DOCUMENT 241

ELECTRONICALLY FILED
1/25/2023 5:57 PM
31-CV-2018-900346.00
CIRCUIT COURT OF
ETOWAH COUNTY, ALABAMA
CASSANDRA JOHNSON, CLERK
IN THE CIRCUIT COURT OF ETOWAH COUNTY, ALABAMA

ROY MOORE, )
)
Plaintiff, )
v. )
CV-2018-900346
)
RICHARD HAGEDORN, et )
al., )
)
)
Defendants/Counterclaim )
Plaintiff )
)
v. )
)
ROY MOORE, JUDGE ROY )
MOORE FOR US SENATE; )
HERRING NETWORKS, INC., )
JANET PORTER, )
FICTITIOUS DEFENDANTS 1-5, whether singular or plural,
Counterclaim Plaintiff hereby intending to designate the entity or those
entities, including persons, who or which made false and defamatory
statements regarding Richard Hagedorn; FICTITIOUS
DEFENDANTS 6–10, whether singular or plural, Counterclaim
Plaintiff hereby intending to designate the entity or those entities,
including persons, who or which invaded Richard Hagedorn’s privacy
and/or placed him in a false light; FICTITIOUS DEFENDANTS 11–21,
whether singular or plural, Counterclaim Plaintiff hereby intending to
designate the entity or those entities, including persons, who or which
engaged in a conspiracy against Richard Hagedorn to make false and
defamatory statements against him, invade his privacy, and place him in
a false light; FICTITIOUS DEFENDANTS 22–25 whether singular or
plural, Counterclaim Plaintiff hereby intending to designate the entity or
those entities, including persons, who or which were Janet Porter’s
employer and/or principal; FICTITIOUS DEFENDANTS 26–30
whether singular or plural, Plaintiff hereby intending to designate the
entity or those entities, including persons, who or which are the
 DOCUMENT 241

successors in interest to any defendant or fictitious defendant;

FICTITIOUS DEFENDANT 31, whether singular or plural, Plaintiff
hereby intending to designate the entity which is the correct legal
description of the entity or individual listed herein as Roy Moore;
FICTITIOUS DEFENDANT 32, whether singular or plural, Plaintiff
hereby intending to designate the entity which is the correct legal
description of the entity or individual listed herein as Judge Roy Moore
For US Senate; FICTITIOUS DEFENDANT 33, whether singular or
plural, Plaintiff hereby intending to designate the entity which is the
correct legal description of the entity or individual listed herein as Janet
Porter; FICTITIOUS DEFENDANT 34, whether singular or plural,
Plaintiff hereby intending to designate the entity which is the correct
legal description of the entity or individual listed herein as Herring
Networks, Inc.; FICTITIOUS DEFENDANTS 35–45, whether singular
or plural, Counterclaim Plaintiff hereby intending to designate the entity
or those entities, including persons, who or which are Heath Jones’s
employer(s), principal(s), and/or co-conspirator; Counterclaim Plaintiff
avers that the identity of the fictitious party defendants herein is
otherwise unknown to Counterclaim Plaintiff at this time, or if their
names are known to Plaintiff at this time, their identify as proper party
defendants is not known to Counterclaim Plaintiff at this time, and their
true names will be substituted by amendment when ascertained.
)
Counterclaim Defendants. )

RICHARD HAGEDORN’S ANSWER & COUNTERCLAIM

For his Answer to Plaintiff Roy Moore’s (hereinafter “Moore”)

Complaint, Defendant Richard Hagedorn enters a general denial stating

that to the extent that Moore’s Complaint contains any allegation or

averment of wrongful or tortious conduct by Hagedorn, Hagedorn denies

those allegations or averments and demands strict proof thereof.

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AFFIRMATIVE DEFENSES

FIRST AFFIRMATIVE DEFENSE

Plaintiff fails to state a claim against Hagedorn.

SECOND AFFIRMATIVE DEFENSE

Hagedorn is entitled to a setoff.

