DOCUMENT1

IN THE CIRCUIT COURT OF HOUSTON COUNTY, ALABAMA

WYLIE YELVERTON,
PLAINTIFF,

) CASE NUMBER:

VS.

LEN WHITE,
DEFENDANT.

TEMPORARY INJUNCTION
TO: LEN WHITE

The verified Petition of the Plaintiff being presented to

the Court praying for a Temporary Injunction, among other relief,
and the Court having considered the same, it is, by the Court,
ORDERED, ADJUDGED and DECREED:

That the defendant, LEN WHITE, is hereby restrained and

enjoined from harassment of the Plaintiff by stalking, threatening
gesturing, hitting, intimidating, or molesting the plaintiff in any
form; that the defendant is further restrained from going on or
around the plaintiff's residence or any place he might be, with the
exception of any reasonable contact in their work place.
That any violation of this Order may subject the defendant
to punishment for Contempt of Court.
DONE this the

day of August

JUDGE

996.

DOCUMENT 1

IN THE CIRCUIT COURT OF HOUSTON COUNTY, ALABAMA

WYLIE YELVERTON,

PETITIONER,
CASE NO. CV-96-5I85

VS.

LEN WHITE,
RESPONDENT.
ORDER
By consent, Respondent, Len White, is hereby restrained from intimidating or
harassing Petitioner, Wylie Yelverton, in any way whatsoever. Both parties are directed to
avoid any unnecessary contact with each other. The parties should be considerate of the
employment situations and recognize that some contact may be necessary in their official
duties, but should refrain from attending social meetings and functions where it is obvious
the other is present. This Order shall remain in force for so long as Petitioner shall remain
in the employment of the City of Dothan, Alabama.

Clerk to notify.
DONE and ORDERED this the I ilf-t day of September, 1996.

FIlLicr)

DENNY HOLLOWAY, JUDGE

20TH JUDICIAL CIRCUIT OF
ALABAMA

SEP 13 1996
J lelf3YRD, CLERK
HO W STON CO., Alw

CT U

DOCUMENT1

IN THE CIRCUIT COURT OF HOUSTdN COUNTY, ALABAMA

WYLIE YELVERTON,
PLAINTIFF,

) CASE NUMBER:

VS.
LEN WHITE,
DEFENDANT.

COMPLAINT FOR PERMANENT INJUNCTION

Comes now the Plaintiff, Wylie Yelverton, and respectfully
represents unto Your Honor as follows:
1.

That Plaintiff is a resident citizen of Dothan, Houston

County, Alabama, and is an employee of the City of Dothan, Alabama.

2.

That the Defendant is a resident citizen of the State of

Alabama and is an employee of the City of Dothan, Alabama.

3.

That on October 30, 1989, the City of Dothan issued a

statement of Equal Opportunity and Affirmative Action Policy

stating that the City of Dothan is an equal employment\affirmative
action employer and calls for the maintenance of a work environment
for all employees which provide freedom from abusive, intimidating,
or offensive behavior on the part of supervisors or other
employees. Further, the memo stated it must be understood by all,
that harassment of any sort will not be tolerated.
4.

That the Defendant, Len White, has set a course of

continuous harassment of the Plaintiff by stalking, threatening

gestures, and verbal acts calculated to make the Plaintiff angry or
to provoke him to act in a violent way toward the Defendant.
5. That the Plaintiff is afraid for his safety because of the
acts of the Defendant. That Plaintiff's physical health is bad and

DOCUMENT]

he suffers from high blood pressure and heart trouble. That he has
been advised by his physician that the stress and anxiety caused by
the acts of the Defendant is extremely harmful to his health.
6.

That the Defendant is violation of the provision of his

employers Equal Opportunity/Affirmative Action policy agreed to by

the City of Dothan and the EEO\AAP Officer.
7.

That

the Plaintiff has no adequate remedy at law or

otherwise for the harm caused by the Defendant and will suffer
irreparable harm, damage and injury to Plaintiff unless the acts
and conducts of the Defendant are enjoined by this Honorable Court.
WHEREFORE, Plaintiff prays after he enters in to a bond as set
by this Court that this Court will issue a temporary injunction
against the Defendant, Len White, restraining him from further
harassment, intimidation, stalking, threatening, or physical
contact of any sort or manner until a hearing is had on the
Plaintiff's application for permanent injunction. Further, that
upon a hearing in this cause that Your Honor will issue a permanent
injunction restraining the Defendant from the acts complained of
in Plaintiff's complaint.

