IN THE CIRCUIT COURT FOR RUTHERFORD COUNTY TENNESSEE

AT MURFREESBORO

CHARLES GARBER, as personal )

representative for his deceased daughter, )
ADRIENNE FRANCES GARBER COX, )
and for the benefit of minor children, )
SKYLER COX, DALTON COX, ERIC COX, ) DOCKET NO. 78641
and JARED COX, )
)
Plaintiffs, )
)
v. ) JURY DEMAND
)
STEVEN ANDREW LOKEY and )
RUTHERFORD COUNTY, )
)
Defendants. )

AMENDED COMPLAINT FOR WRONGFUL DEATH

COME NOW your Plaintiffs, by and through counsel, and respectfully bring the following
Complaint and allegations against the Defendants named herein, and as grounds and in support
thereof, would show unto this Honorable Court as follows:

JURISDICTION & VENUE

1. That the Plaintiff, CHARLES GARBER, is the natural parent and next of kin of the deceased,
ADRIENNE FRANCES GARBER COX, and is the appropriate person to prosecute an
action for her wrongful death on behalf of her minor children, pursuant with Tenn. Code
Ann. §§ 20-5-106, 20-5-107 and 36-4-101.
2. That the deceased, ADRIENNE COX, was a resident of Bedford County, Tennessee at the
time of her murder, leaving behind the following four (4) minor children: Skyler Cox, Dalton
Cox, Eric Cox and Jared Cox; all of whom were residents of Bedford County, Tennessee
upon the date of her death.
3. That the Plaintiff, CHARLES GARBER, is a citizen and resident of the state of Pennsylvania
and hereby submits and avails himself to the jurisdiction and venue of this Honorable Court.
 4. That upon information and belief, the Defendant, STEVEN ANDREW LOKEY, is a resident
and citizen of Rutherford County, Tennessee and submits himself to the jurisdiction and
venue of this Honorable Court by virtue of having been arrested, detained, and knowingly
released by the Rutherford County Jail before brutally murdering the deceased, ADRIENNE
COX, on the same date upon which he was scheduled to return to court in Rutherford County.
5. That the Defendant, RUTHERFORD COUNTY, is a governmental entity, located and
operating with its principal place of business in Murfreesboro, Tennessee, and submits itself
to the jurisdiction and venue of this Honorable Court by virtue of having arrested, detained,
and wrongfully released the Defendant, STEVEN ANDREW LOKEY, who then brutally
murdered the deceased, ADRIENNE COX, on the same date upon which he was scheduled
to appear in court in Rutherford County.
6. That at all times relevant to the matters alleged herein, the Defendant, RUTHERFORD
COUNTY, owned, operated, or both, the Rutherford County Jail where the Defendant
STEVEN ANDREW LOKEY was ordered to be held without bond before he was allowed
to be released a R dC S Detective, Ty Downing.
7. The Defendant, RUTHERFORD COUNTY, is a governmental entity, as set forth within the
meaning of the Tennessee Governmental Tort Liability Act, T.C.A. § 29-20-201, et. seq.,
and pursuant to the same and specifically T.C.A. § 29-20-205, immunity from suit of all
governmental entities is removed for injury proximately caused by a negligent act or
omission of any employee within the scope of his/her employment.
8. That Pursuant to T.C.A. § 29-20-308(a), this is the proper venue for resolving this tort action.

FACTUAL ALLEGATIONS
9. This action arises from the murder of ADRIENNE COX which occurred on June 19th, 2020;
causing the Plaintiffs who are minor children to suffer the loss of their Mother and caregiver
due to an unreasonably dangerous, violent & persistent criminal offender being repeatedly
released by RUTHERFORD COUNTY because he served as their Confidential Informant.
10. That on or about March 16th, 2020, the Defendant, STEVEN ANDREW LOKEY1, was
arrested by Defendant, RUTHERFORD COUNTY, and charged with felony burglary.

1
See Exhibit A for pictures of the Defendant, STEVEN ANDREW LOKEY, who was allowed to walk out of the
Rutherford County Jail free and clear, despite the County having notice of multiple active warrants for his arrest for
violating the terms of his probation for crimes he committed in Rutherford County and Moore County Tennessee.

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 11. At time of his arrest, Lokey was already a convicted felon and in violation of probation for
a litany of prior violent and drug-related offenses dating back to January 2014 for which he
repeatedly failed to appear and had a well-documented history of never complying with the
terms of his probation for the various offenses to which he plead guilty.
12. On March 25, 2020, the Moore County Circuit Court issued a Warrant for Lokey P ba
Violation which was filed with the Rutherford County Court ordering the Court to hold
Lokey without bond until he could be brought before the Moore County court.
13. On April 2, 2020, a Warrant2 a da d d L ba a
Rutherford County for his numerous prior arrests for burglary and possession of meth,
ordering him to serve the remainder of his (2) year sentence and to H d / B d.
14. Lokey was scheduled to appear before the Rutherford County General Sessions Court on
April 29, 2020, for his most recent charges and to answer for violating his probation in
Rutherford County and Moore County.
15. Upon information and belief, the Defendant, STEVEN ANDREW LOKEY, is believed to
be a Confidential Informant working closely under the direction and control of Rutherford
County Detective, Ty Downing.
16. That on or about March 27, 2020 at 6:08 p.m. (CST) the Defendant, STEVEN ANDREW
LOKEY, called Rutherford County Detective T D D a c
phone from the phone kiosk inside the Rutherford County Jail, and during their recorded
phone conversation, Lokey acknowledged knowing that he had a hold in Moore County for
the active warrant. In response, Detective Downing assured Lokey that it would only take a
few phone calls for the County to take care of d ac a L a .
17. During the aforementioned phone call, Lokey specifically asked Detective Downing
whether his bail had been taken care of, to which Downing responded affirmatively, and that
Lokey would be all clear to be released.3
18. On April 18, 2020, an Agreed Order to Release on Recognizance was prepared, at Detective
D d rection and request, and subsequently approved and entered by the Court.
RUTHERFORD COUNTY, by and through one of its agents or employees, then altered the