THIRD AFFIRMATIVE DEFENSE

Hagedorn pleads truth.

FOURTH AFFIRMATIVE DEFENSE

Plaintiff’s claims are barred under the substantial truth doctrine.

FIFTH AFFIRMATIVE DEFENSE

None of Hagedorn’s alleged acts or omissions caused or contributed

to any alleged injury Plaintiff suffered.

SIXTH AFFIRMATIVE DEFENSE

All of Hagedorn’s statements are protected by the First Amendment

to the United States Constitution.

SEVENTH AFFIRMATIVE DEFENSE

Hagedorn did not act with actual malice.

EIGHTH AFFIRMATIVE DEFENSE

All of Hagedorn’s statements were privileged.

NINTH AFFIRMATIVE DEFENSE

Hagedorn avers lack of publication.

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TENTH AFFIRMATIVE DEFENSE

Hagedorn’s statements relate to a matter of public concern.

ELEVENTH AFFIRMATIVE DEFENSE

Plaintiff is a public official and/or public figure.

TWELFTH AFFIRMATIVE DEFENSE

Hagedorn was entitled to rely upon the substantial prior reporting

regarding Roy Moore’s sexual misconduct.

THIRTEENTH AFFIRMATIVE DEFENSE

Hagedorn pleads satire.

FOURTEENTH AFFIRMATIVE DEFENSE

Hagedorn pleads his statements were an expression of opinion.

FIFTEENTH AFFIRMATIVE DEFENSE

Plaintiff’s alleged damages were caused by third-parties for which

Hagedorn is not responsible.

SIXTEENTH AFFIRMATIVE DEFENSE

Hagedorn pleads lack of causation.

SEVENTEENTH AFFIRMATIVE DEFENSE

Plaintiff’s damages, if any, were caused by his own actions or

inaction.

EIGHTEENTH AFFIRMATIVE DEFENSE

Plaintiff is a libel proof plaintiff.

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NINETEENTH AFFIRMATIVE DEFENSE

Plaintiff’s claim for punitive damages is barred by Ala. Code § 6-5-

186 and was stricken. (See Doc. 215.)

TWENTIETH AFFIRMATIVE DEFENSE

Hagedorn reserves the right to amend its Answer and Affirmative

Defenses as discovery progresses.

COUNTERCLAIM

For his Counterclaim against Counterclaim Defendants Roy Moore,

Judge Roy Moore For US Senate, Janet Porter, and Herring Networks,

Inc., Counterclaim Plaintiff Richard Hagedorn states as follows:

INTRODUCTION

Richard Hagedorn is a private citizen. He is not a politician. He is

not a political operative. He is simply an ordinary person. But when Roy

Moore’s past became a matter of public concern, his political machine

quickly maneuvered to distract and deflect from news reports about Mr.

Moore by defaming Mr. Hagedorn. Mr. Moore’s spokesperson appeared

on national television and falsely told the nation that Mr. Hagedorn was

seeking revenge because Mr. Moore sent him to jail. Public records show

that Mr. Moore never sent Mr. Hagedorn to jail. But that did not stop

Moore’s campaign from telling a lie. It also did not stop others from doing

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the same. One America News ran a story where it falsely said that Mr.

Hagedorn was caught with over two pounds of cocaine. To these political

operatives, the facts did not matter. The truth did not matter. All that

mattered was defaming Mr. Hagedorn to benefit Mr. Moore’s campaign.

This lawsuit seeks to restore Mr. Hagedorn’s reputation and serve as a

warning to future political smear campaigns.

PARTIES

1. Counterclaim Plaintiff Richard Hagedorn is an adult citizen

of Etowah County, Alabama.

2. Counterclaim Defendant Roy Moore is an adult citizen of

Etowah County, Alabama.

3. Counterclaim Defendant Janet Porter is an adult citizen of

Ohio that is subject to personal jurisdiction in Alabama because she made

defamatory statements about Richard Hagedorn and directed those

comments toward Alabama.

