Holcomb et al v. Wells Fargo Bank, N.A. et al

Filing 41

ORDER denying 32 Motion for Hearing; granting 33 Motion to Compel; granting 36 Motion for Protective Order; denying 38 Motion to Compel; granting in part and denying in part 28 Motion to Compel. Signed by Magistrate Judge G. R. Smith on 1/11/13. (bcw)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF GEORGIA
SAVANNAH DIVISION
MARIA GOULD HOLCOMB,
and HENRY C. HOLCOMB,
Plaintiff,
v.

Case No. CV412-111

WELLS FARGO BANK, N.A. and
FEDERAL HOME MORTGAGE
CORPORATION, d/b/a FREDDIE
MAC,
Defendants.

ORDER
In this lender-liability case, plaintiffs Marla and Henry Holcomb
move to compel discovery from defendants Wells Fargo Bank, N.A. (WFB)
and the Federal Home Loan Mortgage Association (Freddie Mac). Doc.
28, as amended, doc. 33. Defendants oppose and request oral argument.
Docs. 30 & 32. 1 WFB moves to withdraw its Fed. R. Civ. P. 36(b)
admissions (doc. 31), and it is granted, per the plaintiffs’ agreement.

1

Their hearing request motion is DENIED . Doc. 32.

Doc. 34. And plaintiffs move to amend their motion to include a missing,
“duty to confer” certificate. Doc. 33. 2

I. BACKGROUND
Marla Holcomb owned a North Georgia home and was current on its
mortgage when she asked WFB to lower her interest rate. 3 Doc. 10 at 3.
A WFB representative told her that WFB would not consider a loan
modification until she first missed three monthly mortgage payments.

Id. So, she did. Id. Holcomb’s default triggered the bank’s mortgage
foreclosure process, but WFB’s attorney assured her that the loan was
approved “for a special repayment program.”
confirmed this.

Id. Two follow-up letters

Id. WFB’s attorney later sent Holcomb a “notice of

foreclosure sale,” which WFB told her to disregard, so she did.

Id.

Holcomb next received a WFB letter announcing that it had changed
its mind and would not modify the loan. Just days later -- on January 3,
2012 -- WFB foreclosed on her home. Doc. 10 at 3. But Holcomb was
unaware of that until January 11, 2012, when she received two more WFB
2

This motion, unopposed under L OCAL RULE 7.5, is GRANTED.
For the purpose of this Order, the Court is accepting as true the factual assertions
contained in plaintiffs complaint (doc. 1-1), as well as their portion of the Joint Status
Report. Doc. 10.
2
3

letters. The first invited her to explore her options to avoid foreclosure.
The second was from its lawyer, informing her that “Freddie Mac now
owns the property . . . as the result of a foreclosure.”

Id.

Alleging that she was misled, never received notice of the foreclosure
sale, and could have cured her default, Holcomb sued. Doc. 1-1; doc. 10 at
3. She contends that the defendants committed various lender-liability
wrongs. 4 Her husband joins her because “he used the home with his wife
and has been affected by the actions against [her].” Doc. 10 at 3-4.
WFB denies liability and insists that it timely and consistently
communicated with Marla Holcomb but she failed to transmit required
documentation to it in a timely manner. It denies it ever misled her, too.

4

She plies, inter alia promissory estoppel, contract breach, fraud, bad faith, and
,
emotional distress claims. Doc. 1-1 at 5-6; doc. 10 at 5; doc. 28-1 at 28; see Joseph v.
Fed. Home Loan Mortg. Corp. , 2012 WL 5429639 at * 2-3 (N.D. Ga. Nov. 6, 2012)
(wrongful foreclosure case brought by plaintiff told to stop making payments in order
to qualify for a loan modification; “If [the lender] did make such a statement and
foreclosed anyway, Plaintiff has stated a plausible claim for wrongful foreclosure
based on [its] failure to exercise the power of sale fairly and in good faith.”); Odimbur
v. Wells Fargo Bank, 2012 WL 680057 at * 4 (C.D. Cal. Mar. 1, 2012) (denying motion
to dismiss three-missed-payment, promissory estoppel claim); see also Szlek v. U.S.
Bank Nat‘l Ass'n , 2012 WL 3756941 at * 3 (N.D. Ga. Aug. 28, 2012) (rejecting
borrower’s promissory estoppel claim against lender, in promised loan modification
case, “because the promise alleged by Plaintiff is too vague”); Zions First Nati’l Bank
v. Macke, 316 Ga. App. 744, 752-53 (2012) (lender violated terms of mortgage loan by
accelerating debt before 15 day cure period had expired); see also Daily Report at 1
(Dec. 14, 2012) (borrower awarded $1.2 million against that bank).
3

