IN THE SUPERIOR COURT OF LOWNDES COUNTY
STATE 0F GEORGIA
GEORGIA LOWNDES COUNTY
Filed in office this
KENNETH JOHNSON and
JUL 1 5 2019
Clerk Superior (fourt/State Court]
CIVIL ACTION N0. 2018CV2074
WILBUR M. “BILL” WATSON and
AUSTIN J. FIVEASH as Coroners
for Lowndes County, Georgia,
SUPPLEMENTAL BRIEF IN SUPPORT OF
MOTION TO DISMISS PETITION FOR MANDAMUS
Defendants Wilbur M. “Bill” Watson and Austin J. Fiveash file this Supplemental
Brief in Support of Motion to Dismiss Plaintiffs’ Petition for Mandamus (“the Petition”)
and show the Court as follows:
Plaintiffs come to this court under the guise of seeking mandamus relief in the
form of an order compelling the Lowndes County Coroner to conduct a coroner’s inquest
to determine the cause of death of their son, Kendrick Johnson. A coroner’s inquest is
not warranted or required in this case. OCGA § 45-16—27(a).1 Even a cursory reading of
the Petition, and amendments thereto, discloses the Plaintiffs’ true motive. They come to
this court seeking a determination that their son, Kendrick Johnson, was murdered by
Brian Bell and Brandon Bell.
Plaintiffs have filed at least six (6) separate lawsuits
l The Petition is barred by the Coroner’s determination of the cause and manner of death of Kendrick
Johnson. The former Coroner has already determined the cause of death and is satisfied with that
determination. (See Exhibits A, B and C).
claiming that their son’s death was not accidental and falsely accusing the Bells of
murdering their son. 2
The claims and issues in those lawsuits were adjudicated
adversely to Plaintiffs, and the Petition in this case should therefore be dismissed.
1. Former Coroner Bill Watson Should be dismissed.
As appears from the Affidavit of Lowndes County Coroner Austin Fiveash
(Exhibit D) Fiveash was elected Lowndes County Coroner in 2016 and took
office January 1, 2017. He has been the Coroner at all times since then.
Watson was f