4. Herring Networks, Inc. is a foreign corporation that operates

One America News Network and is subject to personal jurisdiction in

Alabama because it made defamatory statements about Richard

Hagedorn and directed those comments toward Alabama.

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5. Judge Roy Moore For US Senate (hereinafter the “Campaign

Committee”) is a campaign committee established under the rules of the

Federal Election Commission to finance the campaign of Roy Moore for

election to the United States Senate.

6. Fictitious Party Defendants are unknown to Hagedorn at this

time, but they will be substituted herein when ascertained.

FACTS

7. In 1988, Richard Hagedorn was indicted for unlawful

possession of 45.927 grams of cocaine.1 A true and correct copy of the

indictment is attached hereto as Exhibit 1.

8. Hagedorn accepted responsibility and pleaded guilty.

9. The Honorable William H. Rhea, III sentenced Hagedorn to

time in the state penitentiary. A true and correct copy of the Case Action

Summary is attached hereto as Exhibit 2.

10. Hagedorn repaid his debt to society.

11. On November 30, 2017, Heath Jones requested a copy the

records from Hagedorn’s criminal case, along with the records for Jimmy

1 For reference, 2 pounds is 907.185 grams.

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Wright, and gave the Circuit Clerk’s office the e-mail address

[email protected]. See Exhibit 3.

12. Around the same time, One America News Network aired a

story entitled “Moore Accusers Have Ties to Drug Dealers, Washington

Post.” In this story, the narrator falsely stated that Hagedorn was a

“convicted drug dealer who was caught with over two pounds of cocaine.”

A screen shot from the story is below:

13. On December 5, 2017 at 7:39 AM CST, Janet Porter appeared

as Roy Moore’s “Spokesperson” on CNN and falsely stated that “Much

like criminals who are seeking revenge, like the drug dealer that Judge

Moore sent to jail just happens to have a brother who is an editor on The

Washington Post.” A screenshot is below:

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14. Richard Hagedorn has suffered and was harmed by the

Counterclaim Defendants’ actions and inactions including emotional

distress, mental anguish, threats to his business, lost business, and loss

of standing in the community.

15. Hagedorn has satisfied all conditions precedent to bringing

this action.

COUNT ONE
DEFAMATION
(Against Herring Networks, Inc., Roy Moore, & The Campaign
Committee)

16. Hagedorn adopts and incorporates herein all of the previous

factual allegations.

17. Herring Networks, Inc. operates One America News Network.

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18. In or around December 2017, One America News Network

aired a story entitled “Moore Accusers Have Ties to Drug Dealers,

Washington Post.”

19. This story included a false and defamatory statement about

Richard Hagedorn. Specifically, the story stated that Hagedorn was a

“convicted drug dealer who was caught with over two pounds of cocaine.”

20. Upon information and belief, the Counterclaim Defendants

and/or their representatives worked in concert to air this false and

defamatory statement.

21. The indictment confirms that Hagedorn was in unlawful

possession of 45.927 grams of cocaine.

22. These indictment is a publicly available record that would

have confirmed the facts and circumstances of Hagedorn’s criminal case.

23. The Counterclaim Defendants had access to the public records

and, upon information and belief, were provided the records by Heath

Jones (aka [email protected]). Therefore, Counterclaim Defendants

knowingly made this false and defamatory statement.

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24. Alternatively, Counterclaim Defendants recklessly made the

false and defamatory statement when they failed to review the public

records.

25. Alternatively, Counterclaim Defendants negligently made the

false and defamatory statement.

26. The One America News Network story aired to a nationwide

audience and was targeted also to the Alabama audience that was facing

the 2017 special election.

27. As the proximate result of Counterclaim Defendants’ action,

Hagedorn was harmed.

