IN THE UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF MISSISSIPPI

SOUTHERN DIVISION
D.H., by and through her next friend and
Parent, Robert Holmes PLAINTIFF
VS. CIVIL ACTION NO. 1:13CV466-HSO-RHW
MOSS POINT SCHOOL DISTRICT, et al. DEFENDANTS
DEFENDANTS MOTION TO COMPEL RULE 35 PSYCHIATRIC EXAMINATION
All Defendants move the Court to enter an order compelling Plaintiff D.H. to submit to a Rule 35
psychiatric examination and in support state as follows:
1. In her Complaint, D.H. alleges claims of bullying and harassment on account of her gender
expression and sexual orientation in vilation of Title IX of the Education Amendments of 1972, 20 U.S.C.
1681, et seq. and the Equal Protection Clause of the Fourteenth Amendment. [1, 1]. D.H. has
specifically put her psychiatric/psychological health at issue in the following ways:
D.H.s complaint contains allegations of suicidal thoughts: "The harassment was so severe that in
February 2011, nearly two months after her earlier suicide attempt, D.H. had a breakdown in class
where she expressed suicidal thoughts. A crisis intervention team was called to the school." [1, p.
11]).
The Complaint contains multiple references to "injuries." [1, 66, 74].
The Complaint contains several prayers for "damages." [1, 74, 76-77]. The complaint confirms
the plaintiff seeks money for physical and/or psychological damages in addition to her prayer for
injunctive relief.
2. By alleging mental and emotional injuries, D.H. has placed her mental condition at issue. The
Defendants are, therefore, entitled to an independent psychiatric examination of D.H.
Case 1:13-cv-00466-HSO-RHW Document 29 Filed 08/19/14 Page 1 of 3
35023811_1 2
3. Dr. John Thompson is a licensed psychiatrist and is the Director of Forensic Psychiatry at Tulane
University. Dr. Thompson will be designated by the Defendants as an expert in this case. He is qualified to
evaluate D.H.s claims that the Defendants conduct caused her alleged mental and emotional injuries. Dr.
Thompson is also qualified to review medical and psychiatric records pertaining to D.H. in order to evaluate
her allegations of emotional injuries and to formulate an opinion regarding her mental and emotional
condition. Dr. Thompsons curriculum vita is attached as Exhibit 1.
4. The Court has already ordered the relief now sought by the Defendants: The Defendants may
have a Fed. R. Civ. P. 35 (L.U.Civ.R. 35) medical examination of the plaintiff . . . by a physician who has
not examined the plaintiff. The examination must be completed in time to comply with expert designation
deadlines." [Case Management Order, 20, p. 3]. Despite the existing Court order, counsel for D.H. have
objected to the examination. During the August 14, 2014, hearing regarding D.H.s objection, the Court
requested Defendants submit this motion.
5. The Defendants ask the Court to order D.H. to appear for a psychiatric examination to be
performed by Dr. John Thompson on September 22, 2014, at 10:00 a.m. in Moss Point, Mississippi, at a
location mutually agreeable to the parties. Exhibit 2.
Respectfully submitted, this 19th day of August 2014.
Moss Point School District
Moss Point School District Board of Education
Superintendent Maggie Griffin
Durand Payton
/s/ John S. Hooks
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35023811_1 3
OF COUNSEL:
James A. Keith
Mississippi Bar No. 3546
John S. Hooks
Mississippi Bar No. 99175
Adams and Reese LLP
1018 Highland Colony Parkway, Suite 800
Ridgeland, Mississippi 39157
Telephone: 601.353.3234
Facsimile: 601.355.9708
CERTIFICATE OF SERVICE
I, John Hooks, hereby certify that I have this day filed a true and correct copy of the above
document with the Clerk of the Court using the CM/ECF System, which caused notice of filing to be served
on all registered counsel of record.
Dated: August 19, 2014.
/s/ John S. Hooks
Case 1:13-cv-00466-HSO-RHW Document 29 Filed 08/19/14 Page 3 of 3
CURRICULUM VITAE
JOHN W. THOMPSON, JR, M.D.
May 2014
Address: Tulane University School of Medicine
Department of Psychiatry and Behavioral Science TB 53
1440 Canal Street, 10th Floor
New Orleans, Louisiana 70112
Telephone: (504) 988-0847
Birthplace & Date: June 3, 1956 New Orleans, Louisiana
EDUCATION:
University of Texas at San Antonio, San Antonio, Texas. August 1979 May
1982, B.S. in Biology.
University of Texas Medical Branch, Galveston, Texas. June 1982 May 1986,
M.D.
University of Florida, College of Medicine, Gainesville, Florida, July 1986 June
1990, Psychiatric Residency Training.
University of Florida, College of Medicine, Gainesville, Florida, July 1989 June
1990, Forensic Fellow in Psychiatry.
BOARD CERTIFICATION:
ABPN - Diplomate of the American Board of Psychiatry and Neurology, in
Psychiatry, April 1992. #35664
ABPN - Added qualifications in Forensic Psychiatry, December 1994. #244
ABPN - Added qualifications in Addiction Psychiatry, June 1998, #1518.
ABPN - Board Examiner Part II, 1995 to present.
LICENSURE:
Louisiana Medical License 09107R, March 1992.
EX. 1
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JOHN W. THOMPSON, JR., M.D.
PAGE 2
ACTIVITIES IN MEDICAL, PROFESSIONAL OR MENTAL HEALTH
ORGANIZATIONS:
American Psychiatric Association, 1985-present.
Louisiana Psychiatric Medical Association, 1992-present.
American Academy of Psychiatry and the Law, 1990-present.
American Academy of Addiction Psychiatry, 1992-present.
American Academy of Forensic Sciences - 1996 to present.
Forensic Director, State of Louisiana. National Association of State Mental
Health Directors, September 1993 to present.
Co-Chairman, Law & Psychiatry Think Tank, joint venture between Tulane and
LSU, February 2003 to August 2005.
Tulane University School of Medicine Department of Psychiatry & Neurologys
Executive Finance Committee 1995 to present.
Tulane University School of Medicine FPP Executive Committee July 1, 2003
to present.
Tulane University School of Medicine Billing and Collection Subcommittee
July 1, 2003 to August 2005.