Doc. 10 at 4; doc. 30-7 at 11-12. And Freddie Mac insists it simply
purchased the property at foreclosure, breaching no duty to the Holcombs.
Doc. 4; doc. 10 at 4.
The plaintiffs served the defendants discovery requests aimed at
uncovering all the documents, policies, and people who were behind their
loan modification and foreclosure, plus similarly situated others. They
are unhappy with defendants’ responses. In their motion to compel, they
complain that the defendants have wrongfully asserted privileges, made
bad-faith “clarification” requests prior to answering, and failed to provide
adequate responses (by stating, e.g., that when the information is
obtained it will be provided pursuant to a mutually agreeable
arrangement). Doc. 28 at 1.
Defendants respond that the plaintiffs have mischaracterized their
actions and that they have answered the discovery as best they can,
especially since some “discovery requests were addressed to the party
without ownership or control of the requested information”--

i.e. ,

plaintiffs sought from WFB material in Freddie Mac’s possession or
control. Doc. 30 at 2. Defendants also assert that plaintiffs exercised
4

their Fed. R. Civ. P. 26(c) and 37(a)(2) duty to confer with defendants on
only some, but not all, matters, so this Court should deny the motion “and
permit the parties to address the discovery dispute pursuant to their
obligations under the federal rules.” Doc. 30 at 2. Plaintiffs reply that
they fulfilled their duty to confer and that defendants are still obstructing
some of their discovery. Doc. 35.

II. GOVERNING STANDARDS
Rule 26 of the Federal Rules of Civil Procedure provides that
“[p]arties may obtain discovery regarding any nonprivileged matter
that is relevant to any party's claim or defense. . . .” Fed. R. Civ. P.
26(b)(1) (emphasis added). “Relevant information need not be
admissible at the trial if the discovery appears reasonably calculated to
lead to the discovery of admissible evidence.”

Id.

Those who invoke a privilege must prove its existence.

In re

Grand Jury Investigation, 842 F.2d 1223, 1225 (11th Cir. 1987).
Hence, parties cannot simply claim an “in-house” privilege, but only
those recognized by law. And evidentiary privileges, for that matter,
are disfavored.

Adkins v. Christie , 488 F.3d 1324, 1328 (11th Cir.
5

2007); 28 U.S.C. § 2074(b).
“Where a motion to compel is granted, attorney fees and expenses
must be awarded to the prevailing party unless there was no good faith
effort to resolve the motion, the non-disclosure was substantially justified,
or other circumstances make an award of expenses otherwise unjust. Fed.
R. Civ. P. 37(a) (5).”

FormFactor, Inc v. Micro-Probe, Inc 2012 WL
.,

1575093 at * 9 (N.D. Cal. May 3, 2012). “Additionally, Rule 37(b)
requires a disobedient party to pay the reasonable expenses, including
attorney fees, caused by the violation of the order. See Fed. R. Civ. P.
37(b)(2)(C).”

Id.

III. ANALYSIS
A. Duty to Confer
Defendants first insist that plaintiffs have failed to (a) certify their
good faith efforts to resolve this dispute without Court intervention, and
(b) comply with Rule 26.5’s requirement that the movant shall quote each
discovery request verbatim and include the specific ground for the motion
or objection. Doc. 30 at 7-9. On part (a) of their argument defendants
specifically note that plaintiffs failed to include an express certification.
6

Doc. 30 at 7. On part (b), they say that plaintiffs did not negotiate
enough.

Id. at 7-9.