WHEREFORE, Richard Hagedorn demands judgment against

Herring Networks, Inc., Roy Moore, The Campaign Committee, and the

Fictitious Party Defendants, jointly and severally, in a sum of

compensatory and/or punitive damages in excess of the jurisdictional

limits of this Court to be determined by a jury, which will fairly and

adequately compensate Richard Hagedorn for the damages he sustained,

together with interest from the date of the incident, attorneys’ fees,

expenses, and costs of the proceeding, as well as such other, further, and

different relief as this Court deems necessary and proper.

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COUNT TWO
FALSE LIGHT/INVASION OF PRIVACY
(Against Herring Networks, Inc., Roy Moore, & The Campaign
Committee)

28. Hagedorn adopts and incorporates herein all of the previous

factual allegations.

29. Herring Networks, Inc. operates One America News Network.

30. In or around December 2017, One America News Network

aired a story entitled “Moore Accusers Have Ties to Drug Dealers,

Washington Post.”

31. This story included a false statement about Richard

Hagedorn. Specifically, the story stated that Hagedorn was a “convicted

drug dealer who was caught with over two pounds of cocaine.”

32. The indictment confirms that Hagedorn was in unlawful

possession of 45.927 grams of cocaine.

33. These indictment is a publicly available record that would

have confirmed the facts and circumstances of Hagedorn’s criminal case.

34. The Counterclaim Defendants had access to the public records

and, upon information and belief, were provided the records by Heath

Jones (aka [email protected]).

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 DOCUMENT 241

35. Upon information and belief, the Counterclaim Defendants

and/or their representatives worked in concert to air this false statement.

36. The false statement placed Richard Hagedorn in a false light.

37. The false statement would be highly offensive to a reasonable

person.

38. Counterclaim Defendants had knowledge, or acted in reckless

disregard, as to the falsity of the statement and the light in which it

placed Richard Hagedorn.

39. As the proximate result of Counterclaim Defendants’ action,

Hagedorn was harmed.

WHEREFORE, Richard Hagedorn demands judgment against

Herring Networks, Inc., Roy Moore, the Campaign Committee, and the

Fictitious Party Defendants, jointly and severally, in a sum of

compensatory and/or punitive damages in excess of the jurisdictional

limits of this Court to be determined by a jury, which will fairly and

adequately compensate Richard Hagedorn for the damages he sustained,

together with interest from the date of the incident, attorneys’ fees,

expenses, and costs of the proceeding, as well as such other, further, and

different relief as this Court deems necessary and proper.

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 DOCUMENT 241

COUNT THREE
DEFAMATION
(Against Roy Moore, The Campaign Committee, & Janet Porter)

40. Hagedorn adopts and incorporates herein all of the previous

factual allegations.

41. On December 5, 2017 at 7:39 AM CST, Janet Porter appeared

as Roy Moore’s “Spokesperson” on CNN and falsely stated that “Much

like criminals who are seeking revenge, like the drug dealer that Judge

Moore sent to jail just happens to have a brother who is an editor on The

Washington Post.”

42. This statement is false and defamatory

43. Roy Moore never “sent [Richard Hagedorn] to jail.”

44. Not only does Roy Moore have actual knowledge of his actions

as Circuit Judge, but the criminal records are publicly available.

45. The Counterclaim Defendants had access to the public records

and, upon information and belief, were provided the records by Heath

Jones (aka [email protected]).

46. Therefore, Counterclaim Defendants knowingly made this

false and defamatory statement.

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 DOCUMENT 241

47. Alternatively, Counterclaim Defendants recklessly made the

false and defamatory statement when they failed to review the public

records.

48. Alternatively, Counterclaim Defendants negligently made the

false and defamatory statement.

49. Roy Moore acted in concert with Janet Porter to make this

false and defamatory statement and she made it on his behalf as

“Spokesperson.” Alternatively, Roy Moore is vicariously liable for her

statement.

50. The Campaign Committee acted in concert with Janet Porter

to make this false and defamatory statement and she made it on his

behalf as “Spokesperson.” Alternatively, The Campaign Committee is

vicariously liable for her statement.

