SW BK File

Case 3:18-cv-00866-CWR-FKB Document 56 Filed 11/04/19 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF MISSISSIPPI
NORTHERN DIVISION
ALYSSON MILLS, IN HER CAPACITY PLAINTIFF

AS RECEIVER FOR ARTHUR LAMAR
ADAMS AND MADISON TIMBER
PROPERTIES, LLC
vs. CASE NO. 3:18-cv-866-CWR-FKB
BUTLER SNOW LLP; BUTLER SNOW DEFENDANTS

ADVISORY SERVICES, LLC; MATT
THORNTON; BAKER, DONELSON,
BEARMAN, CALDWELL & BERKOWITZ
PC; ALEXANDER SEAWRIGHT, LLC;
BRENT ALEXANDER; and JON
SEAWRIGHT
NOTICE OF SUGGESTION OF BANKRUPTCY

AND AUTOMATIC STAY OF PROCEEDINGS
Please be advised that on November 3, 2019, Defendant Jon Seawright filed a voluntary
petition for bankruptcy relief under Chapter 7 of the United States Bankruptcy Code, in the
United States Bankruptcy Court for the Southern District of Mississippi. Mr. Seawright’s
bankruptcy action is docketed as Case No. 19-03921.
Pursuant to the United States Bankruptcy Code, the filing of a bankruptcy petition
operates as a stay of, among other things, the commencement or continuation of any judicial,
administrative, or other action or proceeding against the debtor that was or could have been
commenced before the petition was filed, or to recover a claim against the debtor that arose
before the petition was filed. All actions against Mr. Seawright, including this civil action,
should be stayed during the pendency of the bankruptcy case, or until further order of the
Bankruptcy Court. Any action taken against the debtor without obtaining the necessary relief
from the automatic stay from the Bankruptcy Court is void ab initio and may be subject to
findings of contempt and the assessment of penalties and fines. The debtor reserves and retains
his statutory right to seek relief in the Bankruptcy Court from any action by Plaintiff or any
judgment, order, or ruling entered in violation of the automatic stay.
In the event the Court or any party has any question regarding Mr. Seawright’s
bankruptcy, please contact Mr. Seawright’s bankruptcy counsel:
R. Michael Bolen
Hood & Bolen, PLLC
370 Highway 80 West
Jackson, MS 39209
Telephone: (601) 923-0788
Facsimile: (601) 922-2968
Email: rmb@hoodbolen.com
Dated: November 4, 2019.
Respectfully submitted,
ALEXANDER SEAWRIGHT, LLC; BRENT

ALEXANDER; and JON SEAWRIGHT
By: /s/ Cody C. Bailey

One of Their Attorneys
OF COUNSEL:
R. David Kaufman (MSB #3526)

Cody C. Bailey (MSB #103718)
BRUNINI, GRANTHAM, GROWER & HEWES, PLLC
The Pinnacle Building, Suite 100
190 East Capitol Street (39201)
Post Office Drawer 119
Jackson, Mississippi 39205
Telephone: (601) 948-3101
Facsimile: (601) 960-6902
dkaufman@brunini.com
cbailey@brunini.com
2
CERTIFICATE OF SERVICE
I, Cody C. Bailey, hereby certify that I have this day caused the foregoing pleading to be
electronically filed with the Clerk of the Court using the CM/ECF system, which will send
notification of such filing to all counsel of record and registered participants.
Dated: November 4, 2019.
/s/ Cody C. Bailey

Cody C. Bailey
3
19-03921-NPO Dkt 1 Filed 11/03/19 Entered 11/03/19 13:02:48 Page 1 of 8
Fill in this information to identify your case:
United States Bankruptcy Court for the:
SOUTHERN DISTRICT OF MISSISSIPPI
Case number (if known) Chapter you are filing under:
Chapter 7
Chapter 11
Chapter 12
Chapter 13 Check if this is an
amended filing
Official Form 101

Voluntary Petition for Individuals Filing for Bankruptcy 12/17
The bankruptcy forms use you and Debtor 1 to refer to a debtor filing alone. A married couple may file a bankruptcy case together—called a joint
case—and in joint cases, these forms use you to ask for information from both debtors. For example, if a form asks, “Do you own a car,” the answer
would be yes if either debtor owns a car. When information is needed about the spouses separately, the form uses Debtor 1 and Debtor 2 to distinguish
between them. In joint cases, one of the spouses must report information as Debtor 1 and the other as Debtor 2. The same person must be Debtor 1 in
all of the forms.
Be as complete and accurate as possible. If two married people are filing together, both are equally responsible for supplying correct information. If
more space is needed, attach a separate sheet to this form. On the top of any additional pages, write your name and case number (if known). Answer
every question.
Part 1: Identify Yourself
About Debtor 1: About Debtor 2 (Spouse Only in a Joint Case):
1. Your full name
Write the name that is on Jon

your government-issued First name First name
picture identification (for
example, your driver's Darrell
license or passport). Middle name Middle name
Bring your picture
identification to your
Seawright
meeting with the trustee. Last name and Suffix (Sr., Jr., II, III) Last name and Suffix (Sr., Jr., II, III)
2. All other names you have

used in the last 8 years
Include your married or
maiden names.
3. Only the last 4 digits of

your Social Security
number or federal xxx-xx-3273
Individual Taxpayer
Identification number
(ITIN)
Official Form 101 Voluntary Petition for Individuals Filing for Bankruptcy page 1
Debtor 1 Jon Darrell Seawright Case number (if known)
4. Any business names and

Employer Identification
Numbers (EIN) you have I have not used any business name or EINs. I have not used any business name or EINs.
used in the last 8 years
Include trade names and Business name(s) Business name(s)

doing business as names
EINs EINs
5. Where you live If Debtor 2 lives at a different address:
4247 Crane Boulevard

Jackson, MS 39216
Number, Street, City, State & ZIP Code Number, Street, City, State & ZIP Code
Hinds
County County
If your mailing address is different from the one If Debtor 2's mailing address is different from yours, fill it
above, fill it in here. Note that the court will send any in here. Note that the court will send any notices to this
notices to you at this mailing address. mailing address.
Number, P.O. Box, Street, City, State & ZIP Code Number, P.O. Box, Street, City, State & ZIP Code
6. Why you are choosing Check one: Check one:

this district to file for
bankruptcy Over the last 180 days before filing this petition, Over the last 180 days before filing this petition, I
I have lived in this district longer than in any have lived in this district longer than in any other
other district. district.
I have another reason. I have another reason.

Explain. (See 28 U.S.C. § 1408.) Explain. (See 28 U.S.C. § 1408.)
Part 2: Tell the Court About Your Bankruptcy Case
7. The chapter of the Check one. (For a brief description of each, see Notice Required by 11 U.S.C. § 342(b) for Individuals Filing for Bankruptcy
Bankruptcy Code you are (Form 2010)). Also, go to the top of page 1 and check the appropriate box.
choosing to file under
Chapter 7
Chapter 11
Chapter 12
Chapter 13
8. How you will pay the fee I will pay the entire fee when I file my petition. Please check with the clerk’s office in your local court for more details
about how you may pay. Typically, if you are paying the fee yourself, you may pay with cash, cashier’s check, or money
order. If your attorney is submitting your payment on your behalf, your attorney may pay with a credit card or check with
a pre-printed address.
I need to pay the fee in installments. If you choose this option, sign and attach the Application for Individuals to Pay
The Filing Fee in Installments (Official Form 103A).
I request that my fee be waived (You may request this option only if you are filing for Chapter 7. By law, a judge may,
but is not required to, waive your fee, and may do so only if your income is less than 150% of the official poverty line that
applies to your family size and you are unable to pay the fee in installments). If you choose this option, you must fill out
the Application to Have the Chapter 7 Filing Fee Waived (Official Form 103B) and file it with your petition.
9. Have you filed for No.

bankruptcy within the
last 8 years? Yes.
District When Case number
10. Are any bankruptcy No

cases pending or being
filed by a spouse who is Yes.
not filing this case with
you, or by a business
partner, or by an
affiliate?
Debtor Relationship to you
District When Case number, if known
Debtor Relationship to you
District When Case number, if known
11. Do you rent your No. Go to line 12.

residence?
Yes. Has your landlord obtained an eviction judgment against you?
No. Go to line 12.
Yes. Fill out Initial Statement About an Eviction Judgment Against You (Form 101A) and file it as part of
this bankruptcy petition.
Part 3: Report About Any Businesses You Own as a Sole Proprietor
12. Are you a sole proprietor

of any full- or part-time No. Go to Part 4.
business?
Yes. Name and location of business
A sole proprietorship is a
business you operate as Name of business, if any
an individual, and is not a
separate legal entity such
as a corporation,
partnership, or LLC.
Number, Street, City, State & ZIP Code
If you have more than one
sole proprietorship, use a
separate sheet and attach
it to this petition. Check the appropriate box to describe your business:
Health Care Business (as defined in 11 U.S.C. § 101(27A))
Single Asset Real Estate (as defined in 11 U.S.C. § 101(51B))
Stockbroker (as defined in 11 U.S.C. § 101(53A))
Commodity Broker (as defined in 11 U.S.C. § 101(6))
None of the above
13. Are you filing under If you are filing under Chapter 11, the court must know whether you are a small business debtor so that it can set appropriate
Chapter 11 of the deadlines. If you indicate that you are a small business debtor, you must attach your most recent balance sheet, statement of
Bankruptcy Code and are operations, cash-flow statement, and federal income tax return or if any of these documents do not exist, follow the procedure
you a small business in 11 U.S.C. 1116(1)(B).
debtor?
No. I am not filing under Chapter 11.
For a definition of small
business debtor, see 11
No. I am filing under Chapter 11, but I am NOT a small business debtor according to the definition in the Bankruptcy
U.S.C. § 101(51D).
Code.
Yes. I am filing under Chapter 11 and I am a small business debtor according to the definition in the Bankruptcy Code.
Part 4: Report if You Own or Have Any Hazardous Property or Any Property That Needs Immediate Attention
14. Do you own or have any No.

property that poses or is
alleged to pose a threat Yes.
of imminent and What is the hazard?
identifiable hazard to
public health or safety?
Or do you own any
property that needs If immediate attention is
immediate attention? needed, why is it needed?
For example, do you own

perishable goods, or
livestock that must be fed, Where is the property?
or a building that needs
urgent repairs?
Number, Street, City, State & Zip Code
Part 5: Explain Your Efforts to Receive a Briefing About Credit Counseling

15. Tell the court whether You must check one: You must check one:
you have received a I received a briefing from an approved credit I received a briefing from an approved credit
briefing about credit counseling agency within the 180 days before I counseling agency within the 180 days before I filed
counseling. filed this bankruptcy petition, and I received a this bankruptcy petition, and I received a certificate of
certificate of completion. completion.
The law requires that you
receive a briefing about Attach a copy of the certificate and the payment Attach a copy of the certificate and the payment plan, if
credit counseling before plan, if any, that you developed with the agency. any, that you developed with the agency.
you file for bankruptcy.
You must truthfully check I received a briefing from an approved credit I received a briefing from an approved credit
one of the following counseling agency within the 180 days before I counseling agency within the 180 days before I filed
choices. If you cannot do filed this bankruptcy petition, but I do not have this bankruptcy petition, but I do not have a certificate
so, you are not eligible to a certificate of completion. of completion.
file.
Within 14 days after you file this bankruptcy Within 14 days after you file this bankruptcy petition, you
If you file anyway, the court petition, you MUST file a copy of the certificate and MUST file a copy of the certificate and payment plan, if
can dismiss your case, you payment plan, if any. any.
will lose whatever filing fee
you paid, and your I certify that I asked for credit counseling I certify that I asked for credit counseling services
creditors can begin services from an approved agency, but was from an approved agency, but was unable to obtain
collection activities again. unable to obtain those services during the 7 those services during the 7 days after I made my
days after I made my request, and exigent request, and exigent circumstances merit a 30-day
circumstances merit a 30-day temporary waiver temporary waiver of the requirement.
of the requirement.
To ask for a 30-day temporary waiver of the requirement,
To ask for a 30-day temporary waiver of the attach a separate sheet explaining what efforts you made
requirement, attach a separate sheet explaining to obtain the briefing, why you were unable to obtain it
what efforts you made to obtain the briefing, why before you filed for bankruptcy, and what exigent
you were unable to obtain it before you filed for circumstances required you to file this case.
bankruptcy, and what exigent circumstances
required you to file this case. Your case may be dismissed if the court is dissatisfied
with your reasons for not receiving a briefing before you
Your case may be dismissed if the court is filed for bankruptcy.
dissatisfied with your reasons for not receiving a
briefing before you filed for bankruptcy. If the court is satisfied with your reasons, you must still
If the court is satisfied with your reasons, you must receive a briefing within 30 days after you file. You must
still receive a briefing within 30 days after you file. file a certificate from the approved agency, along with a
You must file a certificate from the approved copy of the payment plan you developed, if any. If you do
agency, along with a copy of the payment plan you not do so, your case may be dismissed.
developed, if any. If you do not do so, your case
Any extension of the 30-day deadline is granted only for
may be dismissed.
cause and is limited to a maximum of 15 days.
Any extension of the 30-day deadline is granted
only for cause and is limited to a maximum of 15
days.
I am not required to receive a briefing about I am not required to receive a briefing about credit
credit counseling because of: counseling because of:
Incapacity. Incapacity.
I have a mental illness or a mental deficiency I have a mental illness or a mental deficiency that
that makes me incapable of realizing or makes me incapable of realizing or making rational
making rational decisions about finances. decisions about finances.
Disability. Disability.
My physical disability causes me to be My physical disability causes me to be unable to
unable to participate in a briefing in person, participate in a briefing in person, by phone, or
by phone, or through the internet, even after I through the internet, even after I reasonably tried to
reasonably tried to do so. do so.
Active duty. Active duty.

I am currently on active military duty in a I am currently on active military duty in a military
military combat zone. combat zone.
If you believe you are not required to receive a If you believe you are not required to receive a briefing
briefing about credit counseling, you must file a about credit counseling, you must file a motion for waiver
motion for waiver credit counseling with the court. of credit counseling with the court.
Part 6: Answer These Questions for Reporting Purposes
16. What kind of debts do 16a. Are your debts primarily consumer debts? Consumer debts are defined in 11 U.S.C. § 101(8) as “incurred by an
you have? individual primarily for a personal, family, or household purpose.”
No. Go to line 16b.

Yes. Go to line 17.
16b. Are your debts primarily business debts? Business debts are debts that you incurred to obtain
money for a business or investment or through the operation of the business or investment.
No. Go to line 16c.
Yes. Go to line 17.

16c. State the type of debts you owe that are not consumer debts or business debts
17. Are you filing under No. I am not filing under Chapter 7. Go to line 18.
Chapter 7?
Do you estimate that Yes. I am filing under Chapter 7. Do you estimate that after any exempt property is excluded and administrative expenses
after any exempt are paid that funds will be available to distribute to unsecured creditors?
property is excluded and
administrative expenses No
are paid that funds will
be available for Yes
distribution to unsecured
creditors?
18. How many Creditors do 1-49 1,000-5,000 25,001-50,000

you estimate that you 5001-10,000 50,001-100,000
owe? 50-99
100-199 10,001-25,000 More than100,000
200-999
19. How much do you $0 - $50,000 $1,000,001 - $10 million $500,000,001 - $1 billion
estimate your assets to $50,001 - $100,000 $1,000,000,001 - $10 billion
be worth? $10,000,001 - $50 million
$100,001 - $500,000 $50,000,001 - $100 million $10,000,000,001 - $50 billion
$500,001 - $1 million $100,000,001 - $500 million More than $50 billion
20. How much do you $0 - $50,000 $1,000,001 - $10 million $500,000,001 - $1 billion
estimate your liabilities $50,001 - $100,000 $10,000,001 - $50 million $1,000,000,001 - $10 billion
to be?
$100,001 - $500,000 $50,000,001 - $100 million $10,000,000,001 - $50 billion
$500,001 - $1 million $100,000,001 - $500 million More than $50 billion
Part 7: Sign Below
For you I have examined this petition, and I declare under penalty of perjury that the information provided is true and correct.
If I have chosen to file under Chapter 7, I am aware that I may proceed, if eligible, under Chapter 7, 11,12, or 13 of title 11,
United States Code. I understand the relief available under each chapter, and I choose to proceed under Chapter 7.
If no attorney represents me and I did not pay or agree to pay someone who is not an attorney to help me fill out this
document, I have obtained and read the notice required by 11 U.S.C. § 342(b).
I request relief in accordance with the chapter of title 11, United States Code, specified in this petition.
I understand making a false statement, concealing property, or obtaining money or property by fraud in connection with a
bankruptcy case can result in fines up to $250,000, or imprisonment for up to 20 years, or both. 18 U.S.C. §§ 152, 1341, 1519,
and 3571.
/s/ Jon Darrell Seawright
Jon Darrell Seawright Signature of Debtor 2
Signature of Debtor 1
Executed on November 3, 2019 Executed on

MM / DD / YYYY MM / DD / YYYY
For your attorney, if you are I, the attorney for the debtor(s) named in this petition, declare that I have informed the debtor(s) about eligibility to proceed
represented by one under Chapter 7, 11, 12, or 13 of title 11, United States Code, and have explained the relief available under each chapter
for which the person is eligible. I also certify that I have delivered to the debtor(s) the notice required by 11 U.S.C. § 342(b)
If you are not represented by and, in a case in which § 707(b)(4)(D) applies, certify that I have no knowledge after an inquiry that the information in the
an attorney, you do not need schedules filed with the petition is incorrect.
to file this page.
/s/ R. Michael Bolen Miss. Bar Date November 3, 2019
Signature of Attorney for Debtor MM / DD / YYYY
R. Michael Bolen Miss. Bar 3615

Printed name
Hood & Bolen, PLLC

Firm name
Attorneys at Law
3770 Highway 80 West
Jackson, MS 39209
Number, Street, City, State & ZIP Code
Contact phone (601)923-0788 Email address rmb@hoodbolen.com

Miss. Bar 3615 MS
Bar number & State
United States Bankruptcy Court

Southern District of Mississippi
In re Jon Darrell Seawright Case No.
Debtor(s) Chapter 7
VERIFICATION OF CREDITOR MATRIX
The above-named Debtor hereby verifies that the attached list of creditors is true and correct to the best of his/her knowledge.
Date: November 3, 2019 /s/ Jon Darrell Seawright

Jon Darrell Seawright
Signature of Debtor
Software Copyright (c) 1996-2019 Best Case, LLC - www.bestcase.com Best Case Bankruptcy
Debtor 1 Jon Darrell Seawright

First Name Middle Name Last Name
Debtor 2
(Spouse if, filing) First Name Middle Name Last Name
United States Bankruptcy Court for the: SOUTHERN DISTRICT OF MISSISSIPPI
Case number
(if known) Check if this is an
amended filing
Official Form 106Sum

Summary of Your Assets and Liabilities and Certain Statistical Information 12/15
Be as complete and accurate as possible. If two married people are filing together, both are equally responsible for supplying correct
information. Fill out all of your schedules first; then complete the information on this form. If you are filing amended schedules after you file
your original forms, you must fill out a new Summary and check the box at the top of this page.
Part 1: Summarize Your Assets
Your assets
Value of what you own
1. Schedule A/B: Property (Official Form 106A/B)

1a. Copy line 55, Total real estate, from Schedule A/B................................................................................................ $ 575,000.00
1b. Copy line 62, Total personal property, from Schedule A/B..................................................................................... $ 714,100.00
1c. Copy line 63, Total of all property on Schedule A/B............................................................................................... $ 1,289,100.00
Part 2: Summarize Your Liabilities
Your liabilities
Amount you owe
2. Schedule D: Creditors Who Have Claims Secured by Property (Official Form 106D)
2a. Copy the total you listed in Column A, Amount of claim, at the bottom of the last page of Part 1 of Schedule D... $ 470,000.00
3. Schedule E/F: Creditors Who Have Unsecured Claims (Official Form 106E/F)
3a. Copy the total claims from Part 1 (priority unsecured claims) from line 6e of Schedule E/F................................. $ 0.00
3b. Copy the total claims from Part 2 (nonpriority unsecured claims) from line 6j of Schedule E/F............................ $ 165,926,723.00
Your total liabilities $ 166,396,723.00
Part 3: Summarize Your Income and Expenses
4. Schedule I: Your Income (Official Form 106I)

Copy your combined monthly income from line 12 of Schedule I................................................................................ $ 20,742.36
5. Schedule J: Your Expenses (Official Form 106J)

Copy your monthly expenses from line 22c of Schedule J.......................................................................... $ 20,587.04
Part 4: Answer These Questions for Administrative and Statistical Records
6. Are you filing for bankruptcy under Chapters 7, 11, or 13?

