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ANTISMOKING LAWYER SUED BY HIS OWN CLIENT [8.22.3]
Read the Complaint Charging Conflict of Interest
Plaintiffs in an individual action against the tobacco industry sued their former attorney, Ronald Motley.
They charge that Motley breached his fiduciary duty through his involvement with the proposed "global" tobacco settlement, which could indemnify the industry against punitive damages in the type of suit in which Motley represented the plaintiffs.
Here is the entire complaint.
THE CHANCERY COURT, SECOND JUDICIAL DISTRICT, JONES COUNTY, MISSISSIPPI
AVA DEAN BUTLER, individually, as executrix and on behalf of all wrongful death beneficiaries and the estate of Burl Butler, deceased, GLORIA BUTLER BALDWIN, KATHY BUTLER HARRIS, and MELANIE BUTLER DIXON
PLAINTIFFS
VS.
NESS, MOTLEY, LOADHOLT, RICHARDSON & POOLE, P.A., RONALD L. MOTLEY, TERRY E. RICHARDSON, JR. JOSEPH F. RICE, CHARLES W. PATRICK, JR.' DON BARRETT, individually and d/b/a BARRETT LAW OFFICES, DAVID MCCORMICK and CUMBEST CUMBEST HUNTER & MCCORMICK, P.A.
DEFENDANTS
CIVIL ACTION NUMBER __________
COMPLAINT
Ava Dean Butler, individually, as executrix and on behalf of all wrongful death beneficiaries and the estate of Burl Butler, deceased, Gloria Butler Baldwin, Kathy Butler Harris, and Melanie Butler Dixon (collectively referred to as "Plaintiffs") prosecute this complaint against Ness, Motley, Loadholt, Richardson & Poole, P. A. , Ronald L. Motley, Terry E. Richardson, Jr., Joseph F. Rice, Charles W. Patrick Jr., (Mr. Motley, Mr. Richardson, Mr. Rice, Mr. Patrick and the Ness Motley firm are sometimes collectively referred to as "Ness Motley"), Don Barrett individually and d/b/a Barrett Law Offices, David McCormick and Cumbest Cumbest Hunter & McCormick, P.A. (Mr. McCormick and the Cumbest Cumbest law firm sometimes collectively referred to as "McCormick") (all defendants sometimes collectively referred to as "Defendants").
Parties
1. Ava Dean Butler is an adult resident citizen of the Second Judicial District of Jones County, Mississippi. Ms. Butler is prosecuting this cause in her individual capacity and as executrix and on behalf of all wrongful death beneficiaries and the estate of her late husband, Mr. Burl Butler.
2. Gloria Butler Baldwin is an adult resident citizen of Madison County, Mississippi. Gloria Baldwin is the natural daughter and a wrongful death beneficiary of her deceased father, Burl Butler.
3. Kathy Butler Harris is an adult resident citizen of Jones County, Mississippi. Kathy Harris is the natural daughter and a wrongful death beneficiary of her deceased father, Burl Butler.
4. Melanie Butler Dixon is an adult resident citizen of Lincoln County, Mississippi. Melanie Dixon is the natural daughter and a wrongful death beneficiary of her deceased father, Burl Butler.
5. Ness, Motley, Loadholt, Richardson & Poole, P. A. , ("Ness Motley") is a professional association organized and existing under the laws of the state of South Carolina and doing business in the Second Judicial District of Jones County, Mississippi. Ness Motley's principal place of business is located at 151 Meeting St., Suite 600, Charleston, South Carolina 29402. Ness Motley may be served with process of this court by mailing summons to 151 Meeting St., Suite 600, Charleston, South Carolina 29402, in accordance with Rule 4 (c) (5) of the Mississippi Rules of Civil Procedure.
6. Ronald L. Motley is an adult resident citizen of South Carolina. Mr. Motley is a stockholder and/or member of the Ness Motley professional association. Mr. Motley may be served with process of this court by mailing summons to him in accordance with Rule 4 (c) (5) of the Mississippi Rules of Civil Procedure.
7. Terry E. Richardson, Jr., is an adult resident citizen of South Carolina. Mr. Richardson is a stockholder and/or member of the Ness Motley professional association. Mr. Richardson may be served with process of this court by mailing summons to him in accordance with Rule 4 (c) (5) of the Mississippi Rules of Civil Procedure.