51. The CNN interview aired to a nationwide audience, Janet

Porter made her comment in Alabama, and her comment was targeted to

the Alabama audience that was facing the 2017 special election.

52. As the proximate result of Counterclaim Defendants’ action,

Hagedorn was harmed.

WHEREFORE, Richard Hagedorn demands judgment against

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Janet Porter, The Campaign Committee, Roy Moore, and the Fictitious

Party Defendants, jointly and severally, in a sum of compensatory and/or

punitive damages in excess of the jurisdictional limits of this Court to be

determined by a jury, which will fairly and adequately compensate

Richard Hagedorn for the damages he sustained, together with interest

from the date of the incident, attorneys’ fees, expenses, and costs of the

proceeding, as well as such other, further, and different relief as this

Court deems necessary and proper.

COUNT FOUR
FALSE LIGHT/INVASION OF PRIVACY
(Against Roy Moore, The Campaign Committee, & Janet Porter)

53. Hagedorn adopts and incorporates herein all of the previous

factual allegations.

54. On December 5, 2017 at 7:39 AM CST, Janet Porter appeared

as Roy Moore’s “Spokesperson” on CNN and falsely stated that “Much

like criminals who are seeking revenge, like the drug dealer that Judge

Moore sent to jail just happens to have a brother who is an editor on The

Washington Post.”

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55. Roy Moore acted in concert with Janet Porter to make this

false statement. Alternatively, Roy Moore is vicariously liable for her

statement.

56. The Campaign Committee acted in concert with Janet Porter

to make this false statement. Alternatively, The Campaign Committee is

vicariously liable for her statement.

57. Not only does Roy Moore have actual knowledge of his actions

as Circuit Judge, but the criminal records are publicly available.

58. The Counterclaim Defendants had access to the public records

and, upon information and belief, were provided the records by Heath

Jones (aka [email protected]).

59. The false statement placed Richard Hagedorn in a false light.

60. The false statement would be highly offensive to a reasonable

person.

61. Counterclaim Defendants had knowledge, or acted in reckless

disregard, as to the falsity of the statement and the light in which it

placed Richard Hagedorn.

62. As the proximate result of Counterclaim Defendants’ action,

Hagedorn was harmed.

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 DOCUMENT 241

WHEREFORE, Richard Hagedorn demands judgment against

Janet Porter, Roy Moore, The Campaign Committee, and the Fictitious

Party Defendants, jointly and severally, in a sum of compensatory and/or

punitive damages in excess of the jurisdictional limits of this Court to be

determined by a jury, which will fairly and adequately compensate

Richard Hagedorn for the damages he sustained, together with interest

from the date of the incident, attorneys’ fees, expenses, and costs of the

proceeding, as well as such other, further, and different relief as this

Court deems necessary and proper.

COUNT FIVE
NEGLIGENT, RECKLESS, AND/OR WANTON HIRING,
TRAINING, SUPERVISION, AND/OR RETENTION
(Against Roy Moore & The Campaign Committee)

63. Hagedorn adopts and incorporates herein all of the previous

factual allegations.

64. Roy Moore and/or the Campaign Committee are responsible

for Janet Porter as his agent, representative, servant and/or employee.

65. Janet Porter as Roy Moore’s “Spokesperson” made false and

defamatory statements on national news media about Richard Hagedorn.

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66. Roy Moore and/or the Campaign Committee was Janet

Porter’s principal and/or employer and had a duty to monitor and

supervise his agents and/or employees.

67. Roy Moore and/or the Campaign Committee negligently,

Recklessly, and/or wantonly:

a. Hired Janet Porter as his agent, representative, servant,

and/or employee;

b. Trained Janet Porter as his agent, representative, servant,

and/or employee;

c. Monitored Janet Porter as his agent, representative, servant,

and/or employee;

d. Supervised Janet Porter as his agent, representative, servant,

and/or employee; and/or

e. Retained Janet Porter as his agent, representative, servant,

and/or employee.

68. Roy Moore and/or the Campaign Committee knew, or should

have known, of Janet Porter’s unfitness.