COMMUNITY SERVICE, CIVIC & SOCIAL ACTIVITIES:
Active Participant in Triathlons and long distance cycling events since 1986.
MILITARY SERVICE:
United States Air Force, July 29, 1976 - July 28, 1982, Radiologic technician,
Rank E-5. Supervised weekend shift radiology department at Wilford Hall
Medical Center, 1977-1982.
United States Air Force, 9/30/88 to 6/30/92, Rank O-3. Served as Inpatient Staff
Psychiatrist and periodic appointments as Inpatient Chief at Wilford Hall Medical
Center, San Antonio, Texas, 1990-1992.
EX. 1
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JOHN W. THOMPSON, JR., M.D.
PAGE 3
CLINICAL APPOINTMENTS:
Wilford Hall Medical Center, San Antonio, Texas. Inpatient Attending
Psychiatrist. July 1, 1990.
Wilford Hall Medical Center, San Antonio, Texas. Acting Inpatient Chief,
periodic appointments, January 1991 September 1992.
Medical Director, Addictive Behavior Unit, The Ochsner Clinic, New Orleans,
Louisiana, June 15, 1992 to August 31, 1993. .
Clinical Director for Feliciana Forensic Facility and Eastern Louisiana Mental
Health System in Jackson, Louisiana, September 1, 1993 to present.
Chief of Staff, Eastern Louisiana Mental Health System, March 2002 present.
ADMINISTRATIVE APPOINTMENTS:
Undergraduate Education Committee, Graduate Education Committee, Resident
Selection Committee, Department of Psychiatry, University of Florida, 1986-
1990.
Quality Assurance/Risk Management Coordinator for the Division of Mental
Health. Entailed supervising the QA/RM for Depts. of Psychiatry, Psychology,
Social Work and Occupational Therapy, Wilford Hall Medical Center, June 5,
1991 to January 31, 1992.
Coordinator in Dept. of Psychiatry WHMC for implementation and operating
instructions of Clozaril Treatment System, January-August 1991.
Quality Assurance/Risk Management Coordinator for the Addictive Behavior
Unit, Ochsner Clinic, New Orleans, Louisiana, June 1992 to August 31, 1993.
Physician Advisor, The Ochsner Health Plan, September 1992 to August 31,
1993.
ACADEMIC APPOINTMENTS:
Associate Clinical Professor, University of Florida, Department of Psychiatry,
1990 to present.
Associate Clinical Professor, University of Texas Health Science Center at San
Antonio, May 1991 to June 1992.
Associate Professor of Clinical Psychiatry, Tulane University School of
Medicine, September 1, 1993 to June 30, 2004.
EX. 1
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JOHN W. THOMPSON, JR., M.D.
PAGE 4
ACADEMIC APPOINTMENTS (continued):
Promoted to Professor of Clinical Psychiatry, Tulane University School of
Medicine, July 1, 2004 to present.
Director of the Division of Forensic Neuropsychiatry, Tulane University School
of Medicine, September 1, 1993 - present.
Founding Director of Fellowship in Forensic Psychiatry, Tulane University
School of Medicine, July 1, 1994 - present.
Vice-Chairman of Adult Psychiatry, Department of Psychiatry & Neurology,
Tulane University School of Medicine, January 1, 2000 - present.
TEACHING ACTIVITIES:
Forensic Seminar Series, Civil, Criminal, Malpractice with Landmark Case
review in specific areas. Wilford Hall Medical Center to PGY-2 Residents,
March 1991 and February 1992.
Forensic Seminar Series, University of Texas Health Science Center, 10 lecture
series on various aspects of Forensic Psychiatry and Risk Management, July-
October 1991.
"Malingered Post-Traumatic Stress Disorders." presented to National Association
of Disability Examiners conference, Austin, Texas, October 10, 1991.
"Informed Consent and Right to Refuse Treatment in Psychotropic Prescribing."
CME conference PRACTICAL RISK MANAGEMENT FOR THE MENTAL
HEALTH PROFESSIONAL, University of Florida College of Medicine, Division
of CME, November 23, 1991.
Preceptor for UTHSC Medical Students on Interviewing and "AMSIT" Mental
Status Examination training, September-December 1991.
Forensic Seminar Series, Co-chaired with Dr. Gene Usdin for PGY-3 and PGY-4
Residents at Ochsner Clinic, Louisiana State University and Tulane University.
October to December 1992.
Substance Abuse Seminar Series, for PGY-2 residents at the Ochsner Clinic, New
Orleans, September to December 1992.
"The History of the Insanity Defense." Grand Rounds Presentation, Department
of Psychiatry, The Ochsner Clinic, January 12, 1993.
EX. 1
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JOHN W. THOMPSON, JR., M.D.
PAGE 5
TEACHING ACTIVITIES (continued):
"Adolescence and Addiction." CME Conference - 5th Annual Outpatient
Management in Family Practice, Ochsner Clinic, New Orleans, April 17, 1993.
"The History of the Insanity Defense." Grand Rounds Presentation, Department
of Psychiatry, Tulane University School of Medicine, October 1, 1993.
Presentation on Gambling Addiction, Biloxi Regional Medical Center, Biloxi,
MS, Fall 1993.
"PRIME-MD: A New Instrument for Diagnosing Mental Disorders in Primary
Care." Program Director for this CME presentation, December 11, 1993 and
October 29, 1994. Featuring Dr. Sheldon Preskorn.
"Gambling: Fun to Addiction." Guest speaker at annual Byron Griffith Memorial
Presentation, Tulane University School of Medicine, May 19, 1994.
"Informed Consent, Medication Refusal." Coordinator of state forensic CME
presentation, Southeastern Louisiana State Hospital, June 3, 1994.
Grand Rounds Presentations, Feliciana Forensic Facility, "Competency to Stand
Trial," June 30, 1994; "History of Insanity Defense," July 22, 1994; "Right to
Refuse Treatment," September 1, 1994; "Involuntary Commitment," October 6,
1994.
Presented lectures in Forensic Fellowship Seminar Series: "Historical Figures in
Forensic Psychiatry," "History of Insanity Defense," "Criminal Responsibility in
Insanity Defense," "Involuntary Hospitalization," "Competency to be Executed,"
"Informed Consent," Right to Treatment/Right to Refuse Treatment, July 1994
- present.