8. Joseph F. Rice is an adult resident citizen of South Carolina. Mr. Rice is a stockholder and/or member of the Ness Motley professional association. Mr. Rice may be served with process ofthis court by mailing summons to him in accordance with Rule 4 (c) (5) of the Mississippi Rules of Civil Procedure.
9. Charles W. Patrick, Jr., is an adult resident citizen of South Carolina. Mr. Patrick is a stockholder and/or member of the Ness Motley professional association. Mr. Patrick may be served with process of this court by mailing summons to him in accordance with Rule 4 (c) (5) of the Mississippi Rules of Civil Procedure.
10. Don Barrett is an adult resident citizen of Holmes County, Mississippi. Mr. Barrett is a partner in and does business as Barrett Law Offices. Mr. Barrett may be served with process of this court by delivering summons to him at 404 Court Square North, Lexington, Mississippi 39095.
11. David O. McCormick is an adult resident citizen of Jackson County, Mississippi. Mr. McCormick is a stockholder and/or member of the professional association Cumbest Cumbest Hunter & McCormick, P.A.. Mr. McCormick may be served with process of this court by delivering summons to him at 707 Watts Ave., P. O. Drawer 1287, Pascagoula, MS 39568-1287.
12. Cumbest Cumbest Hunter & McCormick, P.A. is a professional association organized and existing under the laws of the state of Mississippi. Its principal place of business is located at 707 Watts Ave., Pascagoula, MS.
Jurisdiction and Venue
13. This court has personal jurisdiction over all defendants residing in the state of Mississippi. Additionally, this court has personal jurisdiction over all non-resident defendants since all such defendants do business in the state of Mississippi, all such defendants entered into contracts to be performed in whole or in part in the state of Mississippi, and all such defendants committed torts in whole or in part in the state of Mississippi.
14. This cause arises out of contracts entered into in whole or in part in Jones County, Mississippi and/or contracts to be performed in whole or in part in Jones County, Mississippi. Venue is proper in Jones County, Mississippi.
15. Additionally, this cause arises out of tortious conduct committed in whole or in part in Jones County, Mississippi. Venue is proper in Jones County, Mississippi.
Facts
(Duty of Fiduciary, Loyalty and Contract)
16. Prior to May, 1994, defendant Barrett approached the law firm of Langston Frazer Sweet & Freese and offered to assist as co- counsel for Plaintiffs in the prosecution of a civil cause filed by Mr. Burl Butler against the tobacco industry in the Circuit Court, First Judicial District, Hinds County, Mississippi. Langston Frazer Sweet & Freese communicated with and advised Mr. Butler who agreed to employ Barrett as additional counsel in the prosecution of his civil suit against the tobacco industry. Mr. Barrett and his firm began this representation prior to Mr. Butler's death and continued such representation on behalf of the estate and wrongful death beneficiaries of Burl Butler.
17. On May 7, 1994, Mr. Butler died as a result of injuries sustained by second-hand smoke. Ava Dean Butler, individually and on behalf of the wrongful death beneficiaries and estate of Burl Butler, dismissed the suit in Hinds County that had been filed during the life of her husband and initiated a wrongful death suit against the tobacco industry under the cause styled Butler vs. Philip Morris Incorporated, Civil Action No. 94-5-53, Circuit Court, Second Judicial District, Jones County, Mississippi.
18. Prior to the filing of the wrongful death suit, Mr. Ron Motley of the law firm of Ness Motley traveled to Jackson, Mississippi, visited the law firm of Langston Frazer Sweet & Frees and offered to assist as co-counsel for the Butler family. Mr. Motley stated his desire to serve as lead counsel. Langston Frazer Sweet & Freese communicated with and advised Mr. and Mrs. Butler who agreed to employ Mr. Motley and the Ness Motley firm as lead counsel in the prosecution of her family's wrongful death suit against the tobacco industry. Mr. Motley and his firm began this representation prior to Mr. Butler's death and continued such representation on behalf of the estate and wrongful death beneficiaries of Burl Butler.
19. Following Mr. Butler's death the Ness Motley firm associated David O. McCormick to assist as co-counsel for the Butler family in the prosecution of their wrongful death suit against the tobacco industry. The Butler family acquiesced in the association of Mr. McCormick on their behalf. Mr. McCormick and his firm began this representation prior to the filing of the wrongful death action and continued such representation through October 29, 1996.
