First Volley

When one initiates a civil suit, and a suit against a state agency for failing to do its job would be civil, if the suit is not dismissed as frivolous out of hand, the plaintiff is entitled to posit interrogatories to the defendant entity. Interrogatories serve the dual purpose of providing information to the plaintiff and an opportunity for the defense to provide exculpatory evidence. Statutory requirements to provide information are partly designed to prevent unnecessary legal action clogging the courts. On the other hand, if it turns out that appropriate records are not being kept by public officials, that in itself is evidence of negligence and may provide grounds for judicial intervention.

GORA request re: Sea island beach, dune and shore disturbance, 1989 to present

Dear Mr. Brady,

Please consider this a request for all documentation, beginning with the application for the permit which was issued to the now defunct Sea Island Company in 1989, relating to the issuance of permits and/or letters of permission for any land disturbance or construction in waters of the state, as well as any applications filed by any person or entity for authorization to disturb land and/or water on the entire Atlantic Ocean side of Sea Island. Please include any inspection reports which validate that permit or letter of permission conditions have been complied with, including any responses to complaints validating same. In addition, please include evidence of liability insurance or financial bonds, naming the State of Georgia as the beneficiary, secured by the applicants to insure proper completion of projects in waters of the state.

By law you have 3 working days or 72 hours to respond to my request. If there is any part of my request that can not be provided for any reason, or in the time allotted, please provide an explanation to me in writing. I am prepared to reimburse the agency for a reasonable expense for staff time spent compiling the requested information.

Please note in particular that the request includes ALL permits or LOPs issued to whomever to authorize land disturbance from the high tide mark and into the surf along the entire eastern shore of Sea Island, including the deeds submitted to validate ownership claims. “Trust but verify.”

Monica Smith
61 Maxwell Avenue
Saint Simons Island, Ga.

P.S. As the owner of 12 acres of pristine marsh, I happen to be an abutter to the south end of Sea Island and have watched as waves have replaced the vegetation on my horizon.