By local rule this Court reminds parties of their duty to confer.
Local Rule 26.4 (“[c]ounsel are reminded that Fed. R. Civ. P. 26(c) and
37(a)(2) require a party seeking a protective order or moving to compel
discovery to certify that a good faith effort has been made to resolve the
dispute before coming to court.”). That rule is enforced. Scruggs v. Int’l

Paper Co., 2012 WL 1899405 at * 2 (S.D. Ga. May 24, 2012). 5
The plaintiffs did provide a certification, just not a standalone
certificate, doc. 28 at 17, though they cured that via amendment. Doc.
33. For that matter, substance, not form, controls. Plaintiffs’ recitation
of some of its discovery questions and responses (doc. 28-1 at 3-17) are
adequate, though not perfect. So, the Court, which simply needs to be
5

Requiring meaningful consultation can lead to informal resolution and thus
conservation of court resources. Avera v. United Airlines, Inc ., 2012 WL 794160 at *
2 (11th Cir. Mar. 13, 2012) (magistrate judge did not abuse his discretion in denying,
without prejudice, plaintiff's motion to compel discovery where plaintiff had not
sought to resolve his discovery dispute with defendant before filing the motion); In re
Rhodes Companies, LLC , 475 B.R. 733, 742 (D. Nev. 2012) (affirming bankruptcy
court’s denial of protective-order motion based on moving party’s failure to include
such certification, rejecting “futility” assertion); Jo Ann Howard & Associates, P.C. v.
Cassity, 2012 WL 1247271 at * 8 (E.D. Mo. Apr. 13, 2012) (rejecting compulsion
request in part because “the failure of the parties to communicate materially impeded
their resolution of this matter.”) (emphasis added).
7

able to see what was asked and how it was answered, will address those.
Meanwhile, defendants’ substantive argument -- that plaintiffs did
not confer enough -- is more difficult to address. Just as “there is “no
magic formula” for determining whether a particular government action
constitutes a taking of property, Arkansas Game and Fish Com'n v.

United States, ___ U.S. ___, 133 S.Ct. 511, 518 (2012), there is none for
assessing good faith here. The totality of the facts and circumstances
necessarily must be considered.
The record shows that on the document requests the parties did
confer directly through an exchange of letters and emails. Doc. 28-1.
But “[p]laintiffs’ counsel’s correspondence,” defendants insist, “shows he
failed to comply with the good faith requirement and that [defense
counsel] attempted to address the concerns in a timely matter.” Doc. 30
at 7. The problem, defendants explain, is that “[p]laintiffs’ counsel sent
five letters to [defense counsel] raising different and equally vague issues
about [d]efendants’ discovery responses.”

Id.

The Court will address this argument by first examining the
plaintiffs’ document requests, which called on WFB to produce (Request #
8

1) “[a]ll policies and requirements applicable to the procedure for a
modification request for the type of loan you were holding for Ms.
Holcomb in effect from January 2, 2011 to date.” Doc. 28-1 at 15. They
also sought (Request # 2) “[t]he complete file pertaining to Mrs.
Holcomb’s request,” the (Request # 3) “payment history on her loan,”
and (Request # 4) the “files on all other borrowers who requested loan
modification who were not in default at the time of the requests from
January 2, 2011 to date.”

Id. 6

On Request # 1 WFP agreed to produce relevant, unprivileged
documents at a mutually agreeable time and place. Doc. 28 at 3; doc.

6

The Court’s review is hampered by the fact that, in their “compel” brief plaintiffs
related their Document Request 4 as “The complete file pertaining to the default and
disclosure of the subject property including those documents pertaining to Freddie
Mac’s acquisition of the loan and property.” Doc. 28 at 5. While plaintiffs point out
that this is from their request for production served with their complaint, id. , n 1, they
furnish a different Request for Production of Documents with their brief’s “Index.”
See doc. 28-1 at 13-15. The defendants, for that matter, also note this disconnect, doc.
30 at 12-13, to which plaintiffs fail to respond in their reply brief. Doc. 35. The
Court will limit its review to that shorter version (i.e . , doc. 28-1 at 15).
Further burdening this Court: The plaintiffs listed, on page 1 of their Index of
Exhibits, their opening discovery as “Attached,” yet have failed to attach them (e.g.,
WFP’s and Freddie Mac’s August and September, 2012 responses). Defendants
likewise have failed to cite accurately their documents on the docket. For example,
they claim they “produced the entire loan file. See Exhibit D." Doc. 30 at 12. But
“Exhibit D” is a “confer” letter. Doc. 30-4. Perhaps they mean “Exhibit J.” Doc.
30-10. Such imprecision impedes an otherwise tedious review of the requests and
responses, then the “confer” chain, as required to discern any Rule 37 violations.
9

30-1 at 3. On October 1, 2012, plaintiffs’ counsel wrote WFB’s counsel
and noted that its response was late, so its objections were moot. More
importantly, WFB furnished them with “a CD disc of over 760 pages” but
no accompanying means to identify which pages responded to which
request. Doc. 28-1 at 16. Plaintiffs supplied defendants with CD
excerpts to show that it would require speculation to connect the dots
together.