"Competency to be Executed." Psychiatry Journal Club, Tulane University School
of Medicine, November 9, 1994.
"Jail Psychiatry." Public Psychiatry Course lecture, Tulane University School of
Medicine, November 10, 1994.
"Confidentiality/Right to Treatment." Forensic Seminar at Ochsner Clinic, New
Orleans, LA, November 15, 1994.
"Substance Abuse in the Elderly." at Neuropsychiatric Aspects of Primary Care
CME Symposium, Le Pavillon Hotel, New Orleans, LA, February 19, 1995.
"Manson Family Values." Grand Rounds Presentation, Department of Psychiatry,
Tulane University School of Medicine, March 3, 1995.
EX. 1
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JOHN W. THOMPSON, JR., M.D.
PAGE 6
TEACHING ACTIVITIES (continued):
"Gambling." Addictions Jazzfest Conference, Le Monteleone Hotel, New
Orleans, LA, May 6, 1995
"Compulsive Gambling: A Professional Prospective." Minnesota Council on
Compulsive Gambling Presentation, Tulane University School of Medicine,
July 25, 1995.
"Forensic Issues in Correctional Psychiatry." Janssen CNS Roundtable
Discussion, San Antonio, Texas, September 1, 1995.
"Medical Ethics and Forensic Psychiatry." Yale/Ochsner Board Review Course,
New Orleans, LA, September 1995 - 1997.
Director, Tulane's Homecoming CME Program, Clinical & Forensic Aspects of
Psychoses. Presented "Novel Antipsychotics & Competency Restoration."
October 14, 1995.
"Right to Treatment/Right to Refuse Treatment." New Dimensions in Mental
Health Administration Course, Le Monteleone Hotel, New Orleans, LA,
October 30, 1995.
"Assessment of Dangerousness for Release of Insanity Acquittees." Grand
Rounds Presentation, Central Louisiana State Hospital, December 14, 1995.
"Gambling Addiction." Presentation to the Phoenix Society, Tulane University
School of Medicine, March 6, 1996.
"Psychiatric Testimony in the Jeffrey Dahmer Trial." Psychiatry Journal Club,
Tulane University School of Medicine, April 17, 1996.
"Psychosis '96." Visiting Faculty Training Program, Atlanta, GA, April 19-21,
1996.
Faculty member for Interactive Medical Network's psychLINK's live, interactive
video symposium, "Aggression in the Treatment of Schizophrenic Inpatients."
Dallas, Texas, May 1, 1996.
"Domestic Violence." Women's Mental Health '96 Conference, Westin Canal
Place Hotel, New Orleans, LA, May 2, 1996.
"Adult Forensic Psychiatry: Transitioning to the Community." Intercontinental
Hotel, New Orleans, LA, September 3, 1996.
EX. 1
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JOHN W. THOMPSON, JR., M.D.
PAGE 7
TEACHING ACTIVITIES (continued):
"The Right to Treatment/Right to Refuse Treatment." New Dimensions in Mental
Health Administration Course, Royal Sonesta Hotel, New Orleans, LA, October
1996.
"Compulsive Gambling: From Fun to Addiction." DePaul Hospital, New Orleans,
LA, March 28, 1997.
"Medical Ethics and Forensic Psychiatry." Patton State Hospital, Patton, CA,
April 9, 1997.
"Risperdal in Competency Restoration." Terrell State Hospital, Terrell, TX,
May 15, 1997.
"The Insanity Defense, History and Practical Applications." and "Informed
Consent and Psychotropic Medications." East Louisiana State Hospital, June 3,
1997.
"Use of Risperidone and Competency to Stand Trial." Medical Center for Federal
Prisoners, Springfield, MO, September 3, 1997.
"Informed Consent - Malpractice and Antipsychotic Medication." Symposium,
Springfield, MO, September 3, 1997.
"Overview of Pathological Gambling." Minnesota Council on Compulsive
Gambling Conference. Tulane University School of Medicine, September 11,
1997.
"Bad Boys, Bad Boys, What you gonna do?" Presentation on sexual predators at
East Louisiana State Hospital, September 23, 1997.
"The Insanity Defense from Hale to Hinckley." Presentation to Orleans Parish
District Attorney's Office, December 13, 1997
"Aggression in Psychiatric Patients." Presentation to Big Spring Texas State
Hospital, December 18, 1997.
"Aggression and Violence in Psychiatric Patients: A Correctional Perspective."
Miami, Orlando, Tallahassee, FL, March 3-5, 1998.
"Competency Restoration." Vernon State Hospital. "Aggression and Violence in
Psychiatric Patients." Trinity Springs Hospital. March 25-26, 1998.
"Mental Illness Behind Bars." Public Psychiatry Class, Tulane University School
of Medicine, April 16, 1998.
EX. 1
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JOHN W. THOMPSON, JR., M.D.
PAGE 8
TEACHING ACTIVITIES (continued):
"Aggression and Violence in Psychiatric Patients." Presentation to state medical
directors, Baton Rouge, LA, April 17, 1998.
Training in evaluation and treatment of sexual predators. East Louisiana State
Hospital, April 20, 1998.
"Aggression and Violence in Psychiatric Patients." Fulton State Hospital, Fulton,
MO, April 30, 1998.
"Aggression and Violence in Psychiatric Patients." Mid-Missouri Mental Health
Center, Columbia, MO, April 30, 1998.
"Gambling: From Fun to Addiction." Symposium, St. Louis, MO, April 30, 1998.
"Aggression and Violence in Psychiatric Patients." St. Louis State Hospital, St.
Louis, MO, May 1, 1998.
"Aggression and Violence in Psychiatric Patients." St. Louis County Jail, St.
Louis, MO, May 1, 1998.
Chairperson for APA Scientific and Clinical Report Session "Psychosocial
Factors in Violence and Risk for Self-Harm." Toronto, Canada, June 4, 1998.
"Aggression and Violence in Psychiatric Patients." Symposium, New York, NY,
July 15, 1998.
"Informed Consent, Malpractice and Psychotropic Medications." Staten Island
Clinic, New York, NY, July 16, 1998.
