Please Click Below On Each Document You Would Like To View. To assist EMC members, some of the core documents are highlighted in bold below.

Plaintiffs’ Demand Letter (Sept. 14, 2007)

Lawsuit (“Member Derivative Complaint”)(October 22, 2007)

Plaintiffs’ Motion for Show Cause Order & Memorandum of Law in Support (Nov. 7, 2007)

Defendant Cobb Electric Membership Corporation’s Memorandum of Law in Support of it Motion to Stay and Request for Immediate Hearing (Nov. 9, 2007)

Plaintiffs’ Memorandum of Law in Support of Motion to Limit Coercive Communications (Nov. 12, 2007)

Defendant Cobb Electric Membership Corporation’s Memorandum of Law in Support of Its Motion for Extension of Time to Answer and for a Protective Order (Nov. 14, 2007)

Defendant Cobb Electric Membership Corporation’s Response in Opposition to Plaintiffs’ Motion to Limit Coercive Communications (Nov. 28, 2007)

Plaintiffs’ Memorandum of Law in Opposition to Defendant Cobb EMC’s Motion to Stay (Nov. 30, 2007)

1. Affidavit of Professor Charles R.T. O’Kelley

2. Affidavit of Kenneth Neil, CPA

3. Affidavit of Harold Smith

Answer of Defendants Larry Chadwick, Sarah C. Brown, Catherine Anderson, Donald W. Barnett, Alton R. Fortney, Jr. & Henry Balkcom, III (Jan. 1, 2008)

Answer of Cobb Energy Management Corporation (Jan. 10, 2008)

Answer of Dwight Brown (Jan. 10, 2008)

Order on Plaintiffs’ Motion to Limit Coercive Communications (Jan. 18, 2008)

Order on Preservation of Documents, Data and Tangible Things (Jan. 18, 2008)

Order on Cobb EMC’s Motion to Stay (Jan. 24, 2008)

Defendant Cobb Electric Membership Corporations’ Memorandum of Law in Support of Its Motion to Dismiss and Motion for More Definite Statement (Feb. 1, 2008)

Order Appointing Special Master (Feb. 1, 2008)

Special Master Order First Order on Discovery & Confidentiality Order (Feb. 8, 2008)

Plaintiffs’ Memorandum of Law in Opposition to Cobb EMC’s Motion to Dismiss and Motion for More Definite Statement (Mar. 7, 2008)

Operating Agreement Between Cobb EMC and Cobb Energy (Dec. 29, 1997)

1. Amendment to Operating Agreement (Aug. 13, 1998)

2. Amendment to Operating Agreement (Oct. 8, 1998)

3. Amendment to Operating Agreement (Jan. 26, 1999)

4. Amendment to Operating Agreement (April 1, 2000)

5. Additional Amendment to Operating Agreement (April 1, 2000)

6. Amendment to Operating Agreement (Feb. 1, 2005)

Joint Venture Agreement for the Design, Licensing, Development and Operation of Software (June 13, 2005)

Affidavit of EMC Accounting Expert Middlebrooks – Redacted by Court Order (08/08)

Dwight Brown’s Deposition Part 1

Dwight Brown’s Deposition Part 2

Memo to Support Motion to Postpone Cobb EMC Annual Meeting-Redacted by Court Order (July 22, 2008)

Reply Memo to Support Motion to Pospone Cobb EMC Annual Meeting (August 22, 2009

First Amended Complaint –Redacted By Court Order (August 26, 2008

Cobb County Superior Court Judge Steven Schuster’s order (August 25, 2008)