20. Following the Butler family's retention of Ness Motley and Barrett, these same attorneys undertook to represent the Attorney General of the State of Mississippi in a Medicaid reimbursement suit against the tobacco industry. McCormick also undertook to represent the Attorney General of the State of Mississippi in the Medicaid reimbursement suit. The acceptance of this representation, although without any knowledge or input from the Butler family, did not in and of itself create a conflict of interest. As alleged more specifically below, the interests of Butler and Defendants' Attorneys General clients began to diverge and conflict as the dual representation continued. Defendants, without the waiver, consent, knowledge or authority of Butler, sacrificed and compromised the interests of Butler for the great pecuniary benefit of themselves and their Attorneys General clients.
McCormick Withdrawal
21. On or about October 14, 1996, McCormick abruptly and without warning to or discussion with Butler filed a motion to withdraw as counsel for Butler. The stated reasons for the requested withdrawal were the lack of "a contract of employment" and McCormick's involvement in "other mass tort litigation." A true and correct copy of McCormick's motion to withdraw is attached hereto as Exhibit "A".
22. On information and belief, at the time of McCormick's withdrawal the interests of Butler and McCormick's Attorneys General clients had diverged and begun to conflict. McCormick recognized the conflicts but consciously and purposefully failed to disclose the conflicts to Butler. McCormick was allowed to withdraw by court order dated October 29, 1996.
Ness Motley Attempted Withdrawal
23. In or around December, 1996, Ness Motley communicated its desire to withdraw as counsel for Butler. While Ms. Butler did not object to the requested withdrawal, Butler insisted that the terms of withdrawal require that Ness Motley provide to her other counsel, Langston Frazer Sweet & Freese, all documents in its possession or control which have any relevance to Butler's claims against the tobacco industry. Additionally, Butler insisted that this production include a draft of the rumored "Global Settlement." On January 30, 1997, the Circuit Court of Jones County, Mississippi, ordered Ness Motley to produce the requested documents. Production of the proposed Global Settlement was ordered immediately, via facsimile transmittal and overnight mail. A true an correct copy of such order is attached hereto as Exhibit "B."
24. On or around February 4, 1997, the Court entertained a status conference to discuss Ness Motley's requested withdrawal and its compliance with the Court's January 30, 1997 order. At the hearing, Butler's former counsel McCormick appeared on behalf of Ness Motley in this adversarial matter against Butler. McCormick's representation of Ness Motley was adverse to Butler. It involved a matter which arose out of Ness Motley's representation of Butler in litigation against the tobacco industry. McCormick undertook the representation of Ness Motley without the waiver, consent or authority of Butler.
25. At the February 4, 1997 status conference Ness Motley and Butler's other counsel negotiated an arrangement whereby Ness Motley would continue to represent Butler but would not be required to comply with the court's January 30, 1997 order relative to the transfer of documents. At no time during these negotiations did Ness Motley or McCormick disclose that terms of the proposed Global Settlement of which they were actively negotiating were adverse to Butler.
The Liggett Settlement
26. On or about March 19, 1997, the Attorney General of the State of Mississippi announced that he and his private special deputy attorneys general, including Barrett, Ness Motley and McCormick, had negotiated a landmark settlement with the Liggett Group, Inc. and its affiliates. The settlement included provisions for the payment of monetary consideration and bound Liggett to various forms of injunctive relief. In exchange for this consideration, the Attorney General released certain rights and/or claims against Liggett. Additionally, Barrett, Ness Motley and McCormick agreed to release certain rights of Butler. The release of these rights was without Butler's knowledge, authority, consent or waiver. It was without the authority or approval of the chancery court of Jones County, Mississippi. Further, it was without any consideration to Butler.
27. The rights and claims of Butler purported to have been released are described in the March 20, 1997 Class Settlement Agreement in the cause styled Fletcher v. Brooke Group Ltd., Liggett Group, Inc. A true and correct copy of the Fletcher settlement is attached hereto as Exhibit "C".