HBORAH S. SEAGLE
IFF
ATTORNEY FOR PLA
82
POST OFFICE BOX
36302
DOTHAN, ALABAMA

DOCUMENT 1

IN THE CIRCUIT COURT OF HOUSTON COUNTY, ALABAMA

WYLIE YELVERTON,
PLAINTIFF,

) CASE NUMBER:

VS.
LEN WHITE,
DEFENDANT.
AFFIDAVIT IN SUPPORT OF TEMPQRARY INJUNCTION

Personally appeared before me the undersigned authority in and

for said State in said County, WYLIE YELVERTON, who after being by
me first duly sworn deposes and says as follows:
My name is Wylie Yelverton.

I am a resident of Dothan,

Houston County, Alabama. I am the Plaintiff in the above entitled

action for injunction against Len White, Defendant. The Defendant
and I are both employees of the City of Dothan and our offices are
located within the same building.

The Defendant, Len White,

continuously harasses, stalks, and intimidates me.

He looks

toward me with threatening gestures and speaks to me with an angry

demeanor. On August 14, 1996, I was in the lobby of our office
building waiting for the elevator, when the elevator arrived Len
White stepped out and begin to look at me with an angry expression.
I stepped in the elevator. Len White turned around and followed me
back into the elevator with an angry facial expression. I had to
leave the elevator in fear of my safety. On August 23, 1996, the
Defendant saw me in the lobby and followed me down the steps. I
looked around and he was standing one step over me. About half way
down I heard a loud noise as if someone had taken a flat object and
hit it hard in the other hand. This frightened me and I turned

DOCUMENT 1

around and the Defendant gave me an angry look. The Defendant has
followed me on numerous occasions sometimes walking just inches
behind me. His gestures, tone of voice and actions are those of
anger. I am afraid for my safety and feel that I am in need of an
injunction for protection.

WYL E YELVERTON

SWORN TO AND SUBSCRIBED BEFORE ME THIS c49 ,OLDAY OF AUGUST,

1996.
NOTARY IfI0j:jeD

DOCUMENTI

IN THE CIRCUIT COURT OF HOUSTON COUNTY, ALABAMA

WYLIE YELVERTON,
PLAINTIFF,

) CASE NUMBER:

VS.

LEN WHITE,
DEFENDANT.

S7(3-

41-

BOND

KNOW ALL MEN BY THESE PRESENTS:

That we, Wylie Yelverton,
Johnnie W. Page
LEN WHITE in the sum of

mrlie Barber

and

are held and firmly bound unto

ONE THOUSAND AND NO/100---- dollars,

for the payment of which we bind ourselves, our heirs, assigns,

executors or administrators, jointly and severally by these
presents.
The condition of this bond is this: That whereas, the above
bounded Wylie Yelverton in a complaint filed by him against said
Len White prayed for and obtained a writ of injunction out of the
Circuit Court of said County upon the approval of this bond,
restraining and enjoining the said Len White from further
harassment, intimidation, stalking or doing bodily harm upon said
Plaintiff.
Now, if, on the dissolution of such injunction, the said Wylie
Yelverton shall pay the amount of the judgment enjoined, with
interest, and also such damages and costs as may be decreed against
him then this bond shall be null and void; otherwise, to remain in
full force and effect.
4A\

Witness our hands and seals this the

1996.
WYLI YELVER ON, SURETY

Taken and approved this

day of August,

DOCUMENT 1

IN THE CIRCUIT COURT OF HOUSTON COUNTY, ALABAMA

WYLIE YELVERTON,
PETITIONER,

vs.

FILED

CASE NO: CV 96-5185

JUL 0 1 1991

LEN WHITE,
RESPONDENT.

4dr

8"40494
CONTEMPT PETITION
Comes now the petitioner, Wylie Yelverton, and respectfully
represents unto your Honor as follows:
1.