69. As the proximate result thereof, Hagedorn was harmed.

WHEREFORE, Richard Hagedorn demands judgment against Roy

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Moore, The Campaign Committee and the Fictitious Party Defendants,

jointly and severally, in a sum of compensatory and/or punitive damages

in excess of the jurisdictional limits of this Court to be determined by a

jury, which will fairly and adequately compensate Richard Hagedorn for

the damages he sustained, together with interest from the date of the

incident, attorneys’ fees, expenses, and costs of the proceeding, as well as

such other, further, and different relief as this Court deems necessary

and proper.

COUNT SIX
CONSPIRACY
(Against All Counterclaim Defendants)

70. Hagedorn adopts and incorporates herein all of the previous

factual allegations.

71. Counterclaim Defendants entered into a conspiracy with each

other, Heath Jones ([email protected]), others, and/or fictitious

defendants to defame Richard Hagedorn and/or invade his privacy and

place him in a false light.

72. Counterclaim Defendants’ actions were unlawful, oppressive,

or immoral or, alternatively, were accomplished through unlawful,

oppressive, or immoral means.

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73. The Counterclaim Defendants acted in concert with or

materially aided each other and/or others, including Heath Jones

([email protected]) in committing an overt act in furtherance of the

conspiracy.

74. Such conduct was the proximate cause of Richard Hagedorn’s

injuries and damages.

WHEREFORE, Richard Hagedorn demands judgment against

Herring Networks, Inc., Janet Porter, Roy Moore, the Campaign

Committee, and the Fictitious Party Defendants, jointly and severally, in

a sum of compensatory and/or punitive damages in excess of the

jurisdictional limits of this Court to be determined by a jury, which will

fairly and adequately compensate Richard Hagedorn for the damages he

sustained, together with interest from the date of the incident, attorneys’

fees, expenses, and costs of the proceeding, as well as such other, further,

and different relief as this Court deems necessary and proper.

JURY DEMAND

Richard Hagedorn demands a trial by struck jury on all counts so

triable.

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/s/ T. Dylan Reeves

T. Dylan Reeves (REE068)
Attorney For Defendant Richard
Hagedorn

OF COUNSEL:
STITES & HARBISON PLLC
401 Commerce Street, Suite 800
Nashville, TN 37219
(615) 782-2323 (telephone)
[email protected]

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CERTIFICATE OF SERVICE

I hereby certify that on January 25, 2023, I electronically filed the

foregoing with the Clerk of the Court using the AlaFile e-filing system,
which will send notification of such filing to all counsel of record.

/s/T. Dylan Reeves

OF COUNSEL

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Exhibit 1
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I NDICTMENT

The State of Alabama CIRCUIT COURT WINTER TERM,1988__.

Etowah County

COUNT ONE
The Grand Jury of said County charges that before the finding of this Indictment
Richard M. Hagedorn, alias Ricky Hagedorn, alias Rick Hagedorn, whose name to the
Grand Jury is otherwise unknown than as stated, did knowingly sell, manufacture,
deliver or bring into this state, or was knowingly in actual or constructive possession
of in excess of 28 grams or more of cocaine or df any mixture containing cocaine,
"
1 to-wit: 45.927 grams,,in violation of the provisions of Title 13A, §13A-12-216,
Code of Alabama 1975, contrary to law and against the peace and dignity of the State
of Alabama.
COUNT TWO

The Grand Jury of said County further charges that before the finding of this Indictment,

i Richard M. Hagedorn, alias Ricky Hagedorn, alias Rick Hagedorn, whose name to the
Grand Jury is otherwise unknown than as stated, did, on, to-wit: the 16th day of
April, 1988, while at or near, to-wit: Gadsden City Hall, Gadsden, Alabama, and
308 Manor Street, Gadsden, Alabama, unlawfully possess cocaine, a controlled substance,
in violation of the provisions of Title 13A, §13A-12-212(a)(1), Code of Alabama 1975,

contrary to law and against the peace and dignity of the State
of Alabama.