"Use of Atypical Antipsychotics to Control Aggression." Cherokee Mental
Health Institute, Cherokee, IA, August 11, 1998.
"Aggression and Violence in Psychiatric Patients." Symposium, Des Moines, IA,
August 14, 1998.
"Use of Atypical Antipsychotics to Control Aggression." Independence Mental
Health Institute, Independence, IA, August 19, 1998.
"Aggression and Violence in Psychiatric Patients." Program, Cedar Rapids, IA,
August 19, 1998.
"Malpractice, Informed Consent, and Antipsychotic Medication." Symposium
for community health professionals, Lafayette, LA, September 21, 1998.
"Malpractice, Informed Consent and Antipsychotic Medication." Grand Rounds,
Tulane University School of Medicine, September 25, 1998.
EX. 1
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JOHN W. THOMPSON, JR., M.D.
PAGE 9
TEACHING ACTIVITIES (continued):
Moderator and Program Chair for Criminal Justice Advisory Board. Windsor
Court Hotel, New Orleans, LA, October 14, 1998
"Paraphilias." Tulane Psychiatry Department Homecoming Presentation, Westin
Hotel, New Orleans, LA, October 17, 1998.
"Ethics in Forensic Psychiatry." South Beach Psychiatric Hospital, Staten Island,
New York, October 30, 1998.
"Informed Consent." Grand Rounds, St. Vincents Medical Center, Staten Island,
New York, October 30, 1998.
"Insanity Defense." Presentation to Tulane's Medical/Legal Society, Tulane
University School of Medicine, New Orleans, LA, November 11, 1998.
"Aggression & Violence in Psychiatric Patients." Presentation to NW Montana
Psychiatric Rehabilitation Center, St. Joseph, MO, November 12, 1998.
"Malpractice, Informed Consent and Antipsychotic Medication." Symposium,
Kansas City, KS, November 12, 1998.
"Aggression & Violence in Psychiatric Patients." Colmery O'Neil VA Medical
Center, Topeka, KS, November 13, 1998.
"Aggression and Violence in the Seriously Mentally Ill." Presentation to Georgia
Best Practices Conference, Atlanta, GA, November 17, 1998
"Restraints in Outpatient Clinics." Presentation to Louisiana State Medical
Director's Council Meeting, March 22, 1999.
Chairperson, Criminal Justice National Advisory Board, Laguna Niguel, CA,
April 29-May 1, 1999.
"Informed Consent and Malpractice." Psychiatry Journal Club, University of
Texas at Houston, Houston, TX, June 8, 1999
"Review Panels: Assessment Strategies - A Systematic Approach to Assessing
Patients before Conditional Release." Presentation for Southeast Louisiana State
Hospital staff, June 24, 1999.
"Correctional Psychiatry in Louisiana." Presentation to the National Alliance for
the Mentally Ill, Lake Charles, LA, August 6, 1999.
EX. 1
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JOHN W. THOMPSON, JR., M.D.
PAGE 10
TEACHING ACTIVITIES (continued):
"Violence and Aggression in Psychiatric Patients." Lincoln Regional Center,
Lincoln, NE, August 19, 1999.
"Violence and Aggression in Psychiatric Patients." Symposium, Omaha, NE,
August 19, 1999.
"Violence and Aggression in Psychiatric Patients." Symposium, Des Moines, IA,
August 24, 1999.
"Malpractice, Informed Consent and Antipsychotic Medication." Cherokee
Mental Health Institute, Cherokee, IA, August 25, 1999.
"Forensic Report Writing and Psychiatric Testimony." Presented to medical staff
of ELMHS, Jackson, LA, September 14, 1999.
"Aggression and Violence in Psychiatric Patients." Clifton T. Perkins Hospital
Center, Jessup, MD, September 21, 1999.
"Aggression and Violence in Psychiatric Patients." Kings Contrivance,
Columbia, MD, September 21, 1999.
Cycle of Urban Unemployment, Crime and Drugs. Moderator of this
multimedia session at APAs 51
st
Institute on Psychiatric Services, New Orleans,
LA, November 1, 1999.
Violence and Psychosis in Correctional Settings. Presentation at APAs 51
st
Institute on Psychiatric Services, New Orleans, LA, November 2, 1999.
Malpractice, Informed Consent. NW MO Psychiatric Rehab Center, St. Joseph,
MO, November 18, 1999.
Violence and Aggression in Psychiatric Patients. Symposium, Kansas City,
MO, November 19, 1999.
Testamentary Capacity. Roundtable discussion with residents of University of
Kansas, Wichita, KS, December 13, 1999.
Insanity Defense. Presentation to community based psychiatrists, Wichita,
Kansas, December 13, 1999.
Malpractice, Informed Consent. Grand Rounds Presentation at University of
Kansas, Wichita, Kansas, December 14, 1999.
EX. 1
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JOHN W. THOMPSON, JR., M.D.
PAGE 11
TEACHING ACTIVITIES (continued):
Violence and Aggression in Psychiatric Patients. Symposium. Kingwood,
Texas, February 9, 2000.
Violence and Aggression in Psychiatric Patients. Life Resource MHMR,
Beaumont, Texas, February 10, 2000.
Ethics and Forensic Psychiatry. Symposium. The Palm, Houston, Texas,
February 10, 2000.
Violence and Aggression in Psychiatric Patients. San Quentin Prison,
California, March 16, 2000.
Violence and Aggression in Psychiatric Patients. Symposium, Sacramento,
CA, March 16, 2000.
Violence and Psychosis: Patterns and Themes of Aggression. Grand Rounds at
Napa State Mental Hospital, Napa, CA, March 17, 2000.
Director of Cycle of Violence: Assessment and Management of Aggression,
Tulane University School of Medicines Mardi Gras Symposium, New Orleans,
LA, February 25-27, 2000.
Violence and Psychosis: Patterns and Themes of Aggression. Presentation at
Tulane University School of Medicines Mardi Gras Symposium, New Orleans,
LA, February 25, 2000.
Informed Consent. Presented to Tulane University Medical Schools
Medical/Legal Society, March 22, 2000.
Patterns and Themes of Aggression in the Mentally Ill. Grand Rounds at Mercy
Hospital and Clinics, Des Moines, Iowa, July 25, 2000.