No. You have nothing to report on this part of the form. Check this box and submit this form to the court with your other schedules.
Yes
7. What kind of debt do you have?
Your debts are primarily consumer debts. Consumer debts are those “incurred by an individual primarily for a personal, family, or
household purpose.” 11 U.S.C. § 101(8). Fill out lines 8-9g for statistical purposes. 28 U.S.C. § 159.
Your debts are not primarily consumer debts. You have nothing to report on this part of the form. Check this box and submit this form to
the court with your other schedules.
Official Form 106Sum Summary of Your Assets and Liabilities and Certain Statistical Information page 1 of 2
8. From the Statement of Your Current Monthly Income: Copy your total current monthly income from Official Form
122A-1 Line 11; OR, Form 122B Line 11; OR, Form 122C-1 Line 14. $
9. Copy the following special categories of claims from Part 4, line 6 of Schedule E/F:
Total claim
From Part 4 on Schedule E/F, copy the following:
9a. Domestic support obligations (Copy line 6a.) $ 0.00
9b. Taxes and certain other debts you owe the government. (Copy line 6b.) $ 0.00
9c. Claims for death or personal injury while you were intoxicated. (Copy line 6c.) $ 0.00
9d. Student loans. (Copy line 6f.) $ 49,948.00
9e. Obligations arising out of a separation agreement or divorce that you did not report as
priority claims. (Copy line 6g.) $ 0.00
9f. Debts to pension or profit-sharing plans, and other similar debts. (Copy line 6h.) +$ 0.00
9g. Total. Add lines 9a through 9f. $ 49,948.00
Official Form 106Sum Summary of Your Assets and Liabilities and Certain Statistical Information page 2 of 2
Fill in this information to identify your case and this filing:

Debtor 2
(Spouse, if filing) First Name Middle Name Last Name
Case number Check if this is an

amended filing
Official Form 106A/B

Schedule A/B: Property 12/15
In each category, separately list and describe items. List an asset only once. If an asset fits in more than one category, list the asset in the category where you
think it fits best. Be as complete and accurate as possible. If two married people are filing together, both are equally responsible for supplying correct
information. If more space is needed, attach a separate sheet to this form. On the top of any additional pages, write your name and case number (if known).
Answer every question.
Part 1: Describe Each Residence, Building, Land, or Other Real Estate You Own or Have an Interest In
1. Do you own or have any legal or equitable interest in any residence, building, land, or similar property?
No. Go to Part 2.
Yes. Where is the property?
1.1 What is the property? Check all that apply

4247 Crane Boulevard Single-family home Do not deduct secured claims or exemptions. Put
Street address, if available, or other description the amount of any secured claims on Schedule D:
Duplex or multi-unit building
Creditors Who Have Claims Secured by Property.
Condominium or cooperative
Manufactured or mobile home

Current value of the Current value of the
Jackson MS 39216-0000 Land entire property? portion you own?
City State ZIP Code Investment property $575,000.00 $575,000.00
Timeshare
Describe the nature of your ownership interest
Other (such as fee simple, tenancy by the entireties, or
Who has an interest in the property? Check one a life estate), if known.
Debtor 1 only
Hinds Debtor 2 only
County Debtor 1 and Debtor 2 only
Check if this is community property
At least one of the debtors and another (see instructions)
Other information you wish to add about this item, such as local
property identification number:
Debtor and wife own as tentants by the entirety with full rights of
survivorship.
2. Add the dollar value of the portion you own for all of your entries from Part 1, including any entries for
pages you have attached for Part 1. Write that number here...........................................................................=> $575,000.00
Part 2: Describe Your Vehicles
Do you own, lease, or have legal or equitable interest in any vehicles, whether they are registered or not? Include any vehicles you own that
someone else drives. If you lease a vehicle, also report it on Schedule G: Executory Contracts and Unexpired Leases.
3. Cars, vans, trucks, tractors, sport utility vehicles, motorcycles
No
Yes
Official Form 106A/B Schedule A/B: Property page 1

4. Watercraft, aircraft, motor homes, ATVs and other recreational vehicles, other vehicles, and accessories
Examples: Boats, trailers, motors, personal watercraft, fishing vessels, snowmobiles, motorcycle accessories
No
Yes
4.1 Make: Honda Who has an interest in the property? Check one
Do not deduct secured claims or exemptions. Put
the amount of any secured claims on Schedule D:
Model: Debtor 1 only Creditors Who Have Claims Secured by Property.
Year: 2004 Debtor 2 only Current value of the Current value of the
Debtor 1 and Debtor 2 only entire property? portion you own?
Other information: At least one of the debtors and another
Check if this is community property $250.00 $250.00
4 wheeler that doesn't run. (see instructions)
5 Add the dollar value of the portion you own for all of your entries from Part 2, including any entries for
.pages you have attached for Part 2. Write that number here.............................................................................=> $250.00
Part 3: Describe Your Personal and Household Items

Do you own or have any legal or equitable interest in any of the following items? Current value of the
portion you own?
Do not deduct secured
claims or exemptions.
6. Household goods and furnishings
Examples: Major appliances, furniture, linens, china, kitchenware
No
Yes. Describe.....
1/2 interest in standard household goods for 6/4.5 house including

living room, dining room, and bedroom furniture, televisions, and
kitchen appliances, etc. $2,500.00
7. Electronics
Examples: Televisions and radios; audio, video, stereo, and digital equipment; computers, printers, scanners; music collections; electronic devices
including cell phones, cameras, media players, games
No
Yes. Describe.....
iPhone $200.00
8. Collectibles of value
Examples: Antiques and figurines; paintings, prints, or other artwork; books, pictures, or other art objects; stamp, coin, or baseball card collections;
other collections, memorabilia, collectibles
No
Yes. Describe.....
9. Equipment for sports and hobbies

Examples: Sports, photographic, exercise, and other hobby equipment; bicycles, pool tables, golf clubs, skis; canoes and kayaks; carpentry tools;
musical instruments
No
Yes. Describe.....
10. Firearms
Examples: Pistols, rifles, shotguns, ammunition, and related equipment
No
Yes. Describe.....
Benelli over/under 12 gauge. $750.00

Glock 17 - 9mm $300.00
T/C .35 Whelen $350.00
11. Clothes
Examples: Everyday clothes, furs, leather coats, designer wear, shoes, accessories
No
Yes. Describe.....
Standard clothing $250.00
12. Jewelry
Examples: Everyday jewelry, costume jewelry, engagement rings, wedding rings, heirloom jewelry, watches, gems, gold, silver
No
Yes. Describe.....
Wedding ring. $250.00
13. Non-farm animals

Examples: Dogs, cats, birds, horses
No
Yes. Describe.....
14. Any other personal and household items you did not already list, including any health aids you did not list
No
Yes. Give specific information.....
15. Add the dollar value of all of your entries from Part 3, including any entries for pages you have attached
for Part 3. Write that number here .............................................................................. $4,600.00
Part 4: Describe Your Financial Assets

Do you own or have any legal or equitable interest in any of the following? Current value of the
portion you own?
16. Cash
Examples: Money you have in your wallet, in your home, in a safe deposit box, and on hand when you file your petition
No
Yes................................................................................................................
Cash $750.00
17. Deposits of money

Examples: Checking, savings, or other financial accounts; certificates of deposit; shares in credit unions, brokerage houses, and other similar
institutions. If you have multiple accounts with the same institution, list each.
No
Yes........................ Institution name:
17.1. BancorpSouth $500.00

18. Bonds, mutual funds, or publicly traded stocks

Examples: Bond funds, investment accounts with brokerage firms, money market accounts
No
Yes.................. Institution or issuer name:
19. Non-publicly traded stock and interests in incorporated and unincorporated businesses, including an interest in an LLC, partnership, and
joint venture
No
Yes. Give specific information about them...................
Name of entity: % of ownership:
850 shares of stock in Baker Donelson that is

not marketable % $0.00
1/2 ownership of Alexander Seawright, LLC.

Brent Alexander owns the remaining 1/2 interest.
This company owns Alexander Seawright
Clearman, LLC, Alexander Seawright
MacroEvent Fund, LLC, Alexander Seawright
Oklahoma Oil Services Fund, LLC, Alexander
Seawright PetroEnergy DeGeer # 2, LLC,
Alexander Seawright PetroEnergy
Transportation, LLC, Alexander Seawright
Timber Fund I, LLC, Alexander Seawright Timber
Fund II, LLC, all of which have filed an intent to
dissolve and Alexander Seawright
Transportation, LLC, which is in a Chapter 7
bankruptcy case, no. 19-00217-NPO. 50% % Unknown
Alexander Seawright Agnes Partnership that

holds interests in oil wells paying debtor $75.00
a month. 25% % Unknown
20. Government and corporate bonds and other negotiable and non-negotiable instruments
Negotiable instruments include personal checks, cashiers’ checks, promissory notes, and money orders.
Non-negotiable instruments are those you cannot transfer to someone by signing or delivering them.
No
Yes. Give specific information about them
Issuer name:
21. Retirement or pension accounts

Examples: Interests in IRA, ERISA, Keogh, 401(k), 403(b), thrift savings accounts, or other pension or profit-sharing plans
No
Yes. List each account separately.
Type of account: Institution name:
ERISA 401k wih Mass Mutual $700,000.00
ERISA IRA with TD Ameritrde $8,000.00
22. Security deposits and prepayments

Your share of all unused deposits you have made so that you may continue service or use from a company
Examples: Agreements with landlords, prepaid rent, public utilities (electric, gas, water), telecommunications companies, or others
No
Yes. ..................... Institution name or individual:
23. Annuities (A contract for a periodic payment of money to you, either for life or for a number of years)
No
Yes............. Issuer name and description.

24. Interests in an education IRA, in an account in a qualified ABLE program, or under a qualified state tuition program.
26 U.S.C. §§ 530(b)(1), 529A(b), and 529(b)(1).
No
Yes............. Institution name and description. Separately file the records of any interests.11 U.S.C. § 521(c):
25. Trusts, equitable or future interests in property (other than anything listed in line 1), and rights or powers exercisable for your benefit
No
Yes. Give specific information about them...
26. Patents, copyrights, trademarks, trade secrets, and other intellectual property
Examples: Internet domain names, websites, proceeds from royalties and licensing agreements
No
27. Licenses, franchises, and other general intangibles

Examples: Building permits, exclusive licenses, cooperative association holdings, liquor licenses, professional licenses
No
Money or property owed to you? Current value of the

portion you own?
28. Tax refunds owed to you

No
Yes. Give specific information about them, including whether you already filed the returns and the tax years.......
Potential tax refund. Federal Unknown
Potential tax refund. State Unknown
Potential earned income tax credit. Unknown
29. Family support

Examples: Past due or lump sum alimony, spousal support, child support, maintenance, divorce settlement, property settlement
No
Yes. Give specific information......
30. Other amounts someone owes you

Examples: Unpaid wages, disability insurance payments, disability benefits, sick pay, vacation pay, workers’ compensation, Social Security
benefits; unpaid loans you made to someone else
No
Yes. Give specific information..
31. Interests in insurance policies

Examples: Health, disability, or life insurance; health savings account (HSA); credit, homeowner’s, or renter’s insurance
No
Yes. Name the insurance company of each policy and list its value.
Company name: Beneficiary: Surrender or refund
value:
Term life with NY AIG Wife Unknown

32. Any interest in property that is due you from someone who has died
If you are the beneficiary of a living trust, expect proceeds from a life insurance policy, or are currently entitled to receive property because
someone has died.
No
33. Claims against third parties, whether or not you have filed a lawsuit or made a demand for payment
Examples: Accidents, employment disputes, insurance claims, or rights to sue
No
Yes. Describe each claim.........
34. Other contingent and unliquidated claims of every nature, including counterclaims of the debtor and rights to set off claims
No
Yes. Describe each claim.........
35. Any financial assets you did not already list

No
36. Add the dollar value of all of your entries from Part 4, including any entries for pages you have attached
for Part 4. Write that number here..................................................................................................................... $709,250.00
Part 5: Describe Any Business-Related Property You Own or Have an Interest In. List any real estate in Part 1.
37. Do you own or have any legal or equitable interest in any business-related property?
No. Go to Part 6.
Yes. Go to line 38.
Part 6: Describe Any Farm- and Commercial Fishing-Related Property You Own or Have an Interest In.
If you own or have an interest in farmland, list it in Part 1.
46. Do you own or have any legal or equitable interest in any farm- or commercial fishing-related property?
No. Go to Part 7.
Yes. Go to line 47.
Part 7: Describe All Property You Own or Have an Interest in That You Did Not List Above
53. Do you have other property of any kind you did not already list?
Examples: Season tickets, country club membership
No
Yes. Give specific information.........
54. Add the dollar value of all of your entries from Part 7. Write that number here .................................... $0.00
Part 8: List the Totals of Each Part of this Form
55. Part 1: Total real estate, line 2 ...................................................................................................................... $575,000.00

56. Part 2: Total vehicles, line 5 $250.00
57. Part 3: Total personal and household items, line 15 $4,600.00
58. Part 4: Total financial assets, line 36 $709,250.00
59. Part 5: Total business-related property, line 45 $0.00
60. Part 6: Total farm- and fishing-related property, line 52 $0.00
61. Part 7: Total other property not listed, line 54 + $0.00
62. Total personal property. Add lines 56 through 61... $714,100.00 Copy personal property total $714,100.00
63. Total of all property on Schedule A/B. Add line 55 + line 62 $1,289,100.00



Debtor 2
Case number
amended filing
Official Form 106C

Schedule C: The Property You Claim as Exempt 4/19
Be as complete and accurate as possible. If two married people are filing together, both are equally responsible for supplying correct information. Using
the property you listed on Schedule A/B: Property (Official Form 106A/B) as your source, list the property that you claim as exempt. If more space is
needed, fill out and attach to this page as many copies of Part 2: Additional Page as necessary. On the top of any additional pages, write your name and
case number (if known).
For each item of property you claim as exempt, you must specify the amount of the exemption you claim. One way of doing so is to state a
specific dollar amount as exempt. Alternatively, you may claim the full fair market value of the property being exempted up to the amount of
any applicable statutory limit. Some exemptions—such as those for health aids, rights to receive certain benefits, and tax-exempt retirement
funds—may be unlimited in dollar amount. However, if you claim an exemption of 100% of fair market value under a law that limits the
exemption to a particular dollar amount and the value of the property is determined to exceed that amount, your exemption would be limited
to the applicable statutory amount.
Part 1: Identify the Property You Claim as Exempt
1. Which set of exemptions are you claiming? Check one only, even if your spouse is filing with you.
You are claiming state and federal nonbankruptcy exemptions. 11 U.S.C. § 522(b)(3)
You are claiming federal exemptions. 11 U.S.C. § 522(b)(2)
2. For any property you list on Schedule A/B that you claim as exempt, fill in the information below.
Brief description of the property and line on Current value of the Amount of the exemption you claim Specific laws that allow exemption
Schedule A/B that lists this property portion you own
Copy the value from Check only one box for each exemption.
Schedule A/B
4247 Crane Boulevard Jackson, MS $575,000.00 $75,000.00 Miss. Code Ann. § 85-3-21
39216 Hinds County Property is in tenancy by
Debtor and wife own as tentants by 100% of fair market value, up to entirety and cannot be
the entirety with full rights of any applicable statutory limit liquidated for debts of one
survivorship. party.
Line from Schedule A/B: 1.1
2004 Honda $250.00 $250.00 Miss. Code Ann. § 85-3-1(a)

4 wheeler that doesn't run.
Line from Schedule A/B: 4.1 100% of fair market value, up to
any applicable statutory limit
1/2 interest in standard household $2,500.00 $2,500.00 Miss. Code Ann. § 85-3-1(a)
goods for 6/4.5 house including
living room, dining room, and 100% of fair market value, up to
bedroom furniture, televisions, and any applicable statutory limit
kitchen appliances, etc.
iPhone $200.00 $200.00 Miss. Code Ann. § 85-3-1(a)

100% of fair market value, up to
Official Form 106C Schedule C: The Property You Claim as Exempt page 1 of 2
Brief description of the property and line on Current value of the Amount of the exemption you claim Specific laws that allow exemption
Schedule A/B that lists this property portion you own
Copy the value from Check only one box for each exemption.
Schedule A/B
Benelli over/under 12 gauge. $750.00 $750.00 Miss. Code Ann. § 85-3-1(a)

Standard clothing $250.00 $250.00 Miss. Code Ann. § 85-3-1(a)

Wedding ring. $250.00 $250.00 Miss. Code Ann. § 85-3-1(a)

Cash $750.00 $750.00 Miss. Code Ann. § 85-3-1(a)

ERISA: 401k wih Mass Mutual $700,000.00 $700,000.00 Miss. Code Ann. § 85-3-1(e)
ERISA: IRA with TD Ameritrde $8,000.00 $8,000.00 Miss. Code Ann. § 85-3-1(e)
Federal: Potential tax refund. Unknown $5,000.00 Miss. Code Ann. § 85-3-1(j)
State: Potential tax refund. Unknown $5,000.00 Miss. Code Ann. § 85-3-1(k)
Potential earned income tax credit. Unknown $5,000.00 Miss. Code Ann. § 85-3-1(i)
3. Are you claiming a homestead exemption of more than $170,350?