JA MES E. HEDGSPETH JR.

DISTRICT ATTORNEY 16th JUDICIAL CIRCUIT,
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•
< 51-2
• '`„:
e-gf-,c1f60
1g0 : '
44 4. Trial Docket A TRUE BILL.
Case Numbere"r6
'27 44 7/
1,,
Grand Jury No. 1 2 41
' Page 3- Foreman Grand Jury.

The State of Alabama Presented to the Court by the Foreman of

Etowah County the Grand Jury in the presence of seventeen
other Grand Jurors and filed in open court on
CIRCUIT COURT
This the day of 19II
THE STATE
vs. Clerk.
RICHARD M. HAGEDORN, alias The Sheriff i3 hereby authorized to release
the within named Defendantin this Indictment
DoB 9-21-53 w/m upon Defendantexecuting bail approved by the

SID Sheriff in the sum f$/0476Wor3

This the/r day of rte
.-6-• 191
(6

Judge 16th Judicial Circuit

INDICTMENT
THE STATE OF ALABAMA
Etowah County
Trafficking in Cocaine and
Clerk ofthe CircuitCourtin andfor said County
rj'-'lawful Possession of and State, do hereby certify that the within
Indictment together with the endorsements
appearing hereon,is a true and correct copy of
Controlled Substances the original Indictment and endorsements on
the same,in the case of the State aforesaid vs.

in the Circuit Courtofsaid County,asthe sam

appears of record in the office of the Clerk (
said Circuit Court.

This the day of 19 _

Clerk.
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AFFIDAVIT
ee-gr-t:579
'‘
0C-gS-
THE STATE OF ALABAMA-ETOWAH COUNTY
Personally came before me, Dell Mackey • Magistrate, of Etowah County
District Court in and for said county, Hugh Cox ,who being duly sworn.
deposes and says that he has probable cause for believing and does believe that
Richard M. Hagedorn
whose name is otherwise unknown to affiant than as stated,did, on, to-wit:
the 16th day of April, 1988,
while at or near, to-wit: Gadsden City Hall, unlawfully possess Cocaine, a
substance, in violation of the provisions of Title 13A7-12-212(a)(1), controlled
1975,
Code of Alabama

COUNT II
Richard M. Hagedorn did, on, to-wit: the 16th day of April, 1988, while at or near,
while at or near, to-wit: 303 Manor St.- Gadsden, unlawfully possess Cocaine, a controlled
substance, in violation of the provisions of Title 13A-12-212(a)(1), Code of Alabama 1975,

itrary to law and against the peace and dignity of the State of Alabama.
SWORN TO AND SUBSCRIBED BEFORE ME
18 day of April 19 88
. 4 the

A GISTRATE,ETOWAH COMITY DISTRICT COURT (LS.)

- WARRANT OF ARREST
al: •

THE STATE OF ALABAMA-ETOWAH

TO ANY LAWFUL OFFICER OF THE STATE OP ALASAMA aRirrisost
You are hereby commanded to arms Richard M. Hactedorn

anter toanswer the State ofAlabama on a charge of Unlawful Possession of Co

2 a
••••••••••mo r

CM my hand April 1? 19 88 .11=.1•11.11,

M AGISTRATE,ETOWAH C NTY DISTRICT COURT

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rHE STATE OF ALABAMA SHERIFFS RETURN

vs.
Richard M. Hagedorn named
Executed by arresting the within

Defendant and 171Pic,te.

Address

AFFIDAVIT AND WARRANT Date -rgia -88

ETOWAH COUNTY DISTRICT COURT

CHARGE:
Sheriff
Unlawful Possession of
Control/2c!Substance
( 2 COUNTS)
I , By
Deputy Sheriff

Bond is hereby fixed at $ Bond t-9 be set

try Judge
MILEAGECHARGE
Judge Mi.(R.I.)at 10t $
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Exhibit 2
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Exhibit 3
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