Id. at 19-24. Hearing nothing, plaintiffs wrote again, on

October 5, 2012. Doc. 28-1 at 25.
WFB says it contacted plaintiffs and “offered to help upon review of
the discovery responses.” Doc. 30 at 8. The email from defense counsel
does not deny that WFB sent plaintiffs an undifferentiated mass of
documents. Nor did it claim that there had been a mistake in production.
Instead, its counsel simply said: “We’ll certainly be happy to work with
you to supplement our responses. We can talk in more detail once I’ve
had a chance to take a little further look.” Doc. 28-1 at 34.
A good faith answer would have been: “That was an honest mistake.
I’ll send you that information immediately.” Yet, that answer was not
given. And defense counsel weighed the process down even further by
10

making plaintiff’s counsel wait: “we can talk in more detail. . . .”
Plaintiff’s counsel, Stanley E. Harris, Jr., then responded with an
October 5, 2012 fax letter, stating that he had not heard from defense
counsel and set an October 15 compliance deadline. After that, Rule 37
would be invoked. Doc. 28-1 at 25. He also complained of other
deficiencies in the defendants’ discovery responses, most particularly
plaintiffs’ quest for the lenders’ loan-modification policies.

Id.

Defense attorney Tracy Starr then tele-conferred with Harris. Doc.
28-1 at 27. In a follow-up, October 9, 2012 letter, Harris summarized
that conversation: WFB stood on Freddie Mac’s “restrictions” on
disclosing its policy (incidentally, neither defendant has moved for a
protective order, 7 nor cited then or here any law to uphold any privilege).
Starr also claimed that plaintiffs had not requested “certain information.”
Harris pointed out Starr’s disclosure that Freddie Mac was the investor
and WFB acted in its interest. That means, he reasoned, that WFB was
Freddie Mac’s agent and thus WFB’s discovery responses should have
confirmed at least that much.
7

Id. Yet, they did not. Id. at 28. After

See, e.g. , U.S. ex rel. St. Joseph's Hosp., Inc. v. United Distributors, Inc ., 2012 WL
5511729 at * 5 (S.D. Ga. Nov. 14, 2012) (granting partial relief to protective-order
movant).
11

supplying further grounds to justify disclosure, Harris noted WFP’s
promise to supplement the CD response with an index and actually supply
cross-references for its documents.

Id.

On October 12, 2012, WFB supplemented its responses to plaintiffs’
requests for admissions, as well as to plaintiffs’ supplemental
interrogatories. Doc. 30-8. And, on October 15, 2012, WFB and Freddie
Mac each produced an “Index of Documents SFB 0001-1763, Produced on
September 10, 2012.” Doc. 30-10 at 1-7. The WFB response tied specific
document clusters (by their Bates stamp numbers) to each document
request. Doc. 30-10 at 1-4. It stood on its refusal to provide files on
other borrowers (obviously plaintiffs want to see if WFB did to others
what plaintiffs claim it did to Marla Holcomb) because WFB “is prohibited
by law from distributing the confidential financial information of its
clients to third parties.” Doc. 30-10 at 3. But, WFB failed to cite any
particular precedent. Harris wrote back on October 16, 2012, further
complaining of defendants’ non-responsiveness. Doc. 28-1 at 30-32. He
filed plaintiffs’ compel motion on October 30, 2012. Doc. 28.
As for the document requests, the Court is satisfied that the duty to
12

confer requirement was met. As for plaintiffs’ other requests it is a
closer call, but the correspondence and teleconference place plaintiffs over
the line on the matters reached here. Thus the Court rejects defendants’
“certification” argument outright, but partly accepts its “duty to confer”
argument. That leaves the substantive dispute here -- whether
defendants satisfactorily complied with plaintiffs’ discovery requests.

