mental and physical pain and suffering, extreme emotional distress, and bad faith damages (for

Plaintiff’s attorney’s fees and expenses of litigation) pursuant to O.C.G.A. § 13-6-11, as well as all

other damages permitted by law, in an amount to be proven at trial.

COUNT III

NEGLIGENCE & GROSS NEGLIGENCE: CHANDLER LECROY

197. Plaintiff hereby incorporates and adopts by reference the previous paragraphs of this

Complaint as if fully and completely set forth herein.

198. The Estate of Chandler LeCroy, by and through Robert W. Hughes in his representative

capacity as the Court-Appointed Personal Administrator of the Estate of Chandler LeCroy

(deceased), is liable to Plaintiff Victoria S. Bowles for LeCroy’s failure to exercise ordinary care and

diligence and who was careless and grossly negligent in the following respects, including but not

limited to:

(a) By engaging in tandem driving/street racing with Defendant Carter (a grossly negligent

joint enterprise) upon the public highways of Athens-Clarke County, Georgia;

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 (b) By driving at dangerous and extraordinarily high speeds (more than 60 mph over the

posted speed limit) during the street race that occurred on Barnett Shoals Road;

(c) In driving too fast for conditions during the street race;

(d) In failing, after Plaintiff Victoria S. Bowles protested, to slow down while driving the

leased UGA Athletic Association vehicle to a safe and legal speed and to refrain from racing the

vehicle and driving in a reckless manner, and:

(e) By operating a motor vehicle without disclosing to her passengers that she was impaired

by alcohol.

199. Plaintiff is entitled to recover against the Estate of LeCroy for special and general

damages which include, medical expenses totaling at least $171,595.08 through the time of filing

this Complaint, lost wages totaling at least $3,434.00 through the time of filing this Complaint, future

lost income, damages due to diminished capacity to work or labor, physical disability, past, present

and future mental and physical pain and suffering, extreme emotional distress, and bad faith damages

(for Plaintiff’s attorney’s fees and expenses of litigation) pursuant to O.C.G.A. § 13-6-11, as well as

all other damages permitted by law, in an amount to be proven at trial.

COUNT IV

NEGLIGENCE AND GROSS NEGLIGENCE: DEFENDANT BREADMAN JALEN, LLC

200. Plaintiff hereby incorporates and adopts by reference the previous paragraphs of this

Complaint as if fully and completely set forth herein.

201. Defendant Breadman Jalen, LLC was the owner of the vehicle being driven by

Defendant Carter on January 15, 2023 and is for all purposes the alter ego of Defendant Carter as

it relates to the events occurring on January 15, 2023 giving rise to this Complaint.

202. Defendant Breadman Jalen, LLC was negligent in entrusting the subject Jeep Trackhawk

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being driven by Defendant Carter to him based upon its knowledge of Defendant Carter’s driving

history and propensity to engage in aggressive driving behavior and driving at extreme speeds.

203. Defendant Breadman Jalen, LLC is vicariously liable for the injuries and damages incurred

by Plaintiff Victoria S. Bowles as set forth herein above.

204. As a direct and proximate result of the negligent actions of Defendant Breadman Jalen,

LLC, Plaintiff Victoria S. Bowles is entitled to an award for special and general damages which

include, medical expenses totaling at least $171,595.08 through the time of filing this Complaint,

lost wages totaling at least $3,434.00 through the time of filing this Complaint, future lost income,

damages due to diminished capacity to work or labor, physical disability, past, present and future

mental and physical pain and suffering, extreme emotional distress, and bad faith damages (for

Plaintiff’s attorney’s fees and expenses of litigation) pursuant to O.C.G.A. § 13-6-11, as well as all

other damages permitted by law, in an amount to be proven at trial.

COUNT V

PUNITIVE DAMAGES

205. Plaintiff hereby incorporates and adopts by reference the previous paragraphs of this

Complaint as if fully and completely set forth herein.

206. The conduct of each Defendant named below, as more fully set forth herein above,

authorizes the imposition of punitive damages against each named Defendant pursuant to O.C.G.A. §

51-12-5.1 in that the conduct of each named Defendant serves to demonstrate and amount to willful

misconduct, wantonness, oppression, or that entire want of care which would raise the presumption

of a conscious indifference to the consequences. See, O.C.G.A. § 40-6-270; Battle v Kilcrease, 54

Ga. App. 808 (1936); Langlois v. Wolford, 246 Ga. App. 209 (2000).

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 Defendant UGA Athletic Association

207. The conduct of the UGA Athletic Association in entrusting the black rental SUV to LeCroy

under circumstances where it had actual knowledge of LeCroy’s habitually reckless conduct while

driving, with knowledge of at least four prior speeding tickets, including two “super speeder” tickets,

as well as the attempts by and through its agent to reduce or mitigate LeCroy’s speeding tickets, is

sufficient to demonstrate and amount to willful misconduct, wantonness, oppression, or that entire

want of care which would raise the presumption of a conscious indifference to the consequences

authorizing the imposition of punitive damages against Defendant UGA Athletic Association

pursuant to O.C.G.A. § 51-12-5.1.

Defendant Carter

208. The conduct of Defendant Carter in engaging in tandem driving/street racing with LeCroy

on Barnett Shoals Road, driving at extremely dangerous and extraordinarily high speeds (59 mph or

more over the posted speed limit) during the street race that occurred on Barnett Shoals Road in

route to the Waffle House on Barnett Shoals Road, are individually and collectively sufficient to

demonstrate and amount to willful misconduct, wantonness, oppression, or that entire want of care

which would raise the presumption of a conscious indifference to the consequences authorizing the

imposition of punitive damages against Defendant Carter pursuant to O.C.G.A. § 51-12-5.1.