(Subject to adjustment on 4/01/22 and every 3 years after that for cases filed on or after the date of adjustment.)
No
Yes. Did you acquire the property covered by the exemption within 1,215 days before you filed this case?
No
Yes
Official Form 106C Schedule C: The Property You Claim as Exempt page 2 of 2

Debtor 2
Case number
amended filing
Official Form 106D

Schedule D: Creditors Who Have Claims Secured by Property 12/15
Be as complete and accurate as possible. If two married people are filing together, both are equally responsible for supplying correct information. If more space
is needed, copy the Additional Page, fill it out, number the entries, and attach it to this form. On the top of any additional pages, write your name and case
number (if known).
1. Do any creditors have claims secured by your property?
No. Check this box and submit this form to the court with your other schedules. You have nothing else to report on this form.
Yes. Fill in all of the information below.
Part 1: List All Secured Claims
Column A Column B Column C
2. List all secured claims. If a creditor has more than one secured claim, list the creditor separately
for each claim. If more than one creditor has a particular claim, list the other creditors in Part 2. As Amount of claim Value of collateral Unsecured
much as possible, list the claims in alphabetical order according to the creditor’s name. Do not deduct the that supports this portion
value of collateral. claim If any
2.1 BancorpSouth Describe the property that secures the claim: $470,000.00 $575,000.00 $0.00
Creditor's Name 4247 Crane Boulevard Jackson, MS
39216 Hinds County
Debtor and wife own as tentants by
the entirety with full rights of
Main Branch survivorship.
As of the date you file, the claim is: Check all that
One Mississippi Plaza apply.
Tupelo, MS 38804 Contingent
Number, Street, City, State & Zip Code Unliquidated
Disputed
Who owes the debt? Check one. Nature of lien. Check all that apply.
Debtor 1 only An agreement you made (such as mortgage or secured
Debtor 2 only car loan)
Debtor 1 and Debtor 2 only Statutory lien (such as tax lien, mechanic's lien)
At least one of the debtors and another Judgment lien from a lawsuit
Check if this claim relates to a Other (including a right to offset)
community debt
Date debt was incurred Last 4 digits of account number
Add the dollar value of your entries in Column A on this page. Write that number here: $470,000.00
If this is the last page of your form, add the dollar value totals from all pages.
Write that number here: $470,000.00
Part 2: List Others to Be Notified for a Debt That You Already Listed
Use this page only if you have others to be notified about your bankruptcy for a debt that you already listed in Part 1. For example, if a collection agency is
trying to collect from you for a debt you owe to someone else, list the creditor in Part 1, and then list the collection agency here. Similarly, if you have more
than one creditor for any of the debts that you listed in Part 1, list the additional creditors here. If you do not have additional persons to be notified for any
debts in Part 1, do not fill out or submit this page.
Official Form 106D Schedule D: Creditors Who Have Claims Secured by Property page 1 of 1

Debtor 2
Case number
amended filing
Official Form 106E/F

Schedule E/F: Creditors Who Have Unsecured Claims 12/15
Be as complete and accurate as possible. Use Part 1 for creditors with PRIORITY claims and Part 2 for creditors with NONPRIORITY claims. List the other party to
any executory contracts or unexpired leases that could result in a claim. Also list executory contracts on Schedule A/B: Property (Official Form 106A/B) and on
Schedule G: Executory Contracts and Unexpired Leases (Official Form 106G). Do not include any creditors with partially secured claims that are listed in
Schedule D: Creditors Who Have Claims Secured by Property. If more space is needed, copy the Part you need, fill it out, number the entries in the boxes on the
left. Attach the Continuation Page to this page. If you have no information to report in a Part, do not file that Part. On the top of any additional pages, write your
name and case number (if known).
Part 1: List All of Your PRIORITY Unsecured Claims
1. Do any creditors have priority unsecured claims against you?
No. Go to Part 2.
Yes.
2. List all of your priority unsecured claims. If a creditor has more than one priority unsecured claim, list the creditor separately for each claim. For each claim listed,
identify what type of claim it is. If a claim has both priority and nonpriority amounts, list that claim here and show both priority and nonpriority amounts. As much as
possible, list the claims in alphabetical order according to the creditor’s name. If you have more than two priority unsecured claims, fill out the Continuation Page of
Part 1. If more than one creditor holds a particular claim, list the other creditors in Part 3.
(For an explanation of each type of claim, see the instructions for this form in the instruction booklet.)
Total claim Priority Nonpriority
amount amount
2.1 IRS Last 4 digits of account number Unknown Unknown Unknown
Priority Creditor's Name
Centralized Insolvency When was the debt incurred?
P. O. Box 7346
Philadelphia, PA 19101-7346
Number Street City State Zip Code As of the date you file, the claim is: Check all that apply
Who incurred the debt? Check one. Contingent
Debtor 1 only Unliquidated
Debtor 2 only Disputed
Debtor 1 and Debtor 2 only Type of PRIORITY unsecured claim:
At least one of the debtors and another Domestic support obligations
Check if this claim is for a community debt Taxes and certain other debts you owe the government
Is the claim subject to offset? Claims for death or personal injury while you were intoxicated
No Other. Specify
Yes
Official Form 106 E/F Schedule E/F: Creditors Who Have Unsecured Claims Page 1 of 21
Software Copyright (c) 1996-2019 Best Case, LLC - www.bestcase.com 32800 Best Case Bankruptcy
2.2 Miss. DOR Last 4 digits of account number $0.00 $0.00 $0.00
Priority Creditor's Name
P. O. Box 22808 When was the debt incurred?
Bankruptcy Section
Jackson, MS 39225
Who incurred the debt? Check one. Contingent
Debtor 2 only Disputed
Debtor 1 and Debtor 2 only Type of PRIORITY unsecured claim:
At least one of the debtors and another Domestic support obligations
Check if this claim is for a community debt Taxes and certain other debts you owe the government
Is the claim subject to offset? Claims for death or personal injury while you were intoxicated
No Other. Specify
Yes
Part 2: List All of Your NONPRIORITY Unsecured Claims

3. Do any creditors have nonpriority unsecured claims against you?
No. You have nothing to report in this part. Submit this form to the court with your other schedules.
Yes.
4. List all of your nonpriority unsecured claims in the alphabetical order of the creditor who holds each claim. If a creditor has more than one nonpriority
unsecured claim, list the creditor separately for each claim. For each claim listed, identify what type of claim it is. Do not list claims already included in Part 1. If more
than one creditor holds a particular claim, list the other creditors in Part 3.If you have more than three nonpriority unsecured claims fill out the Continuation Page of
Part 2.
Total claim
4.1 Alan W. Perry, Esq. Last 4 digits of account number Unknown

Nonpriority Creditor's Name
Attorney at Law When was the debt incurred?
P. O. Box 1789
Jackson, MS 39215-1789
Who incurred the debt? Check one.
Contingent
Debtor 1 only
Debtor 1 and Debtor 2 only Disputed

At least one of the debtors and another Type of NONPRIORITY unsecured claim:
Check if this claim is for a community Student loans

debt Obligations arising out of a separation agreement or divorce that you did not
Is the claim subject to offset? report as priority claims
No Debts to pension or profit-sharing plans, and other similar debts
Yes Other. Specify
4.2 Alysson Mills Receiver Last 4 digits of account number $165,000,000.00

Suite 4600 When was the debt incurred?
201 St. Charles Ave.
New Orleans, LA 70170-4600
Contingent
Debtor 1 only


Suit pending in U. S. District Court,

Southern District of Mississippi, number
Yes Other. Specify 3:18-cv-866-CWR-FKB - Business.
4.3 American Express Last 4 digits of account number $8,658.00

El Paso, TX 79998
Debtor 1 only Contingent


Yes Other. Specify
4.4 Baker Donelson Bearman Last 4 digits of account number Unknown

Scott Pedigo, Agent When was the debt incurred?
100 Vision Dr. # 400
Jackson, MS 39211
Contingent
Debtor 1 only


Yes Other. Specify
4.5 Bank of America Last 4 digits of account number Unknown

Bankruptcy Dept. When was the debt incurred?
P. O. Box 26012
Greensboro, NC 27410


Yes Other. Specify
4.6 Benjamin Graham, Esq. Last 4 digits of account number Unknown

725 Twelfth St., N.W.
Washington, DC 20005-5901
Contingent
Debtor 1 only


Yes Other. Specify
4.7 BMW Financial Services Last 4 digits of account number Unknown

Bankruptcy Depart. When was the debt incurred?
P. O. Box 3608
Dublin, OH 43016


Yes Other. Specify
4.8 Bombay/Prism/Citibank Last 4 digits of account number Unknown

Sioux Falls, SD 57117


Yes Other. Specify
4.9 Bradford Blackmon, Esq Last 4 digits of account number Unknown

P. O. Drawer 105
Canton, MS 39046-0105
Contingent
Debtor 1 only


Yes Other. Specify
4.1
0 Bradley S Clanton, Esq Last 4 digits of account number Unknown
Clanton Law Firm When was the debt incurred?
P. O. Box 4781
Jackson, MS 39296


Yes Other. Specify
4.1
1 Brent Alexander Last 4 digits of account number Unknown
1501 North State St. When was the debt incurred?
Jackson, MS 39202


Yes Other. Specify
4.1
2 Brent Barriere, Esq. Last 4 digits of account number Unknown
Contingent
Debtor 1 only


Yes Other. Specify
4.1
3 Brunini Law Firm Last 4 digits of account number Unknown
Attorneys at Law When was the debt incurred?
P. O. Box 119
Jackson, MS 39205


Yes Other. Specify
4.1
4 Butler Snow Last 4 digits of account number Unknown
P. O. Box 6010
Ridgeland, MS 39158-6010


Yes Other. Specify
4.1
5 Butler Snow Adv. Serv. Last 4 digits of account number Unknown
T. E. Willaims, Agent When was the debt incurred?
1020 Highland Col 1400
Ridgeland, MS 39157
Contingent
Debtor 1 only


Yes Other. Specify
4.1
6 Butler Snow, LLP Last 4 digits of account number Unknown
T. E. Williams Agent When was the debt incurred?
1020 Highland Col 1400
Ridgeland, MS 39157
Contingent
Debtor 1 only


Yes Other. Specify
4.1
7 Capital One Last 4 digits of account number Unknown
P. O. Box 30285
Salt Lake City, UT 84130


Yes Other. Specify
4.1
8 Capital One/Bass Pro Last 4 digits of account number $2,884.00
P. O. Box 30285
Salt Lake City, UT 84130


Yes Other. Specify
4.1
9 Chad J. Hammons, Esq. Last 4 digits of account number Unknown
Jones Walker When was the debt incurred?
P. O. Box 427
Jackson, MS 39205


Yes Other. Specify
4.2
0 Chase Card Services Last 4 digits of account number $23,233.00
P. O. Box 15298
Wilmington, DE 19850


Yes Other. Specify
4.2
1 Citibank Last 4 digits of account number Unknown
SD MC 425 When was the debt incurred?
5800 South Corp Place
Sioux Falls, SD 57108

Type of NONPRIORITY unsecured claim:
At least one of the debtors and another
Yes Other. Specify
4.2
2 Cody Bailey, Esq. Last 4 digits of account number Unknown
P. O. Drawer 119
Contingent
Debtor 1 only


Yes Other. Specify
4.2
3 Craig Singer, Esq. Last 4 digits of account number Unknown
725 Twelfth St., N.W.
Washington, DC 20005-5901
Contingent
Debtor 1 only


Yes Other. Specify
4.2
4 David Kaufman, Esq. Last 4 digits of account number Unknown
P. O. Drawer 119
Contingent
Debtor 1 only


Yes Other. Specify
4.2
5 Dell Financial Service Last 4 digits of account number Unknown
Austin, TX 78708


Yes Other. Specify
4.2
6 Discover Financial Last 4 digits of account number Unknown
P. O. Box 15316
Wilmington, DE 19850


Yes Other. Specify
4.2
7 Edgar H. Carby, Esq. Last 4 digits of account number Unknown
Carby & Carby Attorney When was the debt incurred?
513 State Street
Natchez, MS 39120
Contingent
Debtor 1 only


Yes Other. Specify
4.2
8 Edward Blackmon, Esq. Last 4 digits of account number Unknown
P. O. Box 105
Canton, MS 39046-0105
Contingent
Debtor 1 only


Yes Other. Specify
4.2
9 Equlease, LLC Last 4 digits of account number $775,000.00
Jackson, MS 39236
Contingent
Debtor 1 only


Suit pending in Hinds County Circuit Court,

Yes Other. Specify number 19-cv-00026-WLK - Business.
4.3
0 Ford Motor Credit Last 4 digits of account number Unknown
Bankruptcy Center When was the debt incurred?
P. O. Box 62180
Colorado Springs, CO 80962


Yes Other. Specify
4.3
1 Hyde Carby, Esq. Last 4 digits of account number Unknown
P. O. Box 1047
Natchez, MS 39120


Yes Other. Specify
4.3
2 James Crongeyer Jr Esq Last 4 digits of account number Unknown
P. O. Box 650
Contingent
Debtor 1 only


Yes Other. Specify
4.3
3 Jason Burge, Esq. Last 4 digits of account number Unknown
Contingent
Debtor 1 only


Yes Other. Specify
4.3
4 John A. Purvis, Esq. Last 4 digits of account number Unknown
P. O. Box 1789
Contingent
Debtor 1 only


Yes Other. Specify
4.3
5 Kristen Amond, Esq. Last 4 digits of account number Unknown
Contingent
Debtor 1 only


Yes Other. Specify
4.3
6 LaToya Jeter, Esq. Last 4 digits of account number Unknown
P. O. Box 22969
Jackson, MS 39225
Contingent
Debtor 1 only


Yes Other. Specify
4.3
7 Lilli Bass, Esq. Last 4 digits of account number Unknown
P. O. Box 22969
Jackson, MS 39225
Contingent
Debtor 1 only


Yes Other. Specify
4.3
8 Matt Thornton Last 4 digits of account number Unknown
1020 Highland Colony
Ridgeland, MS 39157
Contingent
Debtor 1 only


Yes Other. Specify
4.3
9 Michael Ulmer, Esq. Last 4 digits of account number Unknown
P. O. Box 650
Contingent
Debtor 1 only


Yes Other. Specify
4.4
0 Michael Williams, Esq. Last 4 digits of account number Unknown
P. O. Box 1789
Contingent
Debtor 1 only


Yes Other. Specify
4.4
1 Navient Last 4 digits of account number $49,948.00
P. O. Box 9640
Wilkes-Barre, PA 18773

Type of NONPRIORITY unsecured claim:
At least one of the debtors and another
Yes Other. Specify
4.4
2 Pemco Financial Corp. Last 4 digits of account number Unknown
Kalamazoo, MI 49019-0357


Yes Other. Specify
4.4
3 PHH Mortgage Services Last 4 digits of account number Unknown
1661 Worthington Rd
West Palm Beach, FL 33409


Yes Other. Specify
4.4
4 PHH Mortgage Servicing Last 4 digits of account number Unknown
P. O. Box 5452
Mount Laurel, NJ 08054


Yes Other. Specify
4.4
5 Rebekka Veith, Esq. Last 4 digits of account number Unknown
Contingent
Debtor 1 only


Yes Other. Specify
4.4
6 Regions Bank Last 4 digits of account number Unknown
P. O. Box 10063
Birmingham, AL 35202


Yes Other. Specify
4.4
7 Regions Mortgage Last 4 digits of account number Unknown
P. O. Box 18001
Hattiesburg, MS 39404


Yes Other. Specify
4.4
8 Simon Bailey, Esq. Last 4 digits of account number Unknown
P. O. Box 1789
Contingent
Debtor 1 only


Yes Other. Specify
4.4
9 Southern Insurance Last 4 digits of account number $32,000.00
591 Northpark Drive When was the debt incurred?
Ridgeland, MS 39157
Contingent
Debtor 1 only


Suit pending in Madison County Court,

Yes Other. Specify number 19-cv-01314 - Business.
4.5
0 Southern States Utily. Last 4 digits of account number Unknown
550 U. S. 49 When was the debt incurred?
Richland, MS 39218


Yes Other. Specify
4.5
1 Synchrony/Brook Bro. Last 4 digits of account number Unknown
P. O. Box 965060
Orlando, FL 32896


Yes Other. Specify
4.5
2 Tower Loan Last 4 digits of account number Unknown
P. O. Box 320001
Flowood, MS 39232


Yes Other. Specify
4.5
3 USAA Fed. Savings Bank Last 4 digits of account number $35,000.00
10750 McDermott Freewy
San Antonio, TX 78288


Yes Other. Specify
4.5
4 Walter Weems, Esq. Last 4 digits of account number Unknown
Brunini, Grantham When was the debt incurred?
P. O. Box 119
Jackson, MS 39205


Yes Other. Specify
4.5
5 Wayne Drinkwater, Esq. Last 4 digits of account number Unknown
P. O. Box 1789
Contingent
Debtor 1 only


Yes Other. Specify
4.5
6 William Busching, Esq. Last 4 digits of account number Unknown
P. O. Box 1510
Gulfport, MS 39502
Contingent
Debtor 1 only


Yes Other. Specify
Part 3: List Others to Be Notified About a Debt That You Already Listed
5. Use this page only if you have others to be notified about your bankruptcy, for a debt that you already listed in Parts 1 or 2. For example, if a collection agency
is trying to collect from you for a debt you owe to someone else, list the original creditor in Parts 1 or 2, then list the collection agency here. Similarly, if you
have more than one creditor for any of the debts that you listed in Parts 1 or 2, list the additional creditors here. If you do not have additional persons to be
notified for any debts in Parts 1 or 2, do not fill out or submit this page.
Name and Address On which entry in Part 1 or Part 2 did you list the original creditor?
PEMCO Insurance Co. Line 4.42 of (Check one): Part 1: Creditors with Priority Unsecured Claims
P. O. Box 778 Part 2: Creditors with Nonpriority Unsecured Claims
Seattle, WA 98111-0778
Last 4 digits of account number
Name and Address On which entry in Part 1 or Part 2 did you list the original creditor?
U S Attorney/IRS Line 2.1 of (Check one): Part 1: Creditors with Priority Unsecured Claims
Suite 4.430 Part 2: Creditors with Nonpriority Unsecured Claims
501 East Court St.
Jackson, MS 39201
Last 4 digits of account number
Part 4: Add the Amounts for Each Type of Unsecured Claim

6. Total the amounts of certain types of unsecured claims. This information is for statistical reporting purposes only. 28 U.S.C. §159. Add the amounts for each
type of unsecured claim.
Total Claim
6a. Domestic support obligations 6a. $ 0.00
Total
claims
from Part 1 6b. Taxes and certain other debts you owe the government 6b. $ 0.00
6c. Claims for death or personal injury while you were intoxicated 6c. $ 0.00
6d. Other. Add all other priority unsecured claims. Write that amount here. 6d. $ 0.00
6e. Total Priority. Add lines 6a through 6d. 6e. $ 0.00
Total Claim
6f. Student loans 6f. $ 49,948.00
Total
claims
from Part 2 6g. Obligations arising out of a separation agreement or divorce that
you did not report as priority claims 6g. $ 0.00
6h. Debts to pension or profit-sharing plans, and other similar debts 6h. $ 0.00
6i. Other. Add all other nonpriority unsecured claims. Write that amount 6i.
here. $ 165,876,775.00
6j. Total Nonpriority. Add lines 6f through 6i. 6j. $ 165,926,723.00

Debtor 2
Case number
amended filing
Official Form 106G

Schedule G: Executory Contracts and Unexpired Leases 12/15
information. If more space is needed, copy the additional page, fill it out, number the entries, and attach it to this page. On the top of any
additional pages, write your name and case number (if known).
1. Do you have any executory contracts or unexpired leases?