Patterns and Themes of Aggression in the Mentally Ill. Grand Rounds at
Minnesota Security Hospital, St. Peter, Minnesota, July 27, 2000.
Patterns and Themes of Aggression in the Mentally Ill. Grand Rounds at Anoka
Treatment Center, Anoka, Minnesota, July 28, 2000.
"Patterns and Themes of Aggression in Correctional Psychiatry." Presentation to
Annual CME Conference for Central NY Psychiatric Association, September 27,
2000.
"Patterns and Themes of Aggression in Correctional Psychiatry." Presentation to
Riker's Island Psychiatric and Pharmacy Staff, September 28, 2000.
EX. 1
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JOHN W. THOMPSON, JR., M.D.
PAGE 12
TEACHING ACTIVITIES (continued):
Director of Sex, Spies, & Videotape: Forensic Issues on the Fringe, Tulane
University School of Medicines Mardi Gras Symposium, February 16-18, 2001.
Doctors Who Kill: Privileging and Credentialing Gone Mad." Presentation at
Tulane University School of Medicines Mardi Gras Symposium, Sex, Spies, &
Videotape: Forensic Issues on the Fringe. New Orleans, LA, February 18, 2001.
Doctors Who Kill: Privileging and Credentialing Gone Mad." Grand Rounds,
Baylor University School of Medicine, Houston, Texas, March 7, 2001.
Doctors Who Kill: Privileging and Credentialing Gone Mad. Presentation at the
Workshop Current and Future Trends in Psychiatry and Criminal Law. APA
Meeting, New Orleans, May 9, 2001.
Aggression in Psychiatric Patients. Grand Rounds. Our Lady of the Lake
Hospital, Baton Rouge, May 17, 2001.
Doctors Who Kill: Privileging and Credentialing Gone Mad. Grand Rounds at
East Tennessee State University, July 6, 2001.
Aggression and Violence in Psychiatric Patients. Grand Rounds, Tulane
University School of Medicine, July 27, 2001.
Workplace Violence. Workshop on Violence Risk Assessment. Delta
Community Mental Health Services, Region V., Jackson, MS, August 17, 2001.
Leadership Role in Root Cause Analysis. Sentinel Event: Conducting Root
Cause Analysis Conference, LSU Faculty Club, Baton Rouge, LA, September 6,
2001.
"Jails as the New Mental Hospitals." Public Psychiatry Course lecture, Tulane
University School of Medicine, March 15, 2002.
Managing Schizophrenia: Raising the Standard of Care. Covington, LA,
April 10, 2002.
Director of Current Controversies in Forensic Psychiatry, Tulane University
School of Medicines French Quarter Festival Symposium, April 12-14, 2002.
Treatment of Schizophrenia with Atypicals and Medico-Legal Considerations in
Institutional Settings and Consent to Treatment. Orlando, FL, April 23, 2002.
EX. 1
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JOHN W. THOMPSON, JR., M.D.
PAGE 13
TEACHING ACTIVITIES (continued):
Malpractice, Informed Consent and Antipsychotic Medication. Alexandria
Mental Health Center, May 2, 2002.
Maternal Filicide. Womens Mental Health Conference, Tulane University
School of Medicine, New Orleans, LA, June 22, 2002.
Filicide. Child Psychiatry Grand Rounds, Tulane University School of
Medicine, New Orleans, LA, August 30, 2002.
The Management of Aggression in Forensic Settings. 10
th
Annual Forensic
Rights and Treatment Conference, Drexel University College of Medicine,
December 5, 2002.
Psychopharmacology of Aggression. Breakout group at Brain & Behavior:
Clinical Neuroscience Comes of Age, Tulane University School of Medicine, Le
Meridien Hotel, December 14, 2002.
Malingering: Guidelines for Forensic Assessment. Grand Rounds, University of
Texas at Houston, Houston, TX, February 12, 2003.
Assessment and Management of Aggression in Psychiatric Inpatients. Kansas
City, MO, March 19, 2003.
Correctional Psychiatry: Treating Aggression with Atypical Antipsychotics.
Presentation to Missouri Correctional Psychiatrists, Independence, MO,
March 20, 2003.
Director of Crime, Psychiatry and New Orleans History, Tulane University
School of Medicines French Quarter Festival Symposium, April 11-13, 2003.
Bernard Marigny: Creole Aristocrat Invents Craps, Loses Fortune. Update on
Compulsive Gambling Assessment and Treatment. Presentation at Tulane
University School of Medicines French Quarter Festival Symposium, Crime,
Psychiatry & New Orleans History, New Orleans, LA, April 11, 2003.
Roundtable Discussion, Cardiac Side Effects of Atypical Antipsychotics.
Mortons Steak House, New Orleans, LA, April 23, 2003.
Overview of Forensic Psychiatry, presented to Tulane Medical Students
Psychiatry Journal Club, April 30, 2003.
Moderator, Louisiana Mental Health Conference, Baton Rouge, LA, May 21,
2003.
EX. 1
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JOHN W. THOMPSON, JR., M.D.
PAGE 14
TEACHING ACTIVITIES (continued):
Informed Consent, Malpractice, and Antipsychotic Medication. Louisiana
Mental Health Conference, Baton Rouge, LA, May 21, 2003.
Schizophrenia: The Cancer Equivalent of the Mentally Ill. Presentation at the
Royal Sonesta Hotel, New Orleans, LA, June 4, 2003.
Informed Consent, Malpractice and Antipsychotic Medications. CME
presentation at Our Lady of the Lakes Tau Center, Baton Rouge, June 19, 2003.
Informed Consent and Atypical Antipsychotics. Region 1 Staff meeting, New
Orleans, LA, September 23, 2003.
Forensic Psychiatry Consultation to Professional Boards. Given to Physical
Therapy Board, Lafayette, LA, September 25, 2003.
Gambling. Filicide. Informed Consent in Antipsychotic Treatment.
Assessment and Treatment of Aggression in Schizophrenia. CME Programs to
Texas Academy of Family Physicians, Beaumont, TX, October 11, 2003.