28. On March 20, 1997, Defendant Ron Motley communicated with Cynthia Langston, another co-counsel for Butler, and informed her that in connection with the overall Liggett settlement he had agreed on Ms. Butler's behalf to commit that Ms. Butler would not object to the Fletcher settlement. Ms. Langston questioned Motley about committing to a settlement without Butler's consent. Mr. Motley reasoned that the Fletcher settlement probably would not be approved. He instructed Ms. Langston to forward to counsel for Liggett a letter confirming that Ms. Butler would not object to the Fletcher settlement. Ms. Langston followed Mr. Motley's instructions. A true and correct copy of Ms. Langston's March 20, 1997 letter is attached hereto as Exhibit "D".
29. At the time that Barrett and Ness Motley committed Ms. Butler to the Liggett settlement, these Defendants had actual knowledge that the settlement had not been presented to or explained to Ms. Butler. They had actual knowledge that Ms. Butler had not given her authority, approval or consent to the settlement. They had actual knowledge that the release of Butler's rights and claims had not been approved by the chancery court of Jones County, Mississippi. They had actual knowledge that Ms. Butler had not waived the conflict of interest that existed between Butler and their Attorneys General clients. Further, at no time did Ness Motley, Barrett or McCormick disclose to Butler the great financial benefits that they hoped to achieve personally by the compromise of Butler's interests.
30. Following the Fletcher settlement, Liggett and counsel for the plaintiffs made a strategic decision to seek approval of the terms of the Fletcher settlement in a class action styled Walker vs. Liggett Group, Inc. et al., Civil Action No. 2:97-0102, United States District Court, Southern District of West Virginia, Charleston Division. On May 27, 1997 Butler through her counsel Langston Frazer Sweet & Freese filed her objection to the settlement. Over the strenuous objection of counsel for Liggett, the West Virginia court did not bind Butler to the Walker settlement. The court reasoned that Ms. Langston's March 20, 1997 letter referred only to Fletcher and did not prohibit Butler from objecting to an identical settlement in another court.
Liggett Documents / Ex Parte Communications
31. In or around March, 1997, following the unauthorized settlement with Liggett, Barrett, Ness Motley and other co-conspirators caused approximately thirteen (13) boxes of Liggett documents to be delivered to the Circuit Court of Jones County, Mississippi. While the value of these documents to Butler is presently unknown, it is clear that the purpose of the emergency and unorthodox production was intended to benefit Defendants and their other clients. Further, on information and belief one or more Defendants and/or their co-conspirators orchestrated and/or had prior knowledge of exparte communications between Honorable Billy Joe Landrum and the Attorney General of the State of Mississippi. These communications culminated in the recusal of Judge Landrum and the delay of the Butler trial.
32. The above actions were undertaken without the knowledge or consent of Butler. They were undertaken as part of a broader conspiracy to further the interests of Defendants and their Attorneys General clients notwithstanding the potential and foreseeable damaging impact on the Butler litigation. Additionally, the delay in the Butler trial setting which was occasioned by ex parte communications between the Attorney General of the State of Mississippi and Judge Landrum will allow Defendants and their clients to lobby for approval of the Global Settlement prior to Butler's rescheduled June, 1998 trial setting.
33. The above actions proximately caused damage to Butler.
The Global Settlement
34. In or around July, 1997, Defendants and their Attorneys General clients entered into a Global Settlement with the tobacco industry. On information and belief, a copy of the text of the Global Settlement is attached as Exhibit "E."
35. The Global Settlement is adverse to Butler's interests in many respects. The most damaging aspect of the settlement directly impacting Butler is found at Title VII, B., 1., which provides:
B. Provisions as to Civil Liability for Past Conduct
The following provisions apply to suits for relief arising from past conduct - i.e., suits by persons claiming injury or damage caused by conduct taking place prior to the effective date of the Act.
All punitive damages claims resolved as part of overall settlement. No punitive damages in individual tort actions. (Emphasis added)
Action removable by defendant to federal court upon receipt of application to, or order of, state court providing for trial or other procedure in violation of this provision.
36. On information and belief, the tobacco industry has committed to the payment of billions of dollars in attorney fees and expenses in exchange for Defendants' unconditional support of the Global Settlement including Title VII. B. 1. Whether or not Butler ultimately is prohibited from seeking punitive damages in her caue against the tobacco industry Butler has a quantum meruit claim against all attorney fees and expenses claimed by Defendants in connection with their support of the Global Settlement, the Liggett Settlement, settlements involving the Attorney General of the State of Mississippi, and settlements involving any other Attorneys General clients represented by Defendants. This claim extends to all fees and expenses claimed by Defendants in the cause styled Mike Moore, Attorney General ex rel, State of Mississippi vs. The American Tobacco Company, et al., No. 04-1429, Chancery Court, Jackson County, Mississippi (May 23, 1994).