No. Check this box and file this form with the court with your other schedules. You have nothing else to report on this form.
Yes. Fill in all of the information below even if the contacts of leases are listed on Schedule A/B:Property (Official Form 106 A/B).
2. List separately each person or company with whom you have the contract or lease. Then state what each contract or lease is for (for
example, rent, vehicle lease, cell phone). See the instructions for this form in the instruction booklet for more examples of executory contracts
and unexpired leases.
Person or company with whom you have the contract or lease State what the contract or lease is for
Name, Number, Street, City, State and ZIP Code
2.1
Name
Number Street
City State ZIP Code

2.2
Name
Number Street
City State ZIP Code

2.3
Name
Number Street
City State ZIP Code

2.4
Name
Number Street
City State ZIP Code

2.5
Name
Number Street
City State ZIP Code
Official Form 106G Schedule G: Executory Contracts and Unexpired Leases Page 1 of 1

Debtor 2
Case number
amended filing
Official Form 106H

Schedule H: Your Codebtors 12/15
Codebtors are people or entities who are also liable for any debts you may have. Be as complete and accurate as possible. If two married
people are filing together, both are equally responsible for supplying correct information. If more space is needed, copy the Additional Page,
fill it out, and number the entries in the boxes on the left. Attach the Additional Page to this page. On the top of any Additional Pages, write
your name and case number (if known). Answer every question.
1. Do you have any codebtors? (If you are filing a joint case, do not list either spouse as a codebtor.
No
Yes
2. Within the last 8 years, have you lived in a community property state or territory? (Community property states and territories include
Arizona, California, Idaho, Louisiana, Nevada, New Mexico, Puerto Rico, Texas, Washington, and Wisconsin.)
No. Go to line 3.
Yes. Did your spouse, former spouse, or legal equivalent live with you at the time?
3. In Column 1, list all of your codebtors. Do not include your spouse as a codebtor if your spouse is filing with you. List the person shown
in line 2 again as a codebtor only if that person is a guarantor or cosigner. Make sure you have listed the creditor on Schedule D (Official
Form 106D), Schedule E/F (Official Form 106E/F), or Schedule G (Official Form 106G). Use Schedule D, Schedule E/F, or Schedule G to fill
out Column 2.
Column 1: Your codebtor Column 2: The creditor to whom you owe the debt
Name, Number, Street, City, State and ZIP Code Check all schedules that apply:
3.1 Ashley Seawright Schedule D, line 2.1

4247 Crane Blvd. Schedule E/F, line
Jackson, MS 39216
Schedule G
BancorpSouth
Official Form 106H Schedule H: Your Codebtors Page 1 of 1

Debtor 2
(Spouse, if filing)
Case number Check if this is:

(If known)
An amended filing
A supplement showing postpetition chapter
13 income as of the following date:
Official Form 106I MM / DD/ YYYY

Schedule I: Your Income 12/15
Be as complete and accurate as possible. If two married people are filing together (Debtor 1 and Debtor 2), both are equally responsible for
supplying correct information. If you are married and not filing jointly, and your spouse is living with you, include information about your
spouse. If you are separated and your spouse is not filing with you, do not include information about your spouse. If more space is needed,
attach a separate sheet to this form. On the top of any additional pages, write your name and case number (if known). Answer every question.
Part 1: Describe Employment
1. Fill in your employment

information. Debtor 1 Debtor 2 or non-filing spouse
If you have more than one job, Employed Employed

attach a separate page with Employment status
information about additional Not employed Not employed
employers.
Occupation Attorney Nurse Practitioner
Include part-time, seasonal, or
self-employed work. Employer's name Baker Donelson Bearman UMMC
Occupation may include student Employer's address

100 Vision Dr. # 400 P.O. Box 23246
or homemaker, if it applies.
Jackson, MS 39211 Jackson, MS 39225
How long employed there?
Part 2: Give Details About Monthly Income
Estimate monthly income as of the date you file this form. If you have nothing to report for any line, write $0 in the space. Include your non-filing
spouse unless you are separated.
If you or your non-filing spouse have more than one employer, combine the information for all employers for that person on the lines below. If you need
more space, attach a separate sheet to this form.
For Debtor 1 For Debtor 2 or

non-filing spouse
List monthly gross wages, salary, and commissions (before all payroll
2. deductions). If not paid monthly, calculate what the monthly wage would be. 2. $ 23,641.48 $ 9,750.00
3. Estimate and list monthly overtime pay. 3. +$ 0.00 +$ 0.00
4. Calculate gross Income. Add line 2 + line 3. 4. $ 23,641.48 $ 9,750.00
Official Form 106I Schedule I: Your Income page 1

For Debtor 1 For Debtor 2 or

non-filing spouse
Copy line 4 here 4. $ 23,641.48 $ 9,750.00
5. List all payroll deductions:

5a. Tax, Medicare, and Social Security deductions 5a. $ 6,035.36 $ 4,375.00
5b. Mandatory contributions for retirement plans 5b. $ 1,000.00 $ 0.00
5c. Voluntary contributions for retirement plans 5c. $ 0.00 $ 0.00
5d. Required repayments of retirement fund loans 5d. $ 0.00 $ 0.00
5e. Insurance 5e. $ 488.16 $ 0.00
5f. Domestic support obligations 5f. $ 0.00 $ 0.00
5g. Union dues 5g. $ 0.00 $ 0.00
5h. Other deductions. Specify: Term life, medical, etc. 5h.+ $ 750.60 + $ 0.00
6. Add the payroll deductions. Add lines 5a+5b+5c+5d+5e+5f+5g+5h. 6. $ 8,274.12 $ 4,375.00
7. Calculate total monthly take-home pay. Subtract line 6 from line 4. 7. $ 15,367.36 $ 5,375.00
8. List all other income regularly received:
8a. Net income from rental property and from operating a business,
profession, or farm
Attach a statement for each property and business showing gross
receipts, ordinary and necessary business expenses, and the total
monthly net income. 8a. $ 0.00 $ 0.00
8b. Interest and dividends 8b. $ 0.00 $ 0.00
8c. Family support payments that you, a non-filing spouse, or a dependent
regularly receive
Include alimony, spousal support, child support, maintenance, divorce
settlement, and property settlement. 8c. $ 0.00 $ 0.00
8d. Unemployment compensation 8d. $ 0.00 $ 0.00
8e. Social Security 8e. $ 0.00 $ 0.00
8f. Other government assistance that you regularly receive
Include cash assistance and the value (if known) of any non-cash assistance
that you receive, such as food stamps (benefits under the Supplemental
Nutrition Assistance Program) or housing subsidies.
Specify: 8f. $ 0.00 $ 0.00
8g. Pension or retirement income 8g. $ 0.00 $ 0.00
8h. Other monthly income. Specify: 8h.+ $ 0.00 + $ 0.00
9. Add all other income. Add lines 8a+8b+8c+8d+8e+8f+8g+8h. 9. $ 0.00 $ 0.00
10. Calculate monthly income. Add line 7 + line 9. 10. $ 15,367.36 + $ 5,375.00 = $ 20,742.36
Add the entries in line 10 for Debtor 1 and Debtor 2 or non-filing spouse.
11. State all other regular contributions to the expenses that you list in Schedule J.
Include contributions from an unmarried partner, members of your household, your dependents, your roommates, and
other friends or relatives.
Do not include any amounts already included in lines 2-10 or amounts that are not available to pay expenses listed in Schedule J.
Specify: 11. +$ 0.00
12. Add the amount in the last column of line 10 to the amount in line 11. The result is the combined monthly income.
Write that amount on the Summary of Schedules and Statistical Summary of Certain Liabilities and Related Data, if it
applies 12. $ 20,742.36
Combined
monthly income
13. Do you expect an increase or decrease within the year after you file this form?
No.
Yes. Explain:
Official Form 106I Schedule I: Your Income page 2

Debtor 1 Jon Darrell Seawright Check if this is:

An amended filing
Debtor 2 A supplement showing postpetition chapter
(Spouse, if filing) 13 expenses as of the following date:
United States Bankruptcy Court for the: SOUTHERN DISTRICT OF MISSISSIPPI MM / DD / YYYY
Case number
(If known)
Official Form 106J

Schedule J: Your Expenses 12/15
information. If more space is needed, attach another sheet to this form. On the top of any additional pages, write your name and case
number (if known). Answer every question.
Part 1: Describe Your Household

1. Is this a joint case?
No. Go to line 2.
Yes. Does Debtor 2 live in a separate household?
No
Yes. Debtor 2 must file Official Form 106J-2, Expenses for Separate Household of Debtor 2.
2. Do you have dependents? No

Do not list Debtor 1 and Yes.
Fill out this information for Dependent’s relationship to Dependent’s Does dependent
Debtor 2. each dependent.............. Debtor 1 or Debtor 2 age live with you?
Do not state the No

dependents names. Wife Yes
No
Son 13 Yes
No
Daughter 16 Yes
No
Yes
3. Do your expenses include No
expenses of people other than
yourself and your dependents? Yes
Part 2: Estimate Your Ongoing Monthly Expenses

Estimate your expenses as of your bankruptcy filing date unless you are using this form as a supplement in a Chapter 13 case to report
expenses as of a date after the bankruptcy is filed. If this is a supplemental Schedule J, check the box at the top of the form and fill in the
applicable date.
Include expenses paid for with non-cash government assistance if you know
the value of such assistance and have included it on Schedule I: Your Income
(Official Form 106I.) Your expenses
4. The rental or home ownership expenses for your residence. Include first mortgage
payments and any rent for the ground or lot. 4. $ 4,045.37
If not included in line 4:
4a. Real estate taxes 4a. $ 341.67

4b. Property, homeowner’s, or renter’s insurance 4b. $ 350.00
4c. Home maintenance, repair, and upkeep expenses 4c. $ 1,200.00
4d. Homeowner’s association or condominium dues 4d. $ 0.00
5. Additional mortgage payments for your residence, such as home equity loans 5. $ 550.00
Official Form 106J Schedule J: Your Expenses page 1

6. Utilities:
6a. Electricity, heat, natural gas 6a. $ 450.00
6b. Water, sewer, garbage collection 6b. $ 200.00
6c. Telephone, cell phone, Internet, satellite, and cable services 6c. $ 400.00
6d. Other. Specify: 6d. $ 0.00
7. Food and housekeeping supplies 7. $ 1,250.00
8. Childcare and children’s education costs 8. $ 3,750.00
9. Clothing, laundry, and dry cleaning 9. $ 500.00
10. Personal care products and services 10. $ 150.00
11. Medical and dental expenses 11. $ 400.00
12. Transportation. Include gas, maintenance, bus or train fare.
Do not include car payments. 12. $ 750.00
13. Entertainment, clubs, recreation, newspapers, magazines, and books 13. $ 250.00
14. Charitable contributions and religious donations 14. $ 0.00
15. Insurance.
Do not include insurance deducted from your pay or included in lines 4 or 20.
15a. Life insurance 15a. $ 300.00
15b. Health insurance 15b. $ 0.00
15c. Vehicle insurance 15c. $ 300.00
15d. Other insurance. Specify: 15d. $ 0.00
16. Taxes. Do not include taxes deducted from your pay or included in lines 4 or 20.
Specify: Additional tax payment for under withholding 16. $ 1,000.00
17. Installment or lease payments:
17a. Car payments for Vehicle 1 17a. $ 400.00
17b. Car payments for Vehicle 2 17b. $ 0.00
17c. Other. Specify: Wife's credit cards 17c. $ 1,500.00
17d. Other. Specify: 17d. $ 0.00
18. Your payments of alimony, maintenance, and support that you did not report as
deducted from your pay on line 5, Schedule I, Your Income (Official Form 106I). 18. $ 0.00
19. Other payments you make to support others who do not live with you. $ 0.00
Specify: 19.
20. Other real property expenses not included in lines 4 or 5 of this form or on Schedule I: Your Income.
20a. Mortgages on other property 20a. $ 0.00
20b. Real estate taxes 20b. $ 0.00
20c. Property, homeowner’s, or renter’s insurance 20c. $ 0.00
20d. Maintenance, repair, and upkeep expenses 20d. $ 0.00
20e. Homeowner’s association or condominium dues 20e. $ 0.00
21. Other: Specify: Ongoing legal fees 21. +$ 2,500.00
22. Calculate your monthly expenses
22a. Add lines 4 through 21. $ 20,587.04
22b. Copy line 22 (monthly expenses for Debtor 2), if any, from Official Form 106J-2 $
22c. Add line 22a and 22b. The result is your monthly expenses. $ 20,587.04
23. Calculate your monthly net income.
23a. Copy line 12 (your combined monthly income) from Schedule I. 23a. $ 20,742.36
23b. Copy your monthly expenses from line 22c above. 23b. -$ 20,587.04
23c. Subtract your monthly expenses from your monthly income.

The result is your monthly net income. 23c. $ 155.32
24. Do you expect an increase or decrease in your expenses within the year after you file this form?
For example, do you expect to finish paying for your car loan within the year or do you expect your mortgage payment to increase or decrease because of a
modification to the terms of your mortgage?
No.
Yes. Explain here:
Official Form 106J Schedule J: Your Expenses page 2


Debtor 2
Case number
amended filing
Official Form 106Dec

Declaration About an Individual Debtor's Schedules 12/15
If two married people are filing together, both are equally responsible for supplying correct information.
You must file this form whenever you file bankruptcy schedules or amended schedules. Making a false statement, concealing property, or
obtaining money or property by fraud in connection with a bankruptcy case can result in fines up to $250,000, or imprisonment for up to 20
years, or both. 18 U.S.C. §§ 152, 1341, 1519, and 3571.
Sign Below
Did you pay or agree to pay someone who is NOT an attorney to help you fill out bankruptcy forms?
No
Yes. Name of person Attach Bankruptcy Petition Preparer’s Notice,

Declaration, and Signature (Official Form 119)
Under penalty of perjury, I declare that I have read the summary and schedules filed with this declaration and
that they are true and correct.
X /s/ Jon Darrell Seawright X

Date November 3, 2019 Date
Official Form 106Dec Declaration About an Individual Debtor's Schedules


Debtor 2
Case number
amended filing
Official Form 107

Statement of Financial Affairs for Individuals Filing for Bankruptcy 4/19
information. If more space is needed, attach a separate sheet to this form. On the top of any additional pages, write your name and case
number (if known). Answer every question.
Part 1: Give Details About Your Marital Status and Where You Lived Before
1. What is your current marital status?
Married
Not married
2. During the last 3 years, have you lived anywhere other than where you live now?
No
Yes. List all of the places you lived in the last 3 years. Do not include where you live now.
Debtor 1 Prior Address: Dates Debtor 1 Debtor 2 Prior Address: Dates Debtor 2
lived there lived there
3. Within the last 8 years, did you ever live with a spouse or legal equivalent in a community property state or territory? (Community property
states and territories include Arizona, California, Idaho, Louisiana, Nevada, New Mexico, Puerto Rico, Texas, Washington and Wisconsin.)
No
Yes. Make sure you fill out Schedule H: Your Codebtors (Official Form 106H).
Part 2 Explain the Sources of Your Income
4. Did you have any income from employment or from operating a business during this year or the two previous calendar years?
Fill in the total amount of income you received from all jobs and all businesses, including part-time activities.
If you are filing a joint case and you have income that you receive together, list it only once under Debtor 1.
No
Yes. Fill in the details.
Debtor 1 Debtor 2
Sources of income Gross income Sources of income Gross income
Check all that apply. (before deductions and Check all that apply. (before deductions
exclusions) and exclusions)
From January 1 of current year until Wages, commissions, $297,982.51 Wages, commissions,
the date you filed for bankruptcy: bonuses, tips
bonuses, tips
Operating a business Operating a business
Official Form 107 Statement of Financial Affairs for Individuals Filing for Bankruptcy page 1
Debtor 1 Debtor 2
Sources of income Gross income Sources of income Gross income
Check all that apply. (before deductions and Check all that apply. (before deductions
exclusions) and exclusions)
For last calendar year: Wages, commissions, $372,683.34 Wages, commissions,

(January 1 to December 31, 2018 ) bonuses, tips
bonuses, tips
For the calendar year before that: Wages, commissions, $336,737.26 Wages, commissions,
(January 1 to December 31, 2017 ) bonuses, tips
bonuses, tips
5. Did you receive any other income during this year or the two previous calendar years?
Include income regardless of whether that income is taxable. Examples of other income are alimony; child support; Social Security, unemployment,
and other public benefit payments; pensions; rental income; interest; dividends; money collected from lawsuits; royalties; and gambling and lottery
winnings. If you are filing a joint case and you have income that you received together, list it only once under Debtor 1.
List each source and the gross income from each source separately. Do not include income that you listed in line 4.
No
Debtor 1 Debtor 2
Sources of income Gross income from Sources of income Gross income
Describe below. each source Describe below. (before deductions
(before deductions and and exclusions)
exclusions)
Part 3: List Certain Payments You Made Before You Filed for Bankruptcy
6. Are either Debtor 1’s or Debtor 2’s debts primarily consumer debts?
No. Neither Debtor 1 nor Debtor 2 has primarily consumer debts. Consumer debts are defined in 11 U.S.C. § 101(8) as “incurred by an
individual primarily for a personal, family, or household purpose.”
During the 90 days before you filed for bankruptcy, did you pay any creditor a total of $6,825* or more?
No. Go to line 7.
Yes List below each creditor to whom you paid a total of $6,825* or more in one or more payments and the total amount you
paid that creditor. Do not include payments for domestic support obligations, such as child support and alimony. Also, do
not include payments to an attorney for this bankruptcy case.
* Subject to adjustment on 4/01/22 and every 3 years after that for cases filed on or after the date of adjustment.
Yes. Debtor 1 or Debtor 2 or both have primarily consumer debts.