2
See Exhibit B attached herewith.
3
No bail was ever set by the Court or paid by Lokey, and the phone call staged by Lokey and Detective Downing
on March 27, 2020 was purely to create a paper trail and to facilitate L a as a Confidential Informant.

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 ac Wa a a dc a a d H d / Ba a d a , ROR (
court order) acc da c a dA dO d .
19. Pursuant to said Order, Lokey was ordered to report weekly to probation supervision and to
appear on Friday June 19, 2020 for his next court date.
20. L a d C d , and violated the terms of his probation, and on
Friday June 19, 2020, the Defendant, STEPHEN ANDREW LOKEY, failed to appear at his
scheduled court date. No warrants were issued for his arrest, and Detective Downing made
no efforts to locate or detain his Confidential Informant. On the same day Lokey failed to
appear, Lokey went to the home of the deceased where he brutally attacked and sadistically
murdered ADRIENNE COX in the presence of multiple witnesses who have agreed to testify
against him in the pending murder trial where he faces First Degree Murder charges for the
death of ADRIENNE COX.
21. A a d c a d a L a R dC c d ,
ADRIENNE COX, suffered brutal, severe and traumatic injuries that led to her death.

ALLEGATIONS OF NEGLIGENCE
22. The Defendant, RUTHERFORD COUNTY, through its employees, agents, or both,
negligently failed to detain and properly hold the criminal Defendant, STEVEN ANDREW
LOKEY, without bail and for the duration of his sentence, as was ordered and specifically
requested in the active warrants that were filed by Rutherford County and Moore County,
Tennessee for L ba a .
23. The Defendant, RUTHERFORD COUNTY, through its employees, agents, or both, had
actual notice that STEVEN LOKEY was a dangerous and violent persistent criminal offender
who was wanted in multiple counties for probation violations, and that he was being held
and detained in their custody and care.
24. Defendant, RUTHERFORD COUNTY, through its employees, agents, or both, was
negligent and incredibly reckless when it intentionally facilitated the release of the
Defendant, STEVEN LOKEY, from their Jail, despite being fully aware that Lokey was a
convicted felon with a propensity for violence and a documented history of abusing meth.
25. Defendant, RUTHERFORD COUNTY, through its employees, agents, or both, was grossly
negligent and extraordinarily reckless when it intentionally deceived the Court and ignored

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 the active warrants for the Defendant, STEVEN LOKEY, in order to direct and facilitate
L release from their custody and care.
26. The actions by the Defendant, RUTHERFORD COUNTY, through its employees, agents,
or both, as listed above were negligent, reckless, and were the direct and proximate cause of
the death of the deceased, ADRIENNE COX.
27. The Defendant, RUTHERFORD COUNTY, had a duty of reasonable care to ensure the
safety and wellbeing of its citizens and residents, and specifically had an obligation to honor
and fully enforce the Warrants and Orders which were issued by the surrounding counties.
28. Defendant, RUTHERFORD COUNTY, breached their duty of reasonable care by
repeatedly and knowingly releasing a dangerous and violent offender such as STEVEN
LOKEY back into the community without bond and in violation and ignorance of the active
Warrants for his arrest and detainment, solely to serve as their Confidential Informant.
29. D da , RUTHERFORD COUNTY , a STEVEN LOKEY a direct and
a ca ADRIENNE COX d a , a d d a a b ab a d
preventable had they exercised reasonable care by honoring the active warrants L
arrest and by not purposely ignoring his jarring criminal history which should have prevented
his release from their custody.

DAMAGES
30. As a direct and proximate result of the negligence of the Defendants as referenced above,
ADRIENNE COX, was brutally and viciously murdered and her minor children, Skyler Cox,
Dalton Cox, Eric Cox and Jared Cox have been forced to endure the impact and trauma
surrounding the nature of her murder and they have been robbed of their caregiver and loving
Mother. They will permanently endure anguish, distress, anxiety, grief and fear, all so
extreme in degree as to significantly impair their ability and inclination to appreciate and
enjoy their remaining pleasures of life, for all of which the Plaintiff, CHARLES GARBER,
as personal representative of the deceased, ADRIENNE COX, and for the benefit of the
minor children, Skyler Cox, Dalton Cox, Eric Cox and Jared Cox, deserve to be
compensated.
31. As a direct and proximate result of the negligence of the Defendants as referenced above,
the deceased, ADRIENNE COX, has incurred funeral expenses, medical expenses,
discretionary costs, and lost earning potential for all of which the Plaintiff, CHARLES

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