B. Document Requests
To reiterate, plaintiffs requested that WFB (Request # 1) produce
“[a]ll policies and requirements applicable to the procedure for a
modification request for the type of loan you were holding for Ms.
Holcomb in effect from January 2, 2011 to date.” Doc. 28-1 at 15. They
also sought (Request # 2) “[t]he complete file pertaining to Mrs.
Holcomb’s request,” the (Request # 3) “payment history on her loan” and
(Request # 4) the “files on all other borrowers who requested loan
modification who were not in default at the time of the requests from
January 2, 2011 to date.”

Id.

The parties’ discovery dispute here has ultimately come to rest not
on the actual document disclosure on Requests ## 1-3, but on the lack of
13

differentiation -- defendants’ failure to tell plaintiffs which of the
documents that defendants pertained to which request. Hence,
defendants failed to provide them with an index of some sort. Plaintiffs
complain that “no ‘index’ was provided.” Doc. 28 at 15, 16.
But defendants say that they “produced their document indexes on
October 15, 2012,” and their documentation establishes that. Doc. 30 at
8. And prior to that, they reason, they were asked to produce the loan
file, which they did, but plaintiffs never did specify what sort of index they
wanted: “The request did not seek an index, and Defendants do not know
what sort of index to which Plaintiffs’ counsel contends he is entitled.”
Doc. 30 at 10.
Plaintiffs in fact did specify what they wanted: that the documents
produced be referenced to each of their document requests. And it is
undisputed that defendants initially failed to comply. Only after Harris
wrote to complain did they finally do so on October 15, 2012. Doc. 30-10.
Defendants claim that they “voluntarily provided an ‘index’ which
identified which Bates stamped documents responded to which requests.”
Doc. 30 at 12 (emphasis added). Of course, that is what they should have
14

produced up front (i.e., tie each pile of documents to its corresponding
discovery request, commonly known as an index). They thus were being
obstructionistic.
Still, the “confer” process worked. Plaintiffs were unhappy, there
was some back and forth, and defendants ultimately coughed up that
information -- prior to the motion to compel. So, the Court rejects the
plaintiffs’ compulsion and sanctions request on that score, as the record
shows that they in fact succeeded in prying the indices out of defendants
just before they filed their motion to compel. That it may have been
exasperating to plaintiffs’ counsel (his need to dictate and send
compulsion letters) is understandable, but the Rules draw the line at
when cost-shifting sanctions may be awarded, and that line was drawn at
compliance prior to the filing of a compel motion. 8
Meanwhile, plaintiffs do correctly illuminate another WFB
8

It is worth noting, however, that pre-filing obstructionism is certainly not the way
to practice before this Court. Plaintiffs have not invoked the sanctions mechanism of
Fed. R. Civ. P. 26(g), which requires the imposition of an “appropriate sanction” on
either the party or the attorney (“or both”) who improperly certifies that a discovery
response is complete, consistent with the rules, and not interposed for purpose of delay
or needlessly increasing the cost of litigation. Rule 26(g)(1),(3). The Court will not
here resort to that rule sua sponte, but defense counsel should bear that rule in mind
before submitting additional discovery responses in this or any other case before this
Court.
15

roadblock in response to their first document request: WFB “states that
the policies and guidelines pertaining to the loan modification request at
issue in this matter are the business confidential property of Freddie
Mac.” Doc. 30-10 at 1. In their latest brief plaintiffs emphasize that “it
is glaringly clear no policies pertaining to the loan modification have been
disclosed.” Doc. 35 at1.
The Court grants plaintiffs relief to the extent that WFB is
withholding any documents based on its own (or any other’s) business
policies, much less any “law or privilege” -- for the simple reason that
WFB carries the burden of identifying any law or privilege and showing
why it applies here. It has not met its burden (generic assertions won’t
do). Mystifyingly, plaintiffs did not, once told by WFB that Freddie Mac
was the proper target, issue a new document request to Freddie Mac for
those documents. 9
On the other hand, both defendants are represented by the same
counsel, and it is undisputed that WFB implemented Freddie Mac’s
policies. To save time, then, the Court deems the request made to
9

This failure undermines plaintiffs’ quest for Rule 37 costs, as they knowingly left
the defendants with a non-frivolous objection. Hence, the Court awards no costs.
16

Freddie Mac and directs the parties to submit a protective order under
which plaintiffs’ counsel may review any loan-modification policy applied
to Marla Holcomb. And if that policy is disclosed on a public website then
both defendants shall download and verbatim reproduce for plaintiffs the
actual wording from same. Such policy is certainly relevant to plaintiffs’
allegation that, whether recklessly or deliberately, WFB induced Marla
Holcomb into an engineered default and wrongful foreclosure. That a
policy forbade, induced, enabled, or in any material way influenced such
reliance would unquestionably be relevant to plaintiffs’ claims.
Similarly, it is not beyond the pale of reason to imagine that such
equity-stripping may have occurred during the Holcomb foreclosure time
frame.