During the 90 days before you filed for bankruptcy, did you pay any creditor a total of $600 or more?
No. Go to line 7.
Yes List below each creditor to whom you paid a total of $600 or more and the total amount you paid that creditor. Do not
include payments for domestic support obligations, such as child support and alimony. Also, do not include payments to an
attorney for this bankruptcy case.
Creditor's Name and Address Dates of payment Total amount Amount you Was this payment for ...
paid still owe
None, except ordinary $0.00 $0.00 Mortgage
course of business Car
See Schedule J Credit Card
Loan Repayment
Suppliers or vendors
Other
7. Within 1 year before you filed for bankruptcy, did you make a payment on a debt you owed anyone who was an insider?
Insiders include your relatives; any general partners; relatives of any general partners; partnerships of which you are a general partner; corporations
of which you are an officer, director, person in control, or owner of 20% or more of their voting securities; and any managing agent, including one for
a business you operate as a sole proprietor. 11 U.S.C. § 101. Include payments for domestic support obligations, such as child support and
alimony.
No
Yes. List all payments to an insider.
Insider's Name and Address Dates of payment Total amount Amount you Reason for this payment
paid still owe
8. Within 1 year before you filed for bankruptcy, did you make any payments or transfer any property on account of a debt that benefited an
insider?
Include payments on debts guaranteed or cosigned by an insider.
No
Yes. List all payments to an insider
Insider's Name and Address Dates of payment Total amount Amount you Reason for this payment
paid still owe Include creditor's name
Part 4: Identify Legal Actions, Repossessions, and Foreclosures
9. Within 1 year before you filed for bankruptcy, were you a party in any lawsuit, court action, or administrative proceeding?
List all such matters, including personal injury cases, small claims actions, divorces, collection suits, paternity actions, support or custody
modifications, and contract disputes.
No
Case title Nature of the case Court or agency Status of the case
Case number
Alysson Mills Receiver vs. Jon Civil U. S. District Court Pending
Darrell Seawright S. D. Mississippi On appeal
18-cv-866-CWR-FKB 501 E Court St # 2.500
Concluded
Jackson, MS 39201
Southern Insurance vs. Jon Darrell Civil Madison County Court Pending
Seawright P. O. Box 1626 On appeal
19-cv-01314 128 West North Street
Concluded
Canton, MS 39046
Equlease, LLC vs. Jon Darrell Civil Hinds Circuit Court Pending
Seawright P. O. Box 327 On appeal
19-cv-00026-WLK Jackson, MS 39205
Concluded
10. Within 1 year before you filed for bankruptcy, was any of your property repossessed, foreclosed, garnished, attached, seized, or levied?
Check all that apply and fill in the details below.
No. Go to line 11.

Yes. Fill in the information below.
Creditor Name and Address Describe the Property Date Value of the
property
Explain what happened
11. Within 90 days before you filed for bankruptcy, did any creditor, including a bank or financial institution, set off any amounts from your
accounts or refuse to make a payment because you owed a debt?
No
Creditor Name and Address Describe the action the creditor took Date action was Amount
taken
12. Within 1 year before you filed for bankruptcy, was any of your property in the possession of an assignee for the benefit of creditors, a
court-appointed receiver, a custodian, or another official?
No
Yes
Part 5: List Certain Gifts and Contributions
13. Within 2 years before you filed for bankruptcy, did you give any gifts with a total value of more than $600 per person?
No
Yes. Fill in the details for each gift.
Gifts with a total value of more than $600 Describe the gifts Dates you gave Value
per person the gifts
Person to Whom You Gave the Gift and

Address:
14. Within 2 years before you filed for bankruptcy, did you give any gifts or contributions with a total value of more than $600 to any charity?
No
Yes. Fill in the details for each gift or contribution.
Gifts or contributions to charities that total Describe what you contributed Dates you Value
more than $600 contributed
Charity's Name
Address (Number, Street, City, State and ZIP Code)
Part 6: List Certain Losses
15. Within 1 year before you filed for bankruptcy or since you filed for bankruptcy, did you lose anything because of theft, fire, other disaster,
or gambling?
No
Describe the property you lost and Describe any insurance coverage for the loss Date of your Value of property
how the loss occurred loss lost
Include the amount that insurance has paid. List pending
insurance claims on line 33 of Schedule A/B: Property.
Part 7: List Certain Payments or Transfers
16. Within 1 year before you filed for bankruptcy, did you or anyone else acting on your behalf pay or transfer any property to anyone you
consulted about seeking bankruptcy or preparing a bankruptcy petition?
Include any attorneys, bankruptcy petition preparers, or credit counseling agencies for services required in your bankruptcy.
No
Person Who Was Paid Description and value of any property Date payment Amount of
Address transferred or transfer was payment
Email or website address made
Person Who Made the Payment, if Not You
Hood & Bolen, PLLC $2,500.00 that includes filing fee and November 1, $2,500.00
3770 Hwy. 80 West educational courses.. 2019.
Jackson, MS 39209
hoodbolen.com
17. Within 1 year before you filed for bankruptcy, did you or anyone else acting on your behalf pay or transfer any property to anyone who
promised to help you deal with your creditors or to make payments to your creditors?
Do not include any payment or transfer that you listed on line 16.
No
Person Who Was Paid Description and value of any property Date payment Amount of
Address transferred or transfer was payment
made
18. Within 2 years before you filed for bankruptcy, did you sell, trade, or otherwise transfer any property to anyone, other than property
transferred in the ordinary course of your business or financial affairs?
Include both outright transfers and transfers made as security (such as the granting of a security interest or mortgage on your property). Do not
include gifts and transfers that you have already listed on this statement.
No
Person Who Received Transfer Description and value of Describe any property or Date transfer was
Address property transferred payments received or debts made
paid in exchange
Person's relationship to you
19. Within 10 years before you filed for bankruptcy, did you transfer any property to a self-settled trust or similar device of which you are a
beneficiary? (These are often called asset-protection devices.)
No
Name of trust Description and value of the property transferred Date Transfer was
made
Part 8: List of Certain Financial Accounts, Instruments, Safe Deposit Boxes, and Storage Units
20. Within 1 year before you filed for bankruptcy, were any financial accounts or instruments held in your name, or for your benefit, closed,
sold, moved, or transferred?
Include checking, savings, money market, or other financial accounts; certificates of deposit; shares in banks, credit unions, brokerage
houses, pension funds, cooperatives, associations, and other financial institutions.
No
Name of Financial Institution and Last 4 digits of Type of account or Date account was Last balance
Address (Number, Street, City, State and ZIP account number instrument closed, sold, before closing or
Code) moved, or transfer
transferred
21. Do you now have, or did you have within 1 year before you filed for bankruptcy, any safe deposit box or other depository for securities,
cash, or other valuables?
No
Name of Financial Institution Who else had access to it? Describe the contents Do you still
Address (Number, Street, City, State and ZIP Code) Address (Number, Street, City, have it?
State and ZIP Code)
22. Have you stored property in a storage unit or place other than your home within 1 year before you filed for bankruptcy?
No
Name of Storage Facility Who else has or had access Describe the contents Do you still
Address (Number, Street, City, State and ZIP Code) to it? have it?
Address (Number, Street, City,
State and ZIP Code)
Part 9: Identify Property You Hold or Control for Someone Else
23. Do you hold or control any property that someone else owns? Include any property you borrowed from, are storing for, or hold in trust
for someone.
No
Owner's Name Where is the property? Describe the property Value
Address (Number, Street, City, State and ZIP Code) (Number, Street, City, State and ZIP
Code)
Part 10: Give Details About Environmental Information
For the purpose of Part 10, the following definitions apply:
Environmental law means any federal, state, or local statute or regulation concerning pollution, contamination, releases of hazardous or
toxic substances, wastes, or material into the air, land, soil, surface water, groundwater, or other medium, including statutes or
regulations controlling the cleanup of these substances, wastes, or material.
Site means any location, facility, or property as defined under any environmental law, whether you now own, operate, or utilize it or used
to own, operate, or utilize it, including disposal sites.
Hazardous material means anything an environmental law defines as a hazardous waste, hazardous substance, toxic substance,
hazardous material, pollutant, contaminant, or similar term.
Report all notices, releases, and proceedings that you know about, regardless of when they occurred.
24. Has any governmental unit notified you that you may be liable or potentially liable under or in violation of an environmental law?
No
Name of site Governmental unit Environmental law, if you Date of notice
Address (Number, Street, City, State and ZIP Code) Address (Number, Street, City, State and know it
ZIP Code)
25. Have you notified any governmental unit of any release of hazardous material?
No
Name of site Governmental unit Environmental law, if you Date of notice
Address (Number, Street, City, State and ZIP Code) Address (Number, Street, City, State and know it
ZIP Code)
26. Have you been a party in any judicial or administrative proceeding under any environmental law? Include settlements and orders.
No
Case Title Court or agency Nature of the case Status of the
Case Number Name case
Address (Number, Street, City,
State and ZIP Code)
Part 11: Give Details About Your Business or Connections to Any Business
27. Within 4 years before you filed for bankruptcy, did you own a business or have any of the following connections to any business?
A sole proprietor or self-employed in a trade, profession, or other activity, either full-time or part-time
A member of a limited liability company (LLC) or limited liability partnership (LLP)
A partner in a partnership
An officer, director, or managing executive of a corporation
An owner of at least 5% of the voting or equity securities of a corporation
No. None of the above applies. Go to Part 12.
Yes. Check all that apply above and fill in the details below for each business.
Business Name Describe the nature of the business Employer Identification number
Address Do not include Social Security number or ITIN.
(Number, Street, City, State and ZIP Code) Name of accountant or bookkeeper
Dates business existed
Alexander Seawright Multiple businesses - see EIN:
Suite 400 Schedule A/B # 19.
100 Vision Drive From-To
Jackson, MS 39211
28. Within 2 years before you filed for bankruptcy, did you give a financial statement to anyone about your business? Include all financial
institutions, creditors, or other parties.
No
Yes. Fill in the details below.
Name Date Issued
Address
(Number, Street, City, State and ZIP Code)
Part 12: Sign Below
I have read the answers on this Statement of Financial Affairs and any attachments, and I declare under penalty of perjury that the answers
are true and correct. I understand that making a false statement, concealing property, or obtaining money or property by fraud in connection
with a bankruptcy case can result in fines up to $250,000, or imprisonment for up to 20 years, or both.
18 U.S.C. §§ 152, 1341, 1519, and 3571.
/s/ Jon Darrell Seawright

Did you attach additional pages to Your Statement of Financial Affairs for Individuals Filing for Bankruptcy (Official Form 107)?
No
Yes
Did you pay or agree to pay someone who is not an attorney to help you fill out bankruptcy forms?
No
Yes. Name of Person . Attach the Bankruptcy Petition Preparer's Notice, Declaration, and Signature (Official Form 119).

Debtor 2
Case number
amended filing
Official Form 108

Statement of Intention for Individuals Filing Under Chapter 7 12/15
If you are an individual filing under chapter 7, you must fill out this form if:
creditors have claims secured by your property, or
you have leased personal property and the lease has not expired.
You must file this form with the court within 30 days after you file your bankruptcy petition or by the date set for the meeting of creditors,
whichever is earlier, unless the court extends the time for cause. You must also send copies to the creditors and lessors you list
on the form
If two married people are filing together in a joint case, both are equally responsible for supplying correct information. Both debtors must
sign and date the form.
Be as complete and accurate as possible. If more space is needed, attach a separate sheet to this form. On the top of any additional pages,
write your name and case number (if known).
Part 1: List Your Creditors Who Have Secured Claims
1. For any creditors that you listed in Part 1 of Schedule D: Creditors Who Have Claims Secured by Property (Official Form 106D), fill in the
information below.
Identify the creditor and the property that is collateral What do you intend to do with the property that Did you claim the property
secures a debt? as exempt on Schedule C?
Creditor's BancorpSouth Surrender the property. No

name: Retain the property and redeem it.
Retain the property and enter into a Yes
Description of 4247 Crane Boulevard Jackson, Reaffirmation Agreement.
property MS 39216 Hinds County Retain the property and [explain]:
securing debt: Debtor and wife own as
tentants by the entirety with full
rights of survivorship.
Part 2: List Your Unexpired Personal Property Leases

For any unexpired personal property lease that you listed in Schedule G: Executory Contracts and Unexpired Leases (Official Form 106G), fill
in the information below. Do not list real estate leases. Unexpired leases are leases that are still in effect; the lease period has not yet ended.
You may assume an unexpired personal property lease if the trustee does not assume it. 11 U.S.C. § 365(p)(2).
Describe your unexpired personal property leases Will the lease be assumed?
Lessor's name: No
Description of leased
Property: Yes
Lessor's name: No
Property: Yes
Official Form 108 Statement of Intention for Individuals Filing Under Chapter 7 page 1
Lessor's name: No
Property: Yes
Lessor's name: No
Property: Yes
Lessor's name: No
Property: Yes
Lessor's name: No
Property: Yes
Lessor's name: No
Property: Yes
Part 3: Sign Below
Under penalty of perjury, I declare that I have indicated my intention about any property of my estate that secures a debt and any personal
property that is subject to an unexpired lease.
X /s/ Jon Darrell Seawright X

Official Form 108 Statement of Intention for Individuals Filing Under Chapter 7 page 2
Fill in this information to identify your case: Check one box only as directed in this form and in Form
122A-1Supp:
Debtor 2 1. There is no presumption of abuse
(Spouse, if filing)
United States Bankruptcy Court for the: Southern District of Mississippi 2. The calculation to determine if a presumption of abuse
applies will be made under Chapter 7 Means Test
Calculation (Official Form 122A-2).
Case number
(if known)
3. The Means Test does not apply now because of
qualified military service but it could apply later.
Check if this is an amended filing
Official Form 122A - 1
Chapter 7 Statement of Your Current Monthly Income 10/19
Be as complete and accurate as possible. If two married people are filing together, both are equally responsible for being accurate. If more space is needed,
attach a separate sheet to this form. Include the line number to which the additional information applies. On the top of any additional pages, write your name and
case number (if known). If you believe that you are exempted from a presumption of abuse because you do not have primarily consumer debts or because of
qualifying military service, complete and file Statement of Exemption from Presumption of Abuse Under § 707(b)(2) (Official Form 122A-1Supp) with this form.
Part 1: Calculate Your Current Monthly Income
1. What is your marital and filing status? Check one only.

Not married. Fill out Column A, lines 2-11.
Married and your spouse is filing with you. Fill out both Columns A and B, lines 2-11.
Married and your spouse is NOT filing with you. You and your spouse are:
Living in the same household and are not legally separated. Fill out both Columns A and B, lines 2-11.
Living separately or are legally separated. Fill out Column A, lines 2-11; do not fill out Column B. By checking this box, you declare under
penalty of perjury that you and your spouse are legally separated under nonbankruptcy law that applies or that you and your spouse are
living apart for reasons that do not include evading the Means Test requirements. 11 U.S.C § 707(b)(7)(B).
Fill in the average monthly income that you received from all sources, derived during the 6 full months before you file this bankruptcy case. 11 U.S.C. §
101(10A). For example, if you are filing on September 15, the 6-month period would be March 1 through August 31. If the amount of your monthly income varied during
the 6 months, add the income for all 6 months and divide the total by 6. Fill in the result. Do not include any income amount more than once. For example, if both
spouses own the same rental property, put the income from that property in one column only. If you have nothing to report for any line, write $0 in the space.
Column A Column B
Debtor 1 Debtor 2 or
non-filing spouse
2. Your gross wages, salary, tips, bonuses, overtime, and commissions (before all
payroll deductions). $ $
3. Alimony and maintenance payments. Do not include payments from a spouse if
Column B is filled in. $ $
4. All amounts from any source which are regularly paid for household expenses
of you or your dependents, including child support. Include regular contributions
from an unmarried partner, members of your household, your dependents, parents,
and roommates. Include regular contributions from a spouse only if Column B is not
filled in. Do not include payments you listed on line 3. $ $
5. Net income from operating a business, profession, or farm
Debtor 1
Gross receipts (before all deductions) $
Ordinary and necessary operating expenses -$
Net monthly income from a business, profession, or farm $ Copy here -> $ $
6. Net income from rental and other real property
Debtor 1
Net monthly income from rental or other real property $ Copy here -> $ $
$ $
7. Interest, dividends, and royalties
Official Form 122A-1 Chapter 7 Statement of Your Current Monthly Income page 1
Column A Column B
non-filing spouse
8. Unemployment compensation $ $
Do not enter the amount if you contend that the amount received was a benefit under
the Social Security Act. Instead, list it here:
For you $
For your spouse $
9. Pension or retirement income. Do not include any amount received that was a
benefit under the Social Security Act. Also, except as stated in the next sentence, do
not include any compensation, pension, pay, annuity, or allowance paid by the
United States Government in connection with a disability, combat-related injury or
disability, or death of a member of the uniformed services. If you received any retired
pay paid under chapter 61 of title 10, then include that pay only to the extent that it
does not exceed the amount of retired pay to which you would otherwise be entitled
if retired under any provision of title 10 other than chapter 61 of that title. $ $
10. Income from all other sources not listed above. Specify the source and amount.
Do not include any benefits received under the Social Security Act; payments
received as a victim of a war crime, a crime against humanity, or international or
domestic terrorism; or compensation, pension, pay, annuity, or allowance paid by the
disability, or death of a member of the uniformed services. If necessary, list other
sources on a separate page and put the total below.
. $ $
$ $
Total amounts from separate pages, if any. + $ $
11. Calculate your total current monthly income. Add lines 2 through 10 for
each column. Then add the total for Column A to the total for Column B. $ + $ = $
Total current monthly

income
Part 2: Determine Whether the Means Test Applies to You
12. Calculate your current monthly income for the year. Follow these steps:
12a. Copy your total current monthly income from line 11 Copy line 11 here=> $
Multiply by 12 (the number of months in a year) x 12

12b. The result is your annual income for this part of the form 12b. $
13. Calculate the median family income that applies to you. Follow these steps:
Fill in the state in which you live.
Fill in the number of people in your household.
Fill in the median family income for your state and size of household. 13. $
To find a list of applicable median income amounts, go online using the link specified in the separate instructions
for this form. This list may also be available at the bankruptcy clerk’s office.
14. How do the lines compare?
14a. Line 12b is less than or equal to line 13. On the top of page 1, check box 1, There is no presumption of abuse.
Go to Part 3.
14b. Line 12b is more than line 13. On the top of page 1, check box 2, The presumption of abuse is determined by Form 122A-2.
Go to Part 3 and fill out Form 122A-2.
Part 3: Sign Below
By signing here, I declare under penalty of perjury that the information on this statement and in any attachments is true and correct.
X /s/ Jon Darrell Seawright

Date November 3, 2019
MM / DD / YYYY
If you checked line 14a, do NOT fill out or file Form 122A-2.
If you checked line 14b, fill out Form 122A-2 and file it with this form.
Debtor 2
(Spouse, if filing)
United States Bankruptcy Court for the: Southern District of Mississippi
Case number Check if this is an amended filing

(if known)
Official Form 122A - 1Supp

Statement of Exemption from Presumption of Abuse Under § 707(b)(2) 12/15
File this supplement together with Chapter 7 Statement of Your Current Monthly Income (Official Form 122A-1), if you believe that you are
exempted from a presumption of abuse. Be as complete and accurate as possible. If two married people are filing together, and any of the
exclusions in this statement applies to only one of you, the other person should complete a separate Form 122A-1 If you believe that this is
required by 11 U.S.C. § 707(b)(2)(C).
Part 1: Identify the Kind of Debts You Have
1. Are your debts primarily consumer debts? Consumer debts are defined in 11 U.S.C. § 101(8) as "incurred by an individual primarily for a
personal, family, or household purpose." Make sure that your answer is consistent with the answer you gave at line 16 of the Voluntary Petition for
Individuals Filing for Bankruptcy (Official Form 1).
No. Go to Form 122A-1; on the top of page 1 of that form, check box 1, There is no presumption of abuse, and sign Part 3. Then submit this
supplement with the signed Form 122A-1.
Yes. Go to Part 2.
Part 2: Determine Whether Military Service Provisions Apply to You
2. Are you a disabled veteran (as defined in 38 U.S.C. § 3741(1))?

