MEMPHIS, Tenn. — A Shelby County commissioner has filed a formal complaint against embattled Shelby County Clerk Wanda Halbert.

Thursday, Commissioner Mick Wright announced that he has filed a 20-page complaint against Halbert. According to Wright, the complaint includes 25 recommendations from witnesses who were interviewed, as well as a summary of 20 itemized complaints.

“This complaint details a variety of ways in which Clerk Halbert has ‘knowingly or willingly neglect[ed] to perform [duties] enjoined upon such officer by any of the laws of the state,’ and at the conclusion of this process ‘shall forfeit such office and shall be ousted from such officer in the manner’ provided by state law,” Wright wrote.

The complaint is addressed to Hamilton County District Attorney Coty Wamp, who is leading an investigation into complaints regarding Halbert and the County Clerk’s office.

Earlier this month, Wamp announced an in-person visit to Memphis to conduct interviews and meetings for the investigation. Wamp previously stated her office heard rumors of complaints and grievances but hadn’t received a formal complaint in writing.

“In order for my office to pursue ‘ouster’ under T.C.A. 8-47-101, we must have evidence in our possession that is clear and convincing to a court of law. … Therefore, we cannot simply rely on hearsay or rumors. We also cannot simply rely on evidence that Ms. Halbert is ‘bad’ at her job,” Wamp wrote in an update on the investigation.

Wright has repeatedly called for Halbert to step down from her position. When the County Clerk’s Poplar Plaza location closed in November, Wright claimed that Halbert hadn’t paid rent at the location since March.

“For some reason, Clerk Halbert simply will not fulfill the duties of her office and so that’s why I’m saying once again, it is time for Clerk Halbert to step aside,” Wright said.

In his complaint, Wright claims that Halbert often shifts blame onto the Shelby County Mayor’s Office when questioned about the clerk’s office issues.

“Any time Clerk Halbert is asked to explain major incidents such as an abrupt office closure, a massive backlog, or neglected obligations, she provides a laundry list of grievances against the Mayor’s Administration, the County Commission, the Trustee’s office, and other parties charged with assisting her department in delivering services to the public,” he wrote.