37. Defendants could not have been in a position to earn the promised fees and expenses from the representation of their Attorneys General clients if not for their breach of duties owed to Butler.
Count I (Breach of Fiduciary)
38. Plaintiffs restate the above allegations.
39. Defendants owed to Plaintiffs a fiduciary duty. This fiduciary was contractual and arose out of the relative position and knowledge of the parties. The Butler family has no legal training. Defendants are all attorneys and/or law firms. The stark contrast in the education, training, knowledge and experience of Defendants versus that of the Butler family relative to legal issues, including issues involving civil torts and legal ethics, created a great trust justifiably and reasonably reposed on Defendants by the Butler family.
40. Defendants breached the fiduciary duties owed to Plaintiffs. The breach was intentional and/or grossly negligent. Defendants intentionally and/or negligently abrogated the fiduciary duties owed to Plaintiffs in exchange for the commitment on the part of the tobacco industry toward the payment of billions of dollars in attorney fees and expenses.
41. Plaintiffs were damaged as a proximate result of Defendants' breach of fiduciary. Plaintiffs in equity and law claim as compensatory damages all attorney fees and expenses earned or to be earned by Defendants in exchange for their support of the Global Settlement, the Liggett Settlement, settlements involving the Attorney General of the State of Mississippi, and settlements involving any other Attorneys General clients represented by Defendants. Such damages include the fees and expenses earned or to be earned by Defendants in the cause styled Mike Moore, Attorney General ex rel, State of Mississippi vs. The American Tobacco Company, et al., No. 04-1429, Chancery Court, Jackson County, Mississippi (May 23, 1994).
Count II
(Breach of Loyalty)
42. Plaintiffs restate the above allegations.
43. Defendants owed to Plaintiffs a duty of loyalty and good faith. This duty was contractual and was imposed on Defendants under the laws of the state of Mississippi and the Mississippi Code of Professional Responsibility pursuant to Defendants' attorney/client relationship with Plaintiffs.
44. Defendants breached the duty of loyalty owed to Plaintiffs. Defendants sacrificed the interests of Plaintiffs in exchange for pecuniary benefits to themselves and their Attorneys General clients. Defendants sacrificed such interests of Plaintiffs without Plaintiffs' authority, consent or waiver. Such breach by Defendants was intentional and/or grossly negligent. Defendants intentionally and/or negligently breached duties of loyalty owed to Plaintiffs in exchange for the commitment on the part of the tobacco industry toward the payment of billions of dollars in attorney fees and expenses.
45. Plaintiffs were damaged as a proximate result of Defendants' breach of the duty of loyalty. Plaintiffs in equity and law claim as compensatory damages all attorney fees and expenses earned or to be earned by Defendants in exchange for their support of the Global Settlement, the Liggett Settlement, settlements involving the Attorney General of the State of Mississippi, and settlements involving any other Attorneys General clients represented by Defendants. Such damages include the fees and expenses earned or to be earned by Defendants in the cause styled Mike Moore, Attorney General ex rel, State of Mississippi vs. The American Tobacco Company, et al., No. 04-1429, Chancery Court, Jackson County, Mississippi (May 23, 1994).
Count III
(Breach of Contract / Implied Duty of Good Faith and Fair Dealing)
46. Plaintiffs restate the above allegations.
47. Defendants were contractually bound to prosecute the tobacco industry for compensatory and punitive damages on behalf of Plaintiffs. Such a contract impliedly imposed on Defendants the duties of good faith and fair dealing in the execution and performance of the contract.
48. Defendants intentionally and/or negligently breached the contractual duties owed to Plaintiffs and breached the duties of good faith and fair dealing. Such breaches were committed in exchange for the commitment on the part of the tobacco industry toward the payment of billions of dollars in attorney fees and expenses.