Pediatric Death Investigation Including Subtle Forms of Fatal Abuse: From the
Scene to the Courtroom. Workshop, American Academy of Forensic Sciences
Annual Meeting, February 17, 2004.
Antipsychotic Drugs and the Criminal Justice System. Neuroethics
Symposium, Co-sponsored by the Tulane Chapter of Sigma Xi, the Tulane
Neuroscience Program, and the Murphy Center for Ethics and Public Affairs of
Tulane University, March 11, 2004.
Informed Consent and the Treatment of Clients with OCDD. LA Academy of
Family Physician Foundation Advances in Clinical Practice for People with
Developmental Disabilities, March 18, 2004.
Informed Consent. Aggression in Schizophrenic Patients. CME Program
through Texas Academy of Family Physicians to Nurses and Physicians at
Alexandria Country Club, Alexandria, LA., April 1, 2004.
Community Outpatient Treatment Readiness and Manson Family Values.
CME Program through Texas Academy of Family Physicians to Nurses and
Physicians at Central State Hospital, Pineville, LA, April 2, 2004.
Director of Forensic Psychiatry Looks at Sex, Drugs and Rock n Roll, Tulane
University School of Medicines French Quarter Festival Symposium,
April 16-18, 2004.
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JOHN W. THOMPSON, JR., M.D.
PAGE 15
TEACHING ACTIVITIES (continued):
Neuropsychiatric Approaches to the Assessment and Treatment of Agitation,
Aggression and Dangerousness. Presentation at Cook County Jail, Chicago, IL,
May 27, 2004.
Violence in the Workplace. Presentation at Phelps Dunbar law firm,
November 4, 2004.
Co-Chair, Primer for Forensic Mental Health Evaluations and Mental Health
Lawyers: Training in Ethical Principles, Competency Evaluation, and
Competency Restoration, New Orleans, LA, November 15, 2004.
Expert Testimony for Mental Health Professionals, and Forensic Evaluations for
Community Placement. Presentation at Primer for Forensic Mental Health
Evaluations and Mental Health Lawyers: Training in Ethical Principles,
Competency Evaluation, and Competency Restoration, New Orleans, LA,
November 15, 2004.
Grand Rounds. Filicide. Tulane University Health Sciences Center,
February 11, 2005.
Filicide Classification and Psychological Evaluation of Perpetrators. Workshop at
American Academy of Forensic Sciences, New Orleans, LA. February 21, 2005.
Director of Forensic Psychiatry Goes to Hollywood, Tulane University School of
Medicines French Quarter Festival Symposium, April 8-10, 2005.
Internet Sexual Addiction: Obsessive Compulsive Disorder or Paraphilia NOS?
Social Work and the Law: Expanding Parameters/Diversity in Practice
Conference, New Orleans, La. April 19, 2005.
Director of Forensic Psychiatry and Athletics, Tulane University School of
Medicines French Quarter Festival Symposium, April 21-23, 2006.
Gambling and Athletics. Tulane University School of Medicines French
Quarter Festival Symposium, April 21-23, 2006.
Director of Forensic Psychiatry Post-Katrina: Lessons Learned Post-Disaster.
Tulane University School of Medicines French Quarter Festival Symposium,
April 13-15, 2007.
Grand Rounds. Management of Aggressive Behavior in Schizophrenia. Tulane
University School of Medicine, September 7, 2007.
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JOHN W. THOMPSON, JR., M.D.
PAGE 16
TEACHING ACTIVITIES (continued):
Director of Forensic Psychiatry: Great Men, Sick Minds? Tulane University
School of Medicines French Quarter Festival Symposium, April 11-13, 2008.
Medical/Legal Issues in Psychiatry and Working with the Court System, Our
Lady of the Lake Regional Medical Center; The 5
th
Annual Francisco Silva
Distinguished Lecture Series, November 14, 2008.
Forensic Psychiatry: Something Short of Insanity-Criminal Law in Louisiana.
Presentation to Louisiana Association of Criminal Defense Lawyers, December 5,
2008.
Director of Forensic Psychiatry: The Many Faces of Antisocial Personality
Disorder. Tulane University School of Medicines French Quarter Festival
Symposium, April 17-19, 2009.
Director of Forensic Psychiatry: Back to the Basics: A Primer in Forensic
Psychiatry/Psychology. Tulane University School of Medicines French Quarter
Festival Symposium, April 9-11, 2010.
Overview of State Forensic System. Presentation at Tulane University School
of Medicines French Quarter Festival Symposium, April 9, 2010.
Malingering in Forensic Evaluations. Presentation at Tulane University School
of Medicines French Quarter Festival Symposium, April 10, 2010.
Psychiatric Aspects of Fitness to Dive: From Initial Evaluation to the Courtroom.
Medical Assessment of Fitness for Diving, sponsored by the Undersea and
Hyperbaric Medical Society, Sheraton Hotel, New Orleans, LA., October 15,
2010.
Director of Forensic Psychiatry: Hot Topics in Forensic Psychiatry. Tulane
University School of Medicines French Quarter Festival Symposium,
April 15-17, 2011.
Medical Marijuana: From Joints to Jurisprudence. Presentation at Tulane
University School of Medicines Brain & Behavior 2011, 16
th
Robert G. Heath
MD Lecture, December 2, 2011.
Director of Forensic Psychiatry: Update on Criminal Forensic Behavioral
Health: From Eye Witness Testimony to the Death Penalty, Tulane University
School of Medicines French Quarter Festival Symposium, April 13-15, 2012.
EX. 1
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JOHN W. THOMPSON, JR., M.D.
PAGE 17
TEACHING ACTIVITIES (continued):
Psychiatric Aspects of Fitness to Dive: From Initial Evaluation to the Courtroom.
Medical Assessment for Fitness to Diving, sponsored by the Diving and
Hyperbaric Medical Educators, Sheraton Hotel, New Orleans, LA., January 20,
2013.
Director of Forensic Psychiatry: "Notorious: Lessons from the Darker Side of
Forensic Psychiatry". Tulane University School of Medicines French Quarter
Festival Symposium, April 12-14, 2013.
Director of Forensic Psychiatry: From Sexual Sadism to Maternal/Fetal
Rights. Tulane University School of Medicines French Quarter Festival
Symposium, April 11-13, 2014.