209. The conduct of Defendant Carter during the events described above, in leaving the scene

of the crash, with knowledge he was a joint bad actor in causing the crash, was in violation of

O.C.G.A. § 40-6-270(a)(1)(2), and his failure to render aid to Ms. Bowles, LeCroy and Devin

Willock (as the result of his failure to determine their location on the scene and their physical

condition) in violation of O.C.G.A. § 40-6-270(a)(3), on its own, authorizes the imposition of

punitive damages against Defendant Carter pursuant to O.C.G.A. § 51-12-5.1.

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 210. Defendant Carter’s leaving the scene of the crash without even attempting to speak to Ms.

Bowles and the other occupants, as mandated by statute, was an intentional and culpable act; such

conduct demonstrating a conscious indifference to the consequences and an entire want of care as to

Ms. Bowles’ and the other occupants’ well-being. See, Langlois v. Wolford, 246 Ga. App. 209

(2000).

211. Defendant Carter’s leaving the scene of the crash without even attempting to speak to Ms.

Bowles, LeCroy and Devin Willock gives rise to the reasonable inference that his flight was from a

sense of guilt. See, Parker v State, 232 Ga. App. 609 (1998).

212. Defendant Carter, at the time of leaving the scene, recognized that being publicly implicated

in a street racing event resulting in severe injuries and the likely deaths of crash victims would

negatively impact his NFL draft status and, therefore, his financial future. Thus, he had not only an

interest to avoid both civil and criminal liability, but also to protect his NFL draft status by leaving

the scene of the crash. See, Langlois v. Wolford, 246 Ga. App. 209 (2000).

213. Accordingly, Defendant Carter’s conduct in leaving the scene of the crash, standing alone,

authorizes the imposition of punitive damages against Defendant Carter pursuant to O.C.G.A. § 51-

12-5.1.

214. Defendant Carter’s prior speeding history, including at least one “super speeder” violation,

standing alone, authorizes the imposition of punitive damages against Defendant Carter pursuant to

O.C.G.A. § 51-12-5.1.

215. Plaintiff is entitled to an award of punitive damages against each named Defendant as

identified in this Count in an amount to be determined by the enlightened conscience of a fair and

impartial jury.

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 COUNT VI

Attorneys’ Fees Under O.C.G.A. § 13-6-11

216. Plaintiff repeats, reiterates and re-alleges each and every allegation contained in this

Complaint with the same force and effect as if fully set forth herein.

217. The Defendants in this action have acted in bad faith, have been stubbornly litigious,

and have caused the Plaintiff unnecessary trouble and expense as provided under Georgia law.

218. The Defendants’ bad faith and stubbornly litigious conduct have caused the Plaintiff

unnecessary trouble and expense. Accordingly, Plaintiff is entitled to recover her reasonable

attorney’s fees and expenses of litigation as provided under O.C.G.A. § 13-6-11 in an amount to be

proven at trial.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff Victoria S. Bowles prays:

(a) That the Complaint and summons be served upon the Defendants as required by law;

(b) That, pursuant to Count I of this Complaint, a judgment be entered against Defendant

UGA Athletic Association and in favor of Plaintiff Victoria S. Bowles for all general damages

permitted under Georgia law in an amount to be proved at trial as well as for all special damages, for

lost income and diminution in earnings capacity, in an amount to be proved at trial, and for past,

present and future medical expenses in an amount not less than $171,595.08;

(c) That, pursuant to Count II of this Complaint, a judgment be entered against Defendant

Jalen Carter and in favor of Plaintiff Victoria S. Bowles for all general damages permitted under

Georgia law in an amount to be proven at trial as well as for all special damages, for lost income and

diminution in earnings capacity, in an amount to be proved at trial, and for past, present and future

medical expenses in an amount not less than $171,595.08;

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 (d) That, pursuant to Count III of this Complaint, a judgment be entered against Chandler

LeCroy by and through the representative of her Estate and in favor of Plaintiff Victoria S. Bowles

for all general damages permitted under Georgia law in an amount to be proven at trial as well as for

all special damages, for lost income and diminution in earnings capacity, in an amount to be proved

at trial, and for past, present and future medical expenses in an amount not less than $171,595.08;

(e) That, pursuant to Count IV of this Complaint, a judgment be entered against Defendant

Jalen Breadman LLC and in favor of Plaintiff Victoria S. Bowles for all general damages permitted

under Georgia law in an amount to be proven at trial as well as for all special damages, for lost

income and diminution in earnings capacity, in an amount to be proved at trial, and for past, present

and future medical expenses in an amount not less than $171,595.08;

(f) That a judgment be entered against each Defendant named in Count V and in favor of

Plaintiff Victoria S. Bowles for punitive damages, pursuant to O.C.G.A. § 51-12-5.1, in an amount

to be determined by the enlightened conscience of a fair and impartial jury;

(i) That, pursuant to Count VI Plaintiff Victoria S. Bowles recover her attorney’s fees and

expenses of litigation against all named Defendants under the provisions of O.C.G.A. § 13-6-11, as

well as permitted by law, in an amount to be proven at trial;

(j) That Plaintiff have a trial by jury; and

(k) That Plaintiff have other and further relief as this Honorable Court deems legal, just, and

equitable.

RESPECTFULLY SUBMITTED this 12th day of July, 2023.

/s/ Robert C. Buck

Robert C. Buck
Georgia Bar No. 092495

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P.O. Box 921429
Peachtree Corners, Georgia 30010-1429

/s/ J. Phillip Boston

J. Phillip Boston
Georgia Bar No. 069525
Law Office of J. Phillip Boston
P.O. Box 8084
Athens, Georgia 30603-8084

Attorneys for Plaintiff

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