49. Plaintiffs were damaged as a proximate result of Defendants' breach of contract and the duties of good faith and fair dealing. Plaintiffs in equity and law claim as compensatory damages all attorney fees and expenses earned or to be earned by Defendants in exchange for their support of the Global Settlement, the Liggett Settlement, settlements involving the Attorney General of the State of Mississippi, and settlements involving any other Attorneys General clients represented by Defendants. Such damages include the fees and expenses earned or to be earned by Defendants in the cause styled Mike Moore, Attorney General ex rel, State of Mississippi vs. The American Tobacco Company, et al., No. 04-1429, Chancery Court, Jackson County, Mississippi (May 23, 1994).
Count IV
(Equitable and Injunctive Relief)
50. Plaintiffs restate the above allegations.
51. Defendants, without Plaintiffs' knowledge, consent or authority used Butler vs. Philip Morris Incorporated, Civil Action No. 94-5-53, Circuit Court, Second Judicial District, Jones County, Mississippi, as a vehicle to enhance negotiating leverage of their Attorneys General clients. On information and belief, such actions included but were not limited to the unauthorized use of attorney work product. Defendants undertook such actions for their own pecuniary benefit and to the exclusion of Plaintiffs. Plaintiffs make a quantum meruit claim against all attorney fees and expenses earned or to be earned by Defendants in whole or in part through the unauthorized use of Butler vs. Philip Morris Incorporated, Civil Action No. 94-5-53, Circuit Court, Second Judicial District, Jones County, Mississippi, as a vehicle to enhance the negotiating leverage of their Attorneys General clients thereby culminating in the tobacco industry's commitment of billions of dollars in attorney fees and expenses to Defendants.
52. Plaintiffs have a quantum meruit claim against all attorney fees and expenses earned or to be earned by Defendants in exchange for their support of the Global Settlement, the Liggett Settlement, settlements involving the Attorney General of the State of Mississippi, and settlements involving any other Attorneys General clients represented by Defendants. Plaintiffs request that this court exercise its equitable powers to disgorge Defendants of the profits they have earned and reasonably expect to earn in whole or in part through the tortious acts set forth in this complaint.
53. Plaintiffs request that the court enjoin Defendants from the collection of attorney fees or expenses earned in whole in or part through the breaches set forth above.
54. Additionally, Plaintiffs request that the court order Defendants to produce at their own expense all work product and documents in their possession or under their control which relate to the claims advanced by Plaintiffs in Butler vs. Philip Morris Incorporated, Civil Action No. 94-5-53, Circuit Court, Second Judicial District, Jones County, Mississippi.
Count V
(Negligence)
55. Plaintiffs restate the above allegations.
56. Defendants owed to Plaintiffs a duty to exercise reasonable care in the performance of their legal, ethical and contractual duties relative to their representation of Butler. Defendants breached this duty. Such breach proximately caused damage to Plaintiffs.
Count VI
(Punitive Damages)
57. Plaintiffs restate the above allegations.
58. Defendants' actions and inactions were intentional, malicious, and/or grossly negligent and justify the award of punitive damages.
59. Defendants' breaches of contractual, fiduciary, and loyalty were so egregious so as to amount to independent torts justifying an award of punitive damages.
For these reasons, Plaintiffs request judgment against Defendants individually, jointly and severally for compensatory damages in excess of Five Hundred Million Dollars ($500,000,000.00) or an amount to be proven at trial and requests an award of punitive damages in excess of One Billion Dollars ($1,000,000,000.00) or an amount to be proven at trial. Plaintiffs request an award of equitable and injunctive relief as set forth above. Plaintiffs further request such other relief as this court in equity may deem just.
Dated: August 18, 1997.
Respectfully submitted: Shane F. Langston, on behalf of Ava Dean Butler, Executrix for the Estate of Burl Butler
Dennis C. Sweet, III, on behalf of Ava Dean Butler, Executrix for the Estate of Burl Butler
OF COUNSEL:
LANGSTON FRAZER SWEET & FREESE, P.A. Shane F. Langston MS Bar # 1061 Dennis C. Sweet, III MS Bar # 8105 201 N. President Street Jackson, Mississippi 39201 (601) 969-1356
Dan C. Taylor Post Office Box 6 Ellisville, Mississippi 39437 (601) 649-6144
Robert Sullivan. SULLIVAN & SULLIVAN Post Office Box 1131 Laurel, Mississippi 39440 (601) 428-1505
W.O. Chet Dillard 101 North State Street Jackson, Mississippi 39201 (601) 355-7961