PEER-REVIEWED PUBLICATIONS:
Beighley PS, Brown GR, Thompson JW: "DSM-III-R Reactive Psychosis among
Air Force Recruits." Journal of Clinical Psychiatry, September 1992.
Newman AW, Thompson JW. "Constitutional Rights and Hypnotically Elicited
Testimony." Journal of the American Academy of Psychiatry and the Law,
Vol. 27, No. 1, 1999.
Newman AW, Thompson JW: "The Rise and Fall of Forensic Hypnosis in
Criminal Investigation." Journal of the American Academy of Psychiatry and the
Law, Vol. 29, No. 1, 2001.
LeBourgeois HW III, Foreman TA, Thompson JW: Drug Seeking in Veterinary
Clinics: Prescription for Disaster. Veterinary Technician, Vol. 22, No. 9,
September 2001.
LeBourgeois HW, Foreman TA, Thompson JW: Novel Cases: Malingering by
Animal Proxy. J Am Acad Psychiatry Law 30:520-4, 2002.
Bertman LJ, Thompson JW, Waters WF, Estupinan-Kane L, Martin J, Russell L:
Effect of an Individualized Treatment Protocol on Restoration of Competency in
Pretrial Forensic Inpatients. J Am Acad Psychiatry Law 31:27-35, 2003.
Pena JM, Franklin R, Thompson JW, Minyard F, Carbin C: The Influence of
French, Spanish, and English Legal Traditions on Early Mental Health Proceeding
in Louisiana. Journal of the American Academy of Psychiatry and the Law
31:345-53, 2003.
EX. 1
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JOHN W. THOMPSON, JR., M.D.
PAGE 18
PEER-REVIEWED PUBLICATIONS (continued):
Bertman-Pate LJ, Burnett D, Thompson JW, Calhoun CJ, DeLand S, Fryou RM:
The New Orleans Forensic Aftercare Clinic: A Seven Year Review Hospital
Discharged and Jail Diverted Clients. Behav. Sci. Law 22: 159-169, 2004.
McDermott B, Thompson, JW: Review Panel Process: An Algorithm for the
Conditional Release of Insanity Acquittees. International Journal of Law &
Psychiatry, 2005.
Manguno-Mire G, Thompson J, Bertman-Pate L, Burnett D, Thompson H. Are
Release Recommendations for NGRI Acquittees Informed by Relevant Data?
Behavioral Sciences and the Law 25: 43-55 (2007).
Manguno-Mire GM, Thompson JW, Shore, JH, Croy CD, Artecona JF, Pickering
JW, The Use of Telemedicine to Evaluate Legal Competence: A Preliminary
Randomized Controlled Study. J Am Acad Psychiatry Law 34:481-9, 2007.
Tohtz D, Thompson JW, Deliberate Indifference Revisited on the Question of
Denial of Psychiatric Medication. J Am Acad Psychiatry Law 34:531-2, 2007.
Koenen M, Thompson JW. "Filicide: Historical Review and Prevention of Child
Death by Parent." Infant Mental Health Journal, Vol 29(1), 61-75 (2008).
Advokat, C.D., Burnett, D.M., Guidry, D., Manguno-Mire, G., & Thompson, Jr.,
J.W. (in Press). Competency restoration treatment: Differences between
defendants competent declared competent or incompetent to stand trial. Journal
of the American Academy of Psychiatry and the Law.
NON-PEER REVIEWED PUBLICATIONS:
Thompson JW, Calhoun C.: "Judicial Inferences of Insidious Proclivities Ruled
Not Enough, Louisiana v. Perez." Newsletter American Acad Psych & the Law,
Vol 20, #2, September 1995.
Thompson JW, Vazzana A: Curbside Consultation submitted to American
Family Physician on scenario "A pregnant woman who is the victim of physical
abuse." July 2002.
AAPL Task Force. Practice Guideline: Forensic Psychiatric Evaluation of
Defendants Raising the Insanity Defense. Journal of the American Academy of
Psychiatry and the Law, Vol 30, Number 2, 2002.
Michael L. Perlin JD: On Desolation Row. Review of Mr. Perlins presentation
at 2002 AAPL Annual Meeting. AAPL Newsletter, April 2003.
EX. 1
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JOHN W. THOMPSON, JR., M.D.
PAGE 19
BOOK CHAPTERS:
Thompson JW, Winstead DK: "Impulse Control Disorders, chapter of
publication CURRENT DIAGNOSIS & TREATMENT IN PSYCHIATRY,
Appleton & Lange Publications, 2000.
Thompson JT, LeBourgeois HW, Black FW: Malingering, chapter of
American Psychiatric Publishing Textbook of Forensic Psychiatry, 2004.
Thompson JW, Artecona J, Bora B. Medical Malpractice, Psychiatry.
International Encyclopedia of Forensic and Legal Medicine. Edited by Payne-
James J, Byard R, Cory T, Henderson C. Published in June 2005.
Thompson JW, Newman AW: Forensic Hypnosis, chapter of publication
APPLIED CRIMINAL PSYCHOLOGY, a guide to forensic behavioral sciences.
Edited by Richard N. Kocsis, PhD. Published in 2009.
ABSTRACTS:
Thompson JW, Giorgi-Guarnieri DL, Zonana HV, Ciccone JR: "Legislative and
Judicial Approaches to Treatment Refusal." AAPL Meeting, October 1994.
Thompson JW, Calhoun CC, Janofsky JS, Vosburg C: "Judicial Decision Making
after Foucha: State v. Perez." AAPL Meeting, October 1995.
Soong CS, Thompson JW: "Pathological Gambling in a Forensic Setting." AAPL
Meeting, October 1995.
Norko MA, Weinstein, HC, Berger BR, Thompson JW, Hanson AL: "Psychiatry
Between a Rock and a Barred Place." AAPL Meeting, October 1997.
Carrington D, Thompson J, Pena J: "Requests for Protective Custody of the
Mentally Ill: the family's role in rapid intervention and the prevention of harm."
APA, Toronto, Canada, June 1998.
Scott CS, Thompson, J, Utter, D, Cullen J, McDermott BE: "Death Penalty
Evaluator - Examiner or Executioner?" Presentation at AAPL Meeting, Fairmont
Hotel. New Orleans, LA, October 25, 1998.