No. Go to line 3.
Yes. Did you incur debts mostly while you were on active duty or while you were performing a homeland defense activity?
10 U.S.C. § 101(d)(1); 32 U.S.C. § 901(1).
No. Go to line 3.
Yes. Go to Form 122A-1: on the top of page 1 of that form, check box 1, There is no presumption of abuse, and sign Part 3. Then
submit this supplement with the signed Form 122A-1.
3. Are you or have you been a Reservist or member of the National Guard?
No. Complete Form 122A-1. Do not submit this supplement.
Yes. Were you called to active duty or did you perform a homeland defense activity? 10 U.S.C. § 101(d)(1); 32 U.S.C. § 901(1).
Yes. Check any one of the following categories that applies:
If you checked one of the categories to the left, go to Form
I was called to active duty after September 11, 2001, for at least 122A-1. On the top of page 1 of Form 122A-1, check box 3,
90 days and remain on active duty. The Means Test does not apply now, and sign Part 3. Then
submit this supplement with the signed Form 122A-1. You
I was called to active duty after September 11, 2001, for at least are not required to fill out the rest of Official Form 122A-1
90 days and was released from active duty on , during the exclusion period. The exclusion period means
which is fewer than 540 days before I file this bankruptcy case. the time you are on active duty or are performing a
homeland defense activity, and for 540 days afterward. 11
I am performing a homeland defense activity for at least 90 days. U.S.C. § 707(b)(2)(D)(ii).
I performed a homeland defense activity for at least 90 days,

If your exclusion period ends before your case is closed,
ending on , which is fewer than 540 days before I
you may have to file an amended form later.
file this bankruptcy case.
Official Form 122A-1Supp Statement of Exemption from Presumption of Abuse Under § 707(b)(2) page 1
Notice Required by 11 U.S.C. § 342(b) for

Individuals Filing for Bankruptcy (Form 2010)
Chapter 7: Liquidation
This notice is for you if:
$245 filing fee
You are an individual filing for bankruptcy,
and $75 administrative fee
Your debts are primarily consumer debts. + $15 trustee surcharge

Consumer debts are defined in 11 U.S.C.
§ 101(8) as “incurred by an individual $335 total fee
primarily for a personal, family, or
household purpose.” Chapter 7 is for individuals who have financial
difficulty preventing them from paying their debts
and who are willing to allow their nonexempt
The types of bankruptcy that are available to property to be used to pay their creditors. The
individuals primary purpose of filing under chapter 7 is to have
your debts discharged. The bankruptcy discharge
Individuals who meet the qualifications may file under relieves you after bankruptcy from having to pay
one of four different chapters of Bankruptcy Code: many of your pre-bankruptcy debts. Exceptions exist
for particular debts, and liens on property may still
Chapter 7 - Liquidation be enforced after discharge. For example, a creditor
may have the right to foreclose a home mortgage or
Chapter 11 - Reorganization repossess an automobile.
Chapter 12 - Voluntary repayment plan However, if the court finds that you have committed
for family farmers or certain kinds of improper conduct described in the
fishermen Bankruptcy Code, the court may deny your
discharge.
Chapter 13 - Voluntary repayment plan
for individuals with regular You should know that even if you file chapter 7 and
income you receive a discharge, some debts are not
discharged under the law. Therefore, you may still
be responsible to pay:
You should have an attorney review your
decision to file for bankruptcy and the choice of most taxes;
chapter.
most student loans;
domestic support and property settlement

obligations;
Notice Required by 11 U.S.C. § 342(b) for Individuals Filing for Bankruptcy (Form 2010) page 1
most fines, penalties, forfeitures, and criminal your income is more than the median income for your
restitution obligations; and state of residence and family size, depending on the
results of the Means Test, the U.S. trustee, bankruptcy
certain debts that are not listed in your bankruptcy administrator, or creditors can file a motion to dismiss
papers. your case under § 707(b) of the Bankruptcy Code. If a
motion is filed, the court will decide if your case should
You may also be required to pay debts arising from: be dismissed. To avoid dismissal, you may choose to
proceed under another chapter of the Bankruptcy
fraud or theft; Code.
fraud or defalcation while acting in breach of If you are an individual filing for chapter 7 bankruptcy,
fiduciary capacity; the trustee may sell your property to pay your debts,
subject to your right to exempt the property or a portion
intentional injuries that you inflicted; and of the proceeds from the sale of the property. The
property, and the proceeds from property that your
death or personal injury caused by operating a bankruptcy trustee sells or liquidates that you are
motor vehicle, vessel, or aircraft while intoxicated entitled to, is called exempt property. Exemptions may
from alcohol or drugs. enable you to keep your home, a car, clothing, and
household items or to receive some of the proceeds if
If your debts are primarily consumer debts, the court the property is sold.
can dismiss your chapter 7 case if it finds that you have
enough income to repay creditors a certain amount. Exemptions are not automatic. To exempt property,
You must file Chapter 7 Statement of Your Current you must list it on Schedule C: The Property You Claim
Monthly Income (Official Form 122A–1) if you are an as Exempt (Official Form 106C). If you do not list the
individual filing for bankruptcy under chapter 7. This property, the trustee may sell it and pay all of the
form will determine your current monthly income and proceeds to your creditors.
compare whether your income is more than the median
income that applies in your state.
If your income is not above the median for your state,

you will not have to complete the other chapter 7 form, Chapter 11: Reorganization
the Chapter 7 Means Test Calculation (Official Form
122A–2).
$1,167 filing fee
If your income is above the median for your state, you
must file a second form —the Chapter 7 Means Test + $550 administrative fee
Calculation (Official Form 122A–2). The calculations on
$1,717 total fee
the form— sometimes called the Means Test—deduct
from your income living expenses and payments on
Chapter 11 is often used for reorganizing a business,
certain debts to determine any amount available to pay
but is also available to individuals. The provisions of
unsecured creditors. If
chapter 11 are too complicated to summarize briefly.
Read These Important Warnings
Because bankruptcy can have serious long-term financial and legal consequences, including loss of
your property, you should hire an attorney and carefully consider all of your options before you file.
Only an attorney can give you legal advice about what can happen as a result of filing for bankruptcy
and what your options are. If you do file for bankruptcy, an attorney can help you fill out the forms
properly and protect you, your family, your home, and your possessions.
Although the law allows you to represent yourself in bankruptcy court, you should understand that
many people find it difficult to represent themselves successfully. The rules are technical, and a mistake
or inaction may harm you. If you file without an attorney, you are still responsible for knowing and
following all of the legal requirements.
You should not file for bankruptcy if you are not eligible to file or if you do not intend to file the
necessary documents.
Bankruptcy fraud is a serious crime; you could be fined and imprisoned if you commit fraud in your
bankruptcy case. Making a false statement, concealing property, or obtaining money or property by
fraud in connection with a bankruptcy case can result in fines up to $250,000, or imprisonment for up to
20 years, or both. 18 U.S.C. §§ 152, 1341, 1519, and 3571.
Under chapter 13, you must file with the court a plan
Chapter 12: Repayment plan for family to repay your creditors all or part of the money that
farmers or fishermen you owe them, usually using your future earnings. If
the court approves your plan, the court will allow you
to repay your debts, as adjusted by the plan, within 3
$200 filing fee years or 5 years, depending on your income and other
+ $75 administrative fee factors.
$275 total fee
After you make all the payments under your plan,
Similar to chapter 13, chapter 12 permits family farmers many of your debts are discharged. The debts that are
and fishermen to repay their debts over a period of time not discharged and that you may still be responsible to
using future earnings and to discharge some debts that pay include:
are not paid.
domestic support obligations,
most student loans,

Chapter 13: Repayment plan for
individuals with regular certain taxes,
income
debts for fraud or theft,
$235 filing fee debts for fraud or defalcation while acting in a

+ $75 administrative fee fiduciary capacity,
$310 total fee
most criminal fines and restitution obligations,
Chapter 13 is for individuals who have regular income
and would like to pay all or part of their debts in certain debts that are not listed in your
installments over a period of time and to discharge bankruptcy papers,
some debts that are not paid. You are eligible for
chapter 13 only if your debts are not more than certain certain debts for acts that caused death or
dollar amounts set forth in 11 U.S.C. § 109. personal injury, and
certain long-term secured debts.
A married couple may file a bankruptcy case

Warning: File Your Forms on Time together—called a joint case. If you file a joint case and
each spouse lists the same mailing address on the
Section 521(a)(1) of the Bankruptcy Code requires that bankruptcy petition, the bankruptcy court generally will
you promptly file detailed information about your mail you and your spouse one copy of each notice,
creditors, assets, liabilities, income, expenses and unless you file a statement with the court asking that
general financial condition. The court may dismiss your each spouse receive separate copies.
bankruptcy case if you do not file this information within
the deadlines set by the Bankruptcy Code, the Understand which services you could receive from
Bankruptcy Rules, and the local rules of the court. credit counseling agencies
For more information about the documents and The law generally requires that you receive a credit
their deadlines, go to: counseling briefing from an approved credit counseling
http://www.uscourts.gov/bkforms/bankruptcy_form agency. 11 U.S.C. § 109(h). If you are filing a joint
s.html#procedure. case, both spouses must receive the briefing. With
limited exceptions, you must receive it within the 180
days before you file your bankruptcy petition. This
Bankruptcy crimes have serious consequences briefing is usually conducted by telephone or on the
Internet.
If you knowingly and fraudulently conceal assets
or make a false oath or statement under penalty In addition, after filing a bankruptcy case, you generally
of perjury—either orally or in writing—in must complete a financial management instructional
connection with a bankruptcy case, you may be course before you can receive a discharge. If you are
fined, imprisoned, or both. filing a joint case, both spouses must complete the
course.
All information you supply in connection with a
bankruptcy case is subject to examination by the You can obtain the list of agencies approved to provide
Attorney General acting through the Office of the both the briefing and the instructional course from:
U.S. Trustee, the Office of the U.S. Attorney, and http://justice.gov/ust/eo/hapcpa/ccde/cc_approved.html
other offices and employees of the U.S. .
Department of Justice.
In Alabama and North Carolina, go to:
Make sure the court has your mailing address http://www.uscourts.gov/FederalCourts/Bankruptcy/
BankruptcyResources/ApprovedCredit
The bankruptcy court sends notices to the mailing AndDebtCounselors.aspx.
address you list on Voluntary Petition for Individuals
Filing for Bankruptcy (Official Form 101). To ensure If you do not have access to a computer, the clerk of
that you receive information about your case, the bankruptcy court may be able to help you obtain
Bankruptcy Rule 4002 requires that you notify the court the list.
of any changes in your address.
B2030 (Form 2030) (12/15)

United States Bankruptcy Court
Southern District of Mississippi
In re Jon Darrell Seawright Case No.
Debtor(s) Chapter 7
DISCLOSURE OF COMPENSATION OF ATTORNEY FOR DEBTOR(S)

1. Pursuant to 11 U .S.C. § 329(a) and Fed. Bankr. P. 2016(b), I certify that I am the attorney for the above named debtor(s) and that
compensation paid to me within one year before the filing of the petition in bankruptcy, or agreed to be paid to me, for services rendered or to
be rendered on behalf of the debtor(s) in contemplation of or in connection with the bankruptcy case is as follows:
For legal services, I have agreed to accept $ 2,500.00
Prior to the filing of this statement I have received $ 2,500.00
Balance Due $ 0.00
2. The source of the compensation paid to me was:
Debtor Other (specify):
3. The source of compensation to be paid to me is:
Debtor Other (specify):
4. I have not agreed to share the above-disclosed compensation with any other person unless they are members and associates of my law firm.
I have agreed to share the above-disclosed compensation with a person or persons who are not members or associates of my law firm. A
copy of the agreement, together with a list of the names of the people sharing in the compensation is attached.
5. In return for the above-disclosed fee, I have agreed to render legal service for all aspects of the bankruptcy case, including:
a. Analysis of the debtor's financial situation, and rendering advice to the debtor in determining whether to file a petition in bankruptcy;
b. Preparation and filing of any petition, schedules, statement of affairs and plan which may be required;
c. Representation of the debtor at the meeting of creditors and confirmation hearing, and any adjourned hearings thereof;
d. [Other provisions as needed]
Negotiations with secured creditors to reduce to market value; exemption planning; preparation and filing of
reaffirmation agreements and applications as needed; preparation and filing of motions pursuant to 11 USC
522(f)(2)(A) for avoidance of liens on household goods.
6. By agreement with the debtor(s), the above-disclosed fee does not include the following service:
Representation of the debtors in any dischargeability actions, judicial lien avoidances, relief from stay actions or
any other adversary proceeding.
CERTIFICATION
I certify that the foregoing is a complete statement of any agreement or arrangement for payment to me for representation of the debtor(s) in
this bankruptcy proceeding.
November 3, 2019 /s/ R. Michael Bolen Miss. Bar

Date R. Michael Bolen Miss. Bar 3615
Signature of Attorney
Hood & Bolen, PLLC
Attorneys at Law
3770 Highway 80 West
Jackson, MS 39209
(601)923-0788 Fax: hoodbolen.com
rmb@hoodbolen.com
Name of law firm
Fill in this information to identify your case: Check one box only as directed in this form and in Form
122A-1Supp:
Debtor 2 1. There is no presumption of abuse
(Spouse, if filing)
United States Bankruptcy Court for the: Southern District of Mississippi 2. The calculation to determine if a presumption of abuse
applies will be made under Chapter 7 Means Test
Calculation (Official Form 122A-2).
Case number
(if known)
3. The Means Test does not apply now because of
qualified military service but it could apply later.
Check if this is an amended filing
Official Form 122A - 1
Chapter 7 Statement of Your Current Monthly Income 10/19
Be as complete and accurate as possible. If two married people are filing together, both are equally responsible for being accurate. If more space is needed,
attach a separate sheet to this form. Include the line number to which the additional information applies. On the top of any additional pages, write your name and
case number (if known). If you believe that you are exempted from a presumption of abuse because you do not have primarily consumer debts or because of
qualifying military service, complete and file Statement of Exemption from Presumption of Abuse Under § 707(b)(2) (Official Form 122A-1Supp) with this form.
Part 1: Calculate Your Current Monthly Income
1. What is your marital and filing status? Check one only.

Not married. Fill out Column A, lines 2-11.
Married and your spouse is filing with you. Fill out both Columns A and B, lines 2-11.
Married and your spouse is NOT filing with you. You and your spouse are:
Living in the same household and are not legally separated. Fill out both Columns A and B, lines 2-11.
Living separately or are legally separated. Fill out Column A, lines 2-11; do not fill out Column B. By checking this box, you declare under
penalty of perjury that you and your spouse are legally separated under nonbankruptcy law that applies or that you and your spouse are
living apart for reasons that do not include evading the Means Test requirements. 11 U.S.C § 707(b)(7)(B).
Fill in the average monthly income that you received from all sources, derived during the 6 full months before you file this bankruptcy case. 11 U.S.C. §
101(10A). For example, if you are filing on September 15, the 6-month period would be March 1 through August 31. If the amount of your monthly income varied during
the 6 months, add the income for all 6 months and divide the total by 6. Fill in the result. Do not include any income amount more than once. For example, if both
spouses own the same rental property, put the income from that property in one column only. If you have nothing to report for any line, write $0 in the space.
Column A Column B
non-filing spouse
2. Your gross wages, salary, tips, bonuses, overtime, and commissions (before all
payroll deductions). $ $
3. Alimony and maintenance payments. Do not include payments from a spouse if
Column B is filled in. $ $
4. All amounts from any source which are regularly paid for household expenses
of you or your dependents, including child support. Include regular contributions
from an unmarried partner, members of your household, your dependents, parents,
and roommates. Include regular contributions from a spouse only if Column B is not
filled in. Do not include payments you listed on line 3. $ $
5. Net income from operating a business, profession, or farm
Debtor 1
Net monthly income from a business, profession, or farm $ Copy here -> $ $
6. Net income from rental and other real property
Debtor 1
Net monthly income from rental or other real property $ Copy here -> $ $
$ $
7. Interest, dividends, and royalties
Column A Column B
non-filing spouse
8. Unemployment compensation $ $
Do not enter the amount if you contend that the amount received was a benefit under
the Social Security Act. Instead, list it here:
For you $
For your spouse $
9. Pension or retirement income. Do not include any amount received that was a
benefit under the Social Security Act. Also, except as stated in the next sentence, do
not include any compensation, pension, pay, annuity, or allowance paid by the
disability, or death of a member of the uniformed services. If you received any retired
pay paid under chapter 61 of title 10, then include that pay only to the extent that it
does not exceed the amount of retired pay to which you would otherwise be entitled
if retired under any provision of title 10 other than chapter 61 of that title. $ $
10. Income from all other sources not listed above. Specify the source and amount.
Do not include any benefits received under the Social Security Act; payments
received as a victim of a war crime, a crime against humanity, or international or
domestic terrorism; or compensation, pension, pay, annuity, or allowance paid by the
disability, or death of a member of the uniformed services. If necessary, list other
sources on a separate page and put the total below.
. $ $
$ $
Total amounts from separate pages, if any. + $ $
11. Calculate your total current monthly income. Add lines 2 through 10 for
each column. Then add the total for Column A to the total for Column B. $ + $ = $
Total current monthly

income
Part 2: Determine Whether the Means Test Applies to You
12. Calculate your current monthly income for the year. Follow these steps:
12a. Copy your total current monthly income from line 11 Copy line 11 here=> $
Multiply by 12 (the number of months in a year) x 12

12b. The result is your annual income for this part of the form 12b. $
13. Calculate the median family income that applies to you. Follow these steps:
Fill in the state in which you live.
Fill in the number of people in your household.
Fill in the median family income for your state and size of household. 13. $
To find a list of applicable median income amounts, go online using the link specified in the separate instructions
for this form. This list may also be available at the bankruptcy clerk’s office.
14. How do the lines compare?
14a. Line 12b is less than or equal to line 13. On the top of page 1, check box 1, There is no presumption of abuse.
Go to Part 3.
14b. Line 12b is more than line 13. On the top of page 1, check box 2, The presumption of abuse is determined by Form 122A-2.
Go to Part 3 and fill out Form 122A-2.
Part 3: Sign Below
By signing here, I declare under penalty of perjury that the information on this statement and in any attachments is true and correct.
X /s/ Jon Darrell Seawright

Date November 3, 2019
MM / DD / YYYY
If you checked line 14a, do NOT fill out or file Form 122A-2.
If you checked line 14b, fill out Form 122A-2 and file it with this form.
Debtor 2
(Spouse, if filing)
United States Bankruptcy Court for the: Southern District of Mississippi
Case number Check if this is an amended filing

(if known)
Official Form 122A - 1Supp

Statement of Exemption from Presumption of Abuse Under § 707(b)(2) 12/15
File this supplement together with Chapter 7 Statement of Your Current Monthly Income (Official Form 122A-1), if you believe that you are
exempted from a presumption of abuse. Be as complete and accurate as possible. If two married people are filing together, and any of the
exclusions in this statement applies to only one of you, the other person should complete a separate Form 122A-1 If you believe that this is
required by 11 U.S.C. § 707(b)(2)(C).
Part 1: Identify the Kind of Debts You Have
1. Are your debts primarily consumer debts? Consumer debts are defined in 11 U.S.C. § 101(8) as "incurred by an individual primarily for a
personal, family, or household purpose." Make sure that your answer is consistent with the answer you gave at line 16 of the Voluntary Petition for
Individuals Filing for Bankruptcy (Official Form 1).
No. Go to Form 122A-1; on the top of page 1 of that form, check box 1, There is no presumption of abuse, and sign Part 3. Then submit this
supplement with the signed Form 122A-1.
Yes. Go to Part 2.
Part 2: Determine Whether Military Service Provisions Apply to You
2. Are you a disabled veteran (as defined in 38 U.S.C. § 3741(1))?