See W. H UDSON , T HE M ONSTER : H OW A GANG OF P REDATORY

L ENDERS AND WALL S TREET BANKERS F LEECED AMERICA-- AND S PAWNED A
GLOBAL C RISIS (Times Books, Oct. 2010); Yates v. U.S. Bank Nat. Ass'n ,
2012 WL 6115016 at * 14 (E.D. Mich. Dec. 10, 2012) (affirming, in
wrongful foreclosure suit, order to disclose lender information on decision
to proceed with foreclosure, plus lender’s internal policies; “it is very
relevant to know: (1) whether Defendants complied with their own
17

internal policies, and (2) the reasons for denying the permanent
modification and proceeding with foreclosure of the home.”).
The Court is aware of defendants’ sensitivity to Request # 4, which
seeks the “files on all other borrowers who requested loan modification
who were not in default at the time of the requests from January 2, 2011
to date.” It is narrowed to those who were not in default when they
sought a loan modification, yet were foreclosed upon, then claimed they
were misled or deceived by WFB. The request is deemed served on both
defendants. The Court will accept a proposed protective order in that
regard. Defendants shall comply within 21 days of the date this Order is
served.

C. Interrogatories
The briefing has winnowed the remainder of the parties’ dispute
down to just a few items, see doc. 35 at 1-5, and they go to defendants’
interrogatory responses. Plaintiffs want the defendants to identify all
loan policies as applied to Marla Holcomb, and they want the identity of
any individuals familiar with the specific facts of this case. Doc. 35 at 1.
They also want to know the names of the individuals who created the
18

disclosed documents. Doc. 30 at 13.
WFB insists its response is complete. It says it has identified all
individuals with knowledge of Marla Holcomb’s foreclosure, doc. 30 at 13,
and it “does not know the identities of all such individuals, and the names
on the documents [that it] produced are reasonably available to the
[p]laintiffs.”

Id. Plaintiffs fail to say what more the defendants can do

on that score, so their motion to compel is denied to that extent.
Next, plaintiffs want to know from Freddie Mac “any facts regarding
the disposition of the contents of the home foreclosed upon which tangible
items were not collateral for the loan at issue.” Doc. 35 at 1. They
apparently reference their Interrogatory # 6 to Freddie Mac, which asked
it to identify individuals who removed “content from the subject
property.” Doc. 30 at 16. This defendant has responded: “Freddie Mac
does not know who removed the items. . . .”

Id. Plaintiffs do not specify

what more can be compelled from this defendant, so their motion is denied
on these grounds, too.
The Holcombs move for a protective order. Doc. 36. They want to
postpone their January 16, 2013 depositions until after they have had the
19

benefit of the discovery sought here.

Id. at 2-3. Discovery currently

ends on January 21, 2013. Doc. 27. The Court grants the motion and
extends discovery until March 1, 2013. The parties shall work out new
deposition dates within that time frame. Defendants’ motion to compel
plaintiffs’ depositions for January 16, 2013, is denied. Doc. 38.

IV. CONCLUSION
The Court GRANTS in part and DENIES in part plaintiffs’ Motion
to Compel (doc. 28). The Court DENIES defendants’ oral-argument
motion, doc. 32, grants WFB’s motion to withdraw its admissions, doc. 31,
and GRANTS plaintiffs’ motion to amend their motion to compel, doc. 33,
as well as their motion for a protective order. Doc. 36. Defendants’
motion to compel plaintiffs’ depositions for January 16, 2013, (doc. 38) is

DENIED .
SO ORDERED , this 11th day of January, 2013.

UNITED STATES MAGISTRATE JUDGE
SOUTHERN DISTRICT OF GEORGIA

20