Carrington D, McDermott BE, Thompson J: Danger by Age: Analysis of
Forensic Sex Offenders. Presentation at AAPL Meeting, Baltimore, MD,
October 14, 1999.
McDermott BE, Thompson J: Mad or Bad? The Release of Insanity Aquittees.
Presentation at AAPL Meeting, Baltimore, MD, October 15, 1999.
EX. 1
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JOHN W. THOMPSON, JR., M.D.
PAGE 20
ABSTRACTS (continued):
Draft AAPL Practice Guideline for NGRI Evaluations. Presentation of the Task
Force, Vancouver, Canada, AAPL Meeting, October, 2000.
"Review Panel Process in Louisiana, Conditional Release Decision-Making."
Presentation to National Association of State Mental Health Program Directors,
Chandler, Arizona, December 5, 2000.
"A Procedure for the Restoration to Competency: A Critical Pathways Approach."
Presentation to National Association of State Mental Health Program Directors,
Chandler, Arizona, December 6, 2000.
Behavioral Addictions: Impulse Disorders and the Law. AAPL Meeting,
Boston, MA, October 25, 2001.
Novel Cases: Malingering By Proxy in Animal. AAPL Meeting, Boston, MA,
October 27, 2001.
Psychiatric Evaluation of Filicide Perpetrators. Pediatric Death Investigation
Including Subtle Forms of Fatal Abuse: From the Scene to the Courtroom.
American Academy of Forensic Sciences, Atlanta, GA, February 11, 2002.
Moderator of Mock Trial, Capital Punishment in Texas: Law and Order or an
Abuse of Authority, American Academy of Psychiatry and Law Meeting, San
Antonio, TX, October 16, 2003.
Treatment Algorithms in the Correctional Setting. Workshop at American
Academy of Psychiatry & the Law Meeting, Scottsdale, AZ, October 21, 2004.
Expert Consensus Guidelines for the Treatment of Bipolar Disorder in the
Correctional Setting. Workshop at American Academy of Psychiatry & the Law
Meeting, Montreal, Canada, October 27, 2005.
Telemedicine in Forensic Psychiatry Applications and Acceptance. American
Academy of Psychiatry and the Law Meeting, Montreal Canada, October 29,
2005.
PROFESSIONAL PUBLICATIONS REVIEWED:
Guest reviewer, Journal of Clinical Psychopharmacology, April, 1992 to present.
Guest reviewer, Psychiatric Times, January, 1993.
Guest reviewer, Journal of Clinical Psychiatry, August, 1992 to present.
EX. 1
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JOHN W. THOMPSON, JR., M.D.
PAGE 21
PROFESSIONAL PUBLICATIONS REVIEWED (continued):
Associate Editor, AAPL Newsletters, 1998 to April 2010.
Guest Reviewer for Journal of American Academy of Psychiatry and the Law,
1998 to present.
FORENSIC COURT EXPERIENCE:
Qualified as expert witness in Florida State Courts and in Federal Court in
Florida.
Appointed as an expert consultant by USAF at WHMC in 1990-1992.
Appointed by courts in Florida to render opinion on Competency to Stand Trial or
Mental State at the Time of Offense in 75 to 100 legal cases.
Appointed by military courts to render opinion on Competency to Stand Trial and
Mental State at Offense.
Over 300 Medical Evaluation Board Exams performed in Military to render
psychiatric diagnosis, impairment and prognosis for Military members presented
to Medical Evaluation boards.
Qualified as an expert in field of Forensic Psychiatry in civil and criminal court
throughout Louisiana.
HONORS:
Chief Resident, Department of Psychiatry, University of Florida, 1989-1990.
Listed in The Best Doctors in America (1996-1997; 1997-1998; 2001-2002;
2007-2008 and 2011-2012)
Distinguished Visiting Professor, Wilford Hall Medical Center, San Antonio, TX,
June 19-23, 1995.
Elected Fellow of the American Psychiatric Association, December, 2000.
Named Distinguished Fellow of the American Psychiatric Association, February,
2003.
Associate Editor, Journal of the American Academy of Psychiatry and the Law,
Newsletter, 3-year term through October, 2014.
EX. 1
Case 1:13-cv-00466-HSO-RHW Document 29-1 Filed 08/19/14 Page 21 of 21
IN THE UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF MISSISSIPPI
SOUTHERN DIVISION
D.H., by and through her next friend and
Parent, Robert Holmes PLAINTIFF
VS. CIVIL ACTION NO. 1:13CV466-HSO-RHW
MOSS POINT SCHOOL DISTRICT, et al. DEFENDANTS
DEFENDANTS NOTICE OF RULE 35 PSYCHIATRIC EXAMINATION
To: All Counsel of Record
Please take notice that, pursuant to Federal Rule of Civil Procedure 35, the psychiatric examination
of D.H. will be conducted by Dr. John Thompson on September 22, 2014, at 10:00 a.m. The examination
will consist of Dr. Thompsons interview of D.H. and his review of any records D.H. produces at the
examination. The examination will take place in Moss Point, Mississippi, at a location to be agreed upon by
the parties.
Respectfully submitted, this 19th day of August 2014.
Moss Point School District
Moss Point School District Board of Education
Superintendent Maggie Griffin
Durand Payton
/s/ John S. Hooks
EX. 2
Case 1:13-cv-00466-HSO-RHW Document 29-2 Filed 08/19/14 Page 1 of 2
35023316_1 2
OF COUNSEL:
James A. Keith
Mississippi Bar No. 3546
John S. Hooks
Mississippi Bar No. 99175
Adams and Reese LLP
1018 Highland Colony Parkway, Suite 800
Ridgeland, Mississippi 39157
Telephone: 601.353.3234
Facsimile: 601.355.9708
CERTIFICATE OF SERVICE
I, John Hooks, hereby certify that I have this day filed a true and correct copy of the above
document with the Clerk of the Court using the CM/ECF System, which caused notice of filing to be served
on all registered counsel of record.
Dated: August 19, 2014.
/s/ John S. Hooks
EX. 2
Case 1:13-cv-00466-HSO-RHW Document 29-2 Filed 08/19/14 Page 2 of 2