No. Go to line 3.
Yes. Did you incur debts mostly while you were on active duty or while you were performing a homeland defense activity?
10 U.S.C. § 101(d)(1); 32 U.S.C. § 901(1).
No. Go to line 3.
Yes. Go to Form 122A-1: on the top of page 1 of that form, check box 1, There is no presumption of abuse, and sign Part 3. Then
submit this supplement with the signed Form 122A-1.
3. Are you or have you been a Reservist or member of the National Guard?
Yes. Were you called to active duty or did you perform a homeland defense activity? 10 U.S.C. § 101(d)(1); 32 U.S.C. § 901(1).
Yes. Check any one of the following categories that applies:
If you checked one of the categories to the left, go to Form
I was called to active duty after September 11, 2001, for at least 122A-1. On the top of page 1 of Form 122A-1, check box 3,
90 days and remain on active duty. The Means Test does not apply now, and sign Part 3. Then
submit this supplement with the signed Form 122A-1. You
I was called to active duty after September 11, 2001, for at least are not required to fill out the rest of Official Form 122A-1
90 days and was released from active duty on , during the exclusion period. The exclusion period means
which is fewer than 540 days before I file this bankruptcy case. the time you are on active duty or are performing a
homeland defense activity, and for 540 days afterward. 11
I am performing a homeland defense activity for at least 90 days. U.S.C. § 707(b)(2)(D)(ii).
I performed a homeland defense activity for at least 90 days,

If your exclusion period ends before your case is closed,
ending on , which is fewer than 540 days before I
you may have to file an amended form later.
file this bankruptcy case.
Official Form 122A-1Supp Statement of Exemption from Presumption of Abuse Under § 707(b)(2) page 1
IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF MISSISSIPPI
NORTHERN DIVISION
ALYSSON MILLS, IN HER CAPACITY PLAINTIFF

PROPERTIES, LLC
vs. CASE NO. 3:18-cv-866-CWR-FKB
BUTLER SNOW LLP; BUTLER SNOW DEFENDANTS

BEARMAN, CALDWELL & BERKOWITZ
SEAWRIGHT
ANSWER AND AFFIRMATIVE DEFENSES OF ALEXANDER SEAWRIGHT, LLC,

BRENT ALEXANDER, AND JON SEAWRIGHT
Defendants Alexander Seawright, LLC (“Alexander Seawright”), Brent Alexander, and
Jon Seawright (collectively, the “Alexander Seawright Defendants”), by and through
undersigned counsel, file this Answer and Affirmative Defenses in response to the Complaint
filed against them by Plaintiff Alysson Mills, in her capacity as Receiver for Arthur Lamar
Adams (“Adams”) and Madison Timber Properties, LLC (“Madison Timber”).
ANSWER
Subject to and without waiving any of their affirmative defenses stated below, the
Alexander Seawright Defendants answer the specific allegations of the Receiver’s Complaint,
paragraph by paragraph, each of the following numbered and unnumbered paragraphs
corresponding to those in the Complaint. For convenience, the Alexander Seawright Defendants
may answer several consecutive paragraphs of the Receiver’s Complaint with a single response,
identifying the paragraphs to which the response is directed. All allegations of the Receiver’s
Complaint that are not expressly admitted in this Answer are hereby denied. The Alexander
Seawright Defendants’ admissions are confined to the exact language in this Answer, and to the
extent that any response varies from the wording of the allegations of the Complaint, those
allegations are denied. The Alexander Seawright Defendants deny all allegations and inferences
contained in the headings and subheadings used in the Complaint.
INTRODUCTION
The Receiver’s allegations in her Introduction are not directed to the Alexander
Seawright Defendants and therefore do not require a response from them. To the extent a
response is required from the Alexander Seawright Defendants, they are without sufficient
knowledge and information to respond to all of the allegations in the Introduction and therefore
deny the same, except as follows. The Alexander Seawright Defendants admit: it is apparent that
Adams and Madison Timber operated a Ponzi scheme that defrauded hundreds of lenders,
including Alexander and Seawright; the Alexander Seawright Defendants believed that Madison
Timber used their money as well as other lenders’ money to purchase timber from landowners,
sold the timber to lumber mills at a higher price, and repaid lenders their principal plus interest
with the proceeds of those timber sales. The Alexander Seawright Defendants deny the
remaining allegations in the Introduction. All allegations not expressly admitted are denied. The
Alexander Seawright Defendants affirmatively state that they had no knowledge of Adams’s
fraudulent conduct or his intent to operate Madison Timber as a Ponzi scheme.
JURISDICTION AND VENUE
1. The allegations in Paragraph 1 attempt to state legal conclusions to which no
response is required from the Alexander Seawright Defendants. To the extent a response is
required from the Alexander Seawright Defendants, they admit that this Court has jurisdiction
2
over this action and the parties and that venue is proper in this Court. All allegations not
expressly admitted are denied.
2. The allegations in Paragraph 2 are not directed to the Alexander Seawright
Defendants and therefore do not require a response from them. To the extent a response is
required from the Alexander Seawright Defendants, they admit that this action is related to a
civil action pending before the Court styled Securities and Exchange Commission v. Arthur
Lamar Adams and Madison Timber Properties, LLC, No. 3:18-cv-252-CWR-FKB. The
pleadings in that action speak for themselves. All allegations not expressly admitted are denied.
Defendants and therefore do not require a response from them. Further, the allegations in
Paragraph 3 attempt to state legal conclusions to which no response is required by the Alexander
Seawright Defendants. To the extent a response is required from the Alexander Seawright
Defendants, they deny that the Receiver is entitled to bring any suit or claim against them. All
allegations not expressly admitted are denied.
required from the Alexander Seawright Defendants, they state that the pleadings filed in
Securities and Exchange Commission v. Arthur Lamar Adams and Madison Timber Properties,
LLC, No. 3:18-cv-252-CWR-FKB, speak for themselves. All allegations not expressly admitted
are denied.
PARTIES
Paragraph 5 attempt to state legal conclusions to which no response is required by the Alexander
3
Seawright Defendants. To the extent a response is required from the Alexander Seawright
Defendants, they admit that Plaintiff Alysson Mills has been appointed by the Court as Receiver
for the estates of Adams and Madison Timber. The Alexander Seawright Defendants deny the
remaining allegations of Paragraph 5 to the extent they are inconsistent with the Court’s order,
which speaks for itself. The Alexander Seawright Defendants deny that the Receiver has
standing to pursue claims against them. All allegations not expressly admitted are denied.
required from the Alexander Seawright Defendants, they admit upon information and belief that
Butler Snow LLP is a limited liability partnership doing business in Mississippi. All allegations
not expressly admitted are denied.
Butler Snow Advisory Services, LLC is a Mississippi limited liability company doing business in
Mississippi. All allegations not expressly admitted are denied.
required from the Alexander Seawright Defendants, they are without sufficient knowledge and
information to admit or deny the allegations in Paragraph 8 and therefore deny the same. All
allegations not expressly admitted are denied.
4
required from the Alexander Seawright Defendants, they admit that Baker, Donelson, Bearman,
Caldwell & Berkowitz, PC (“Baker Donelson”) is a Tennessee professional corporation doing
business in Mississippi. All allegations not expressly admitted are denied.
10. Admitted.
11. Admitted.
12. The Alexander Seawright Defendants admit that Jon Seawright is an adult
resident of Jackson, Mississippi, that he is a shareholder of Baker Donelson, and that he and
Brent Alexander are the sole members of Alexander Seawright, LLC. The Alexander Seawright
Defendants admit that Jon Seawright was previously a member of Baker Donelson’s national
governing Board of Directors, although he is not currently a member of the Board of Directors.
required from the Alexander Seawright Defendants, they admit that Adams, through Madison
Timber, operated a Ponzi scheme that purported to purchase timber from landowners and resell it
to lumber mills at higher prices. All allegations not expressly admitted are denied.
information to admit or deny the allegations in Paragraph 14 and therefore deny the same.
required from the Alexander Seawright Defendants, they admit that they believed Madison
5
Timber would use the loans to acquire timber deeds and cutting agreements; that Madison
Timber would sell the timber to lumber mills at a higher price; and that Madison Timber would
use proceeds of those sales to repay the lenders principal plus interest. All allegations not
required from the Alexander Seawright Defendants, they admit that lenders received promissory
notes in the amount of their loans, payable in twelve monthly installments together with
promised interest. They admit that lenders received twelve pre-dated checks, each in the amount
of the installment due under the promissory note. They admit that lenders received a timber deed
and cutting agreement by which a named landowner purported to grant to Madison Timber the
rights to harvest timber on the land described in the deed and by which Madison Timber
purported to grant its rights to the lender. All allegations not expressly admitted are denied.
most if not all of the timber deeds and cutting agreements have been deemed to be fraudulent.
The Alexander Seawright Defendants are without sufficient knowledge and information to admit
or deny the remaining allegations in Paragraph 17 and therefore deny the same. All allegations
not expressly admitted are denied.
6
required from the Alexander Seawright Defendants, they admit that Adams turned himself into
authorities on or about April 19, 2018. The Alexander Seawright Defendants are without
sufficient knowledge and information to admit or deny the remaining allegations in Paragraph 20
and therefore deny the same. All allegations not expressly admitted are denied.
required from the Alexander Seawright Defendants, they admit the allegations in Paragraph 21,
upon information and belief.
required from the Alexander Seawright Defendants, they admit the allegations in Paragraph 22,
upon information and belief.
response is required by the Alexander Seawright Defendants. To the extent a response is required
7
from the Alexander Seawright Defendants, they are without sufficient knowledge and
24. Some of the allegations in Paragraph 24 are not directed to the Alexander
Seawright Defendants and therefore do not require a response from them. Further, the allegations
in Paragraph 24 attempt to state legal conclusions to which no response is required by the
Alexander Seawright Defendants. To the extent a response is required from the Alexander
Seawright Defendants, they deny all of the allegations in Paragraph 24.
from the Alexander Seawright Defendants, they deny the allegations in Paragraph 25.
BUTLER SNOW
26. – 67. Paragraphs 26 through 67 of the Receiver’s Complaint are not directed to the
Alexander Seawright Defendants and therefore do not require a response from them. To the
extent a response is required from the Alexander Seawright Defendants, they are without
sufficient knowledge and information to admit or deny the allegations in Paragraphs 26 through
67 and therefore deny the same.
BAKER DONELSON
68. Denied.
69. Denied.
70. The Alexander Seawright Defendants deny that they formed a partnership with
Adams. The Alexander Seawright Defendants admit that Alexander Seawright, LLC worked in
good faith to coordinate loans from Alexander Seawright Timber Fund I, LLC (“Timber Fund
I”), of which Alexander Seawright, LLC was a member, to Madison Timber. In exchange for its
8
work coordinating the loans, Madison Timber paid Alexander Seawright, LLC loan-origination
fees. The Alexander Seawright Defendants admit that they believed the loans were low risk. The
Alexander Seawright Defendants deny the allegedly quoted language set forth in Paragraph 70 to
the extent the same is inconsistent with the documents, emails, and text messages produced by
the Alexander Seawright Defendants to the Receiver. All allegations not expressly admitted are
denied.
71. The Alexander Seawright Defendants admit that they believed Madison Timber
was a legitimate business that presented an opportunity for lenders to earn interest on their loans.
The Alexander Seawright Defendants deny that they pitched the first loan opportunity to a client
of Baker Donelson. The Alexander Seawright Defendants deny the allegedly quoted language set
forth in Paragraph 71 to the extent the same is inconsistent with the documents, emails, and text
messages produced by the Alexander Seawright Defendants to the Receiver. All allegations not
72. The Alexander Seawright Defendants admit that Madison Timber paid Alexander
Seawright, LLC loan-origination fees. The Alexander Seawright Defendants admit that Adams
sometimes referred to the fees as “birddog fees.” The Alexander Seawright Defendants deny the
allegedly quoted language set forth in Paragraph 72 to the extent the same is inconsistent with
the documents, emails, and text messages produced by the Alexander Seawright Defendants to
the Receiver. All allegations not expressly admitted are denied.
73. The Alexander Seawright Defendants admit that Madison Timber paid Alexander
Seawright, LLC loan-origination fees. The Alexander Seawright Defendants deny the remaining
allegations of Paragraph 73.
9
74. The Alexander Seawright Defendants admit that Alexander Seawright, LLC
prepared subscription agreements and accompanying documents for the loans to Madison
Timber from Timber Fund I, which was initially called Alewright Investments, LLC. The
Alexander Seawright Defendants admit that Alexander Seawright, LLC worked in good faith to
coordinate loans from Timber Fund I, of which Alexander Seawright, LLC was a member, to
Madison Timber. In exchange for its work coordinating the loans, Madison Timber paid
Alexander Seawright, LLC loan-origination fees. The Alexander Seawright Defendants deny the
remaining allegations of Paragraph 74.
75. The Alexander Seawright Defendants deny that they “pitched their fund to
potential investors, including Baker Donelson clients, as an exclusive ‘friends and family’ fund.”
The Alexander Seawright Defendants admit that Brent Alexander used the phrase “simple,
elegant and profitable” to describe the Timber Fund I loan model. The Alexander Seawright
Defendants deny that “neither Alexander nor Seawright invested their own money in the fund.”
The Alexander Seawright Defendants deny the other allegedly quoted language set forth in
Paragraph 75 to the extent the same is inconsistent with the documents, emails, and text
76. The Alexander Seawright Defendants deny that “Alexander was a persistent
salesman.” The Alexander Seawright Defendants deny the allegedly quoted language set forth in
10
77. The Alexander Seawright Defendants deny that “[i]f a potential investor was
noncommittal, Alexander applied pressure.” The Alexander Seawright Defendants deny the
78. Denied.
from the Alexander Seawright Defendants, they are without sufficient knowledge and
information to admit or deny allegations regarding what lenders might have “reasonably
believed” and therefore deny the same. All allegations not expressly admitted are denied.
80. Denied.
81. The Alexander Seawright Defendants deny the allegations of Paragraph 81 to the
extent they are inconsistent with the biographies of Jon Seawright and Brent Alexander on the
Baker Donelson website. All allegations not expressly admitted are denied.
82. Denied.
83. The Alexander Seawright Defendants admit that they occasionally used Baker
Donelson’s Jackson, Mississippi office address for business related to the loans by Timber Fund
I to Madison Timber. The Alexander Seawright Defendants deny the remaining allegations of
Paragraph 83.
84. The Alexander Seawright Defendants admit that they discussed the Timber Fund I
loans with Baker Donelson colleagues. The Alexander Seawright Defendants deny the allegedly
quoted language set forth in Paragraph 84 to the extent the same is inconsistent with the
11
documents, emails, and text messages produced by the Alexander Seawright Defendants to the
Receiver. All allegations not expressly admitted are denied.
85. The Alexander Seawright Defendants deny that that they undertook no
meaningful evaluations of the loans. The Alexander Seawright Defendants admit that they asked
about potential risks to the timber in the event of natural disasters, and they received assurances
from Adams that all tracts were covered by an umbrella insurance policy. The Alexander
Seawright Defendants deny the allegedly quoted language set forth in Paragraph 85 to the extent
the same is inconsistent with documents, emails, and text messages produced by the Alexander
Seawright Defendants to the Receiver. All allegations not expressly admitted are denied.
86. The Alexander Seawright Defendants admit that they gave lenders “Equity Term
Sheets” that described the terms of loans to be made from Timber Fund I to Madison Timber.
The Alexander Seawright Defendants deny that the March 5, 2017 Equity Term Sheet states that
the Alexander Seawright Defendants would personally inspect the property. The Alexander
Seawright Defendants deny the allegedly quoted language set forth in Paragraph 86 to the extent
the same is inconsistent with documents, emails, and text messages produced by the Alexander
87. The Alexander Seawright Defendants admit that they prepared a loan closing
checklist that speaks for itself. The Alexander Seawright Defendants deny the remaining
allegations in Paragraph 87.
88. The Alexander Seawright Defendants admit that they inspected tracts of land that
were the subjects of the property deeds. The Alexander Seawright Defendants deny the allegedly
12
89. Denied.
90. Denied.
from the Alexander Seawright Defendants, they deny all of the allegations in Paragraph 91.
92. The Alexander Seawright Defendants deny that they did not undertake
meaningful investigations of the loans. The Alexander Seawright Defendants deny the allegedly
93. Denied.
94. Denied.
95. The Alexander Seawright Defendants admit upon information and belief that the
majority of timber deeds and cutting agreements have been deemed to be fraudulent. The
Alexander Seawright Defendants deny that they should have recognized that the signatures were
forged by Adams, because the deeds were notarized. The Alexander Seawright Defendants deny
the remaining allegations in Paragraph 95.
96. The Alexander Seawright Defendants lack sufficient knowledge and information
to admit or deny whether Madison Timber ever had any real contracts with mills and whether a
call to the mills would have “confirmed the truth,” and therefore deny those allegations. The
13
Alexander Seawright Defendants admit that they never called a mill. All allegations not
97. The Alexander Seawright Defendants admit that Adams required lenders to agree
not to record the deeds unless Madison Timber failed to make a payment due under the
promissory note. The Alexander Seawright Defendants deny the allegedly quoted language set
messages produced by the Alexander Seawright Defendants to the Receiver. The Alexander
Seawright Defendants deny the remaining allegations in Paragraph 97.
98. The Alexander Seawright Defendants are without sufficient knowledge and
information to admit or deny the allegations in the first sentence of Paragraph 98 and therefore
deny the same. The Alexander Seawright Defendants deny the allegedly quoted language set
Seawright Defendants deny the remaining allegations in Paragraph 98.
99. The Alexander Seawright Defendants are without sufficient knowledge and
information to admit or deny the allegations in the first two sentences of Paragraph 99 and
therefore deny the same. The Alexander Seawright Defendants deny that they never “evaluated
the investment in light of” market considerations. The Alexander Seawright Defendants deny the
100. The Alexander Seawright Defendants admit that Adams told them that Madison
Timber would not issue checks in December going forward and that what had been a 12-month
14
payoff would become a 13-month payoff, skipping the last month of the year. The Alexander
Seawright Defendants deny the allegedly quoted language set forth in Paragraph 100 to the
extent the same is inconsistent with the documents, emails, and text messages produced by the
Alexander Seawright Defendants to the Receiver. The Alexander Seawright Defendants deny the
remaining allegations in Paragraph 100.
101. The Alexander Seawright Defendants deny the allegedly quoted language set
Seawright Defendants affirmatively state that Alexander Seawright Timber Fund II, LLC
(“Timber Fund II”) was formed on April 23, 2018, the day before the Alexander Seawright
Defendants learned that Madison Timber was a sham. Timber Fund II never started operations, it
never accepted any members other than Alexander Seawright, LLC, and it never participated in
any loans to Madison Timber. All allegations not expressly admitted are denied.
Seawright Defendants admit that they used Baker Donelson’s Jackson, Mississippi office for
business related to Timber Fund I. Again, the Alexander Seawright Defendants affirmatively
state that Timber Fund II was formed on April 23, 2018, the day before the Alexander Seawright
Defendants learned that Madison Timber was a sham. Fund II never started operations, it never
accepted any members other than Alexander Seawright, LLC, and it never participated in any
loans to Madison Timber. All allegations not expressly admitted are denied.
15
103. The Alexander Seawright Defendants admit that they formed Timber Fund II. The
Alexander Seawright Defendants admit that they compiled information regarding their proposal
for Timber Fund II to share with potential lenders, which speaks for itself. The Alexander
Seawright Defendants deny the allegedly quoted language set forth in Paragraph 103 to the
extent the same is inconsistent with the documents, emails, and text messages produced by the
Alexander Seawright Defendants to the Receiver. All allegations not expressly admitted are
denied.
104. The Alexander Seawright Defendants admit that they compiled information
regarding their proposal for Timber Fund II to share with potential lenders, which speaks for
itself. The Alexander Seawright Defendants deny the allegedly quoted language set forth in
105. The Alexander Seawright Defendants admit that they received feedback regarding
Timber Fund II that was “not all good.” The Alexander Seawright Defendants deny the allegedly
106. The Alexander Seawright Defendants deny that they did not stand to lose money
in Timber Fund I. The Alexander Seawright Defendants further deny that they would not have
stood to lose money in Timber Fund II, had it begun operations. The Alexander Seawright
Defendants deny the allegedly quoted language set forth in Paragraph 106 to the extent the same
16
is inconsistent with the documents, emails, and text messages produced by the Alexander
109. The Alexander Seawright Defendants admit that they identified an initial key
lender for Timber Fund II, but that loan was never made. The Alexander Seawright Defendants
deny the allegedly quoted language set forth in Paragraph 109 to the extent the same is
inconsistent with the documents, emails, and text messages produced by the Alexander
110. The Alexander Seawright Defendants deny that the initial key lender for Timber
Fund II was a Baker Donelson client. The Alexander Seawright Defendants deny the allegedly
111. The Alexander Seawright Defendants admit that they opened a bank account for
Timber Fund II. The Alexander Seawright Defendants deny the allegedly quoted language set
17
112. The Alexander Seawright Defendants admit that Adams turned himself into
authorities and admitted the fraud before Timber Fund II began operations. The Alexander
Seawright Defendants admit that they told others that they were victims of Adams’s fraud, and
they are. The Alexander Seawright Defendants deny the allegedly quoted language set forth in
CAUSES OF ACTION
COUNT I
FOR CIVIL CONSPIRACY AGAINST ALL DEFENDANTS
113. The Alexander Seawright Defendants incorporate herein by reference each of
their above responses to the Receiver’s Complaint.
by the Alexander Seawright Defendants to the allegations in Paragraph 114, they deny the same.
115. Denied.
116. Denied.
117. The Alexander Seawright Defendants admit that Madison Timber has been
determined to be a Ponzi scheme. The Alexander Seawright Defendants affirmatively state they
never knew Adams was a fraud, they never knew Madison Timber was a Ponzi scheme, and they
never acted with an unlawful purpose. All allegations not expressly admitted are denied.
18
118. Denied.
119. Denied.
120. Denied.
121. Denied.
122. Denied.
123. Denied.
124. Denied.
125. Denied.
COUNT II
FOR AIDING AND ABETTING AGAINST ALL DEFENDANTS
128. Denied.
129. Denied.
130. Denied.
131. Denied.
132. Denied.
133. Denied.
134. Denied.
19
COUNT III
FOR RECKLESSNESS, GROSS NEGLIGENCE, AND AT A MINIMUM NEGLIGENCE
AGAINST ALL DEFENDANTS
138. Denied.
139. Denied.
140. Denied.
141. Denied.
142. Denied.
143. Denied.
144. Denied.
COUNT IV
FOR VIOLATIONS OF MISSISSIPPI’S FRAUDULENT TRANSFER ACT
AGAINST BUTLER SNOW ADVISORY, THORNTON,