That on or about the 28th day of August, 1996 ; the

petitioner filed his Complaint foi Injunction against the

Respondent, Len White. On the 13th day of September 1996 this
Honorable Court entered a permanent restraining Len White from
intimidating or harrassing petitioner, Wylie Yelverton in any way.
Parties were directed to avoid unneccesary contact with each other
and to refrain from attending social meetings and functions where
the other would be present.
2. That on or about May 2, 1997, Lhe petitioner and respondent
were entering the Civic Center building at the same time. The
petitioner was climbing the set of steps located to the right and
the respondent was climbing the set of steps located to the left.
The respondent entered the Civic Center building first and crossed
over to the set of doors in front of the steps the petitioner was
ascending.

The respondent then held the door and prevented the

petitioner from entering the building.

Petitioner alleges

that

this was done in violation of the September 12, 1996 Restrainina

Order and for the purpose of harrassment and intimidation.

DOCUMENT1

3. That on or about May 6, 1997. the petitioner was leavina the

Civic Center on the Northside of the building during lunch time. As

he entered the pedestrian crosswalk the respondent drove into the

crosswalk in his vehicle and blocked the petitioner's path. As
the petitioner attempted to go around the rear of respondent's
vehicle the respondent put his car in reverse and hacked up aaaie
blocking the petitioner's path. The petitioner then attempted to
go around the front of respondent's car and respondent pulled
forward. This sequence was again repeated. The Petitioner alleges
that this course of action was done in violation of the restraining
order and for the purpose of harrassernent.
4.

That on or about. May 10, 1997, the petitioner Wylie

Yelverton was hosting a private retirement party for Jerry Holland,

a City Electrical Inspector, in the third floor conference room at
the Civil Center. The party was by invitation only. Len White, ie
violation of the restraining order, appeared uninvited to this
event. While petitioner, Wylie Yelverson was making a presentation
Mr. White entered the room and entered into conversation with other
guests only a few feet from Mr. Yelverton. Petitioner alleges this
was done in violation of the Restraining Order and for the
purpose of hairassment and intimidation.
Wherefore, Petitioner prays that this Honorable Court wil7
take jurisdiction of this petition and that the Respondent,

T en

White be and appear before the Court at a time and date to be fixed

DOCUNIENTI

by the Court, and and then and there show cause if any he ham as

to

why he should be adjudged in Contempt of Court and further should

he taxed for attorney's fees in the Respondent's behalf.

orah S. Seag
Attorney for Re
P.O. Box 2082
Dothan, Alabama

dent
36302

STATE OF ALABAMA
HOUSTON COUNTY
Before me the undersigned authority in and for said State and
County, personally appeared, Wylie Yelverton, who being by me first
duly sworn, deposes and says that he is the Respondent in the abc.ve
and foregoing cause, and that the facts contained therein are tr;Ja
and correct.

Wylie Yelverton
Sworn to and subscribed before me on this the
July, 1.997.

4114

/2-4A/11

N7411ary Pu lic

Serve Defendant at:

126 North St. Andrews St.
Dothan, Alabama
36301

1 5tday

DOCUMENT 1

IN THE CIRCUIT COURT OF HOUSTON COUNTY, ALABAMA

CIVIL DIVISION
WYLIE YELVERTON,

PLAINTIFF,

VS.

LEN WHITE,

DEFENDANT.

CASE NO. CV-96-5185

ORDER
The verified Petition of the Plaintiff being presented to the Court praying for
a Permanent Injunction, among other relief, and the Court having considered the
same, it is hereby,
ORDERED, ADJUDGED and DECREED:
That the defendant, LEN WHITE, is in constructive civil contempt of Court
for attending and remaining at a function in which plaintiff was already present and
which function was a part of plaintiffs department.
That the defendant, LEN WHITE, is permanently restrained and enjoined
from harassment of the plaintiff by stalking, threatening gesturing, hitting,
intimidating, or molesting the plaintiff in any form; that the defendant is further
restrained from going on or around the plaintiffs residence or any place he might
be.

DOCUMENT 1

That any further violation of this ORDER will subject the defendant to
punishment for Contempt of Court.
That costs and attorneys fees for this Petition are taxed to defendant.
Clerk to notify.
DONE and ORDERED this the

DENNY HOLLOWAY, JUDG

20TH JUDICIAL CIRCUIT OF
ALABAMA

fr:!!!

74'1

OCT 2 1997.
4-4

eUDY BYRD, atiiiK

HOUSTON CO., AL