ALEXANDER SEAWRIGHT, ALEXANDER, AND SEAWRIGHT
20
COUNT V
FOR VIOLATIONS OF MISSISSIPPI’S RACKETEER INFLUENCED

AND CORRUPT ORGANIZATION ACT

21
154. Denied.
155. Denied.
156. Denied.
157. Denied.
158. Denied.
COUNT VI
FOR JOINT VENTURE LIABILITY
AGAINST ALEXANDER SEAWRIGHT, ALEXANDER, AND SEAWRIGHT
161. Denied.
162. Denied.
163. Denied.
164. Denied.
22
COUNT VII
FOR ATTORNEY MALPRACTICE
AGAINST BUTLER SNOW
Paragraph 166 attempt to state legal conclusions to which no response is required. To the extent
a response is required from the Alexander Seawright Defendants, they deny the allegations in
Paragraph 166.
required from the Alexander Seawright Defendants, they deny the allegations in Paragraph 167.
23
COUNT VIII
FOR NEGLIGENT RETENTION AND SUPERVISION
AGAINST BUTLER SNOW AND BAKER DONELSON
24
a response is required from the Alexander Seawright Defendants, they deny the allegations in
Paragraph 178.
25
LIABILITY OF BUTLER SNOW FOR BUTLER SNOW ADVISORY
a response is required from the Alexander Seawright Defendants to the allegations in Paragraph
187, they deny the same.
26
LIABILITY OF ALEXANDER AND SEAWRIGHT FOR ALEXANDER SEAWRIGHT
All allegations not expressly admitted are denied.
BUTLER SNOW’S AND BAKER DONELSON’S VICARIOUS LIABILITY
27
The Alexander Seawright Defendants deny the allegations contained in the unnumbered
paragraph on page 44 of the Complaint beginning “WHEREFORE” and in each of its numbered
subparagraphs. The Alexander Seawright Defendants deny that the Receiver is entitled to the
relief requested or to any relief whatsoever from the Alexander Seawright Defendants.
AFFIRMATIVE DEFENSES
FIRST AFFIRMATIVE DEFENSE
The Receiver’s Complaint fails to state a claim against the Alexander Seawright
Defendants for which relief can be granted. Therefore, the Receiver’s claims against the
Alexander Seawright Defendants should be dismissed pursuant to Federal Rule of Civil
Procedure 12(b)(6).
SECOND AFFIRMATIVE DEFENSE
The Receiver’s claims against Jon Seawright and Brent Alexander are barred because the
Receiver cannot pierce the limited liability veil of Alexander Seawright, LLC.
THIRD AFFIRMATIVE DEFENSE
The Receiver’s claims against the Alexander Seawright Defendants are barred by the
doctrine of in pari delicto. The Receiver stands in the shoes of Adams and Madison Timber, the
primary wrongdoers who controlled the Ponzi scheme that duped hundreds of people, including
the Alexander Seawright Defendants. Accordingly, the Receiver cannot seek damages or
contribution from the Alexander Seawright Defendants.
FOURTH AFFIRMATIVE DEFENSE
The Receiver’s claims against the Alexander Seawright Defendants are barred because
the Receiver lacks standing to pursue claims on behalf of anyone other than Adams and Madison
Timber.
28
FIFTH AFFIRMATIVE DEFENSE
they did not owe any legal duty to Adams or Madison Timber, and they did not breach any legal
duty allegedly owing to Adams or Madison Timber.
SIXTH AFFIRMATIVE DEFENSE
good faith value defense. The Alexander Seawright Defendants operated at all times in good
faith and under a belief that they were doing business with a legitimate, legal business and not a
fraudulent scheme. Moreover, the Alexander Seawright Defendants contributed in good faith
significant amounts of time, money, services, and other value for which they were entitled to be
compensated.
SEVENTH AFFIRMATIVE DEFENSE
The Receiver’s claims against the Alexander Seawright Defendants are barred by the acts
and omissions of Adams and Madison Timber; the acts and omissions of the representatives and
agents of Adams and Madison Timber; and the acts and omissions of others for whom the
Alexander Seawright Defendants are not responsible. The Alexander Seawright Defendants are
not directly or proximately responsible for any damages that Adams and Madison Timber might
have allegedly suffered. The Receiver’s claims against the Alexander Seawright Defendants are
barred because the Alexander Seawright Defendants complied at all times with all applicable
standards of care.
EIGHTH AFFIRMATIVE DEFENSE
doctrines of contributory negligence, comparative fault, waiver, estoppel, failure of
29
consideration, fraud, illegality, release, payment, accord and satisfaction, assumption of the risk,
unclean hands, and by the failure of Adams and Madison Timber to mitigate their damages.
NINTH AFFIRMATIVE DEFENSE
the Receiver failed to plead items of special damage and alleged fraud with sufficient
particularity.
TENTH AFFIRMATIVE DEFENSE
The Receiver’s claims against the Alexander Seawright Defendants for punitive damages
are barred: (a) By the Eighth Amendment to the United States Constitution and Section 28 of the
Mississippi Constitution; (b) By the Fifth and Fourteenth Amendments to the United States
Constitution prohibiting substantive and procedural due process violations; as well as by Section
14 of the Mississippi Constitution; (c) By the Fourteenth Amendment to the United States
Constitution guaranteeing equal protection under the laws; (d) By the Fourth, Fifth, Sixth and
Eighth Amendments to the United States Constitution and Sections 14, 17, 26, and 28 of the
Mississippi Constitution to the extent such sanctions are attempted to be imposed without
requiring the burden of proof to be beyond a reasonable doubt; (e) By the provisions of Miss.
Code Ann. § 11-1-65; and (f) By the holdings of United States Supreme Court in BMW v. Gore,
517 U.S. 559 (1996), Cooper Industries, Inc. v. Leatherman Tool Group, Inc., 532 U.S. 424
(2001), and State Farm v. Campbell, 538 U.S. 408 (2003). Moreover, the Receiver’s Complaint
fails to state a claim against the Alexander Seawright Defendants upon which relief can be
granted for punitive damages, the Receiver cannot prove the facts necessary under applicable law
to substantiate an award of punitive damages, and therefore the Alexander Seawright Defendants
affirmatively deny that they are liable to Adams and Madison Timber for punitive damages.
30
ELEVENTH AFFIRMATIVE DEFENSE
the Receiver has not alleged, and the Receiver cannot show, that the Alexander Seawright
Defendants knew of Adams’s fraud or that Madison Timber was a fraudulent scheme.
TWELFTH AFFIRMATIVE DEFENSE
The Receiver’s claims against the Alexander Seawright Defendants are barred for the
reasons set forth in the Alexander Seawright Defendants’ Motion to Dismiss and Memorandum
in Support of the same, which are being filed simultaneously with this Answer and Affirmative
Defenses and is incorporated by reference as if set forth in full.
THIRTEENTH AFFIRMATIVE DEFENSE
As discovery has not been completed in this matter, the Alexander Seawright Defendants
affirmatively plead all applicable defenses available under Rules 12(b) and 8(c) of the Federal
Rules of Civil Procedure, including but not limited to: insufficiency of process, insufficiency of
service of process, failure to join a party under Rule 19, arbitration and award, assumption of the
risk, coercion, duress, failure of consideration, fraud, illegality, injury by fellow servant, laches,
license, res judicata, collateral estoppel, business judgment rule, statute of frauds, statute of
limitations, offset, contribution, waiver, indemnity, failure to give full and proper notice, release,
payment, willful concealment of facts, unconscionability, unconstitutionality of punitive
damages, and any other matter constituting an avoidance or affirmative defense.
FOURTEENTH AFFIRMATIVE DEFENSE
The Alexander Seawright Defendants reserve the right to assert, and hereby give notice
that they intend to rely upon, any other defense that may become available or appear during
31
discovery proceedings or otherwise in this action and hereby reserve the right to amend this
responsive pleading to assert such defenses.
AND NOW, having fully answered each and every allegation of the Receiver’s
Complaint filed against them, the Alexander Seawright Defendants respectfully request that this
Court dismiss the Receiver’s claims against them with prejudice, taxing all costs against the
Receiver and awarding the Alexander Seawright Defendants their reasonable attorneys’ fees and
expenses incurred in defending this lawsuit. The Alexander Seawright Defendants also request
such other and further relief as this Court deems just and proper.
Date: March 6, 2019.
ALEXANDER SEAWRIGHT, LLC; BRENT

ALEXANDER; and JON SEAWRIGHT
By: /s/ R. David Kaufman

R. David Kaufman
One of Their Attorneys
R. David Kaufman (MSB #3526)

Cody C. Bailey (MSB #103718)
BRUNINI, GRANTHAM, GROWER & HEWES, PLLC
The Pinnacle Building, Suite 100
190 East Capitol Street (39201)
Post Office Drawer 119
Jackson, Mississippi 39205
Telephone: (601) 948-3101
Facsimile: (601) 960-6902
Email: dkaufman@brunini.com
Counsel for Defendants Alexander Seawright, LLC, Brent

Alexander, and Jon Seawright
32
CERTIFICATE OF SERVICE
I, R. David Kaufman, hereby certify that on March 6, 2019, I caused the foregoing
pleading to be electronically filed with the Clerk of the Court using the CM/ECF system, which
will send notification of such filing to all counsel of record and registered participants.
/s/ R. David Kaufman

R. David Kaufman
33
UNITED STATES DISTR ICT COURT

SOUTHERN DISTR ICT OF M ISS ISS IPPI
NORTHERN DIVISION
ALYSSON MILLS, IN HER CAPACITY 866CWR-FKB

Case No. 3:18-cv-00____
ADAMS AND MADISON TIMBER Arising out of Case No. 3:18-cv-252,
PROPERTIES, LLC, Securities and Exchange Commission v.
Arthur Lamar Adams and Madison Timber
Plaintiff, Properties, LLC
v. Hon. Carlton W. Reeves, District Judge
BUTLER SNOW LLP; BUTLER SNOW

BEARMAN, CALDWELL & BERKOWITZ,
SEAWRIGHT,
Defendants.
COMPLAINT
Alysson Mills, in her capacity as the court-appointed receiver for Arthur Lamar Adams and
Madison Timber Properties, LLC (the “Receiver”), through undersigned counsel, files this
Complaint against Butler Snow LLP; Butler Snow Advisory Services, LLC; Matt Thornton;
Baker, Donelson, Bearman, Caldwell & Berkowitz, PC; Alexander Seawright, LLC; Brent
Alexander; and Jon Seawright (collectively “Defendants”), stating as follows:

INTRODUCTION
For more than ten years, Arthur Lamar Adams (“Adams”), through his companies Madison
Timber Company, LLC and Madison Timber Properties, LLC (“Madison Timber”), operated a
Ponzi scheme that defrauded hundreds of investors. Investors believed that Madison Timber used
investors’ money to purchase timber from Mississippi landowners; that Madison Timber sold the
timber to Mississippi lumber mills at a higher price; and that Madison Timber repaid investors
their principal plus interest with the proceeds of those sales. Investors received timber deeds that
purported to secure their investments—but the deeds were fake. There was no timber and no
proceeds from sales of timber. The money used to repay existing investors came solely from new
investors.
Madison Timber had to continuously grow to repay existing and new investors, and
continuously grow it did. In 2011, Madison Timber took in approximately $10 million from
investors. By 2018 that number had grown by a factor of 16. In the one-year period prior to April
19, 2018, the date Adams surrendered to federal authorities and confessed to the Ponzi scheme,
Madison Timber took in approximately $164.5 million. As of April 19, 2018, Madison Timber
had 501 outstanding promissory notes, reflecting debts to investors of more than $85 million.1
Madison Timber would not have grown without Defendants’ encouragement and
assistance. Defendants lent their influence, their professional expertise, and even their clients to
Adams. They made a fraudulent enterprise a fraternity. Defendants contributed to the success of
the Madison Timber Ponzi scheme, and therefore to the debts of the Receivership Estate to
investors. By this complaint the Receiver seeks to hold Defendants accountable.
1
The evidence at Adams’s sentencing established that of the $164.5 million that Madison Timber received in its last
year of operation, it paid back approximately $79.5 million, leaving an $85 million difference. The outstanding
principal and interest owed to investors is necessarily higher.
2
JURISDICTION AND VENUE
1. The Court has jurisdiction over this action and its parties, and venue is proper in
this Court, pursuant to the Securities Act of 1933, 15 U.S.C. § 77v(a); the Securities & Exchange
Act of 1934, 15 U.S.C. § 78aa; 28 U.S.C. § 1692; and 28 U.S.C. § 754.
2. This action arises in connection with and is ancillary to the civil action already
pending in this Court styled Securities & Exchange Commission v. Arthur Lamar Adams and
Madison Timber Properties, LLC, No. 3:18-cv-252-CWR-FKB. In that civil action, the Securities
& Exchange Commission (“S.E.C.”) alleges that “[b]eginning in approximately 2004,” Adams,
through Madison Timber, “committed securities fraud by operating a Ponzi scheme” in violation
of the Securities Act of 1933 and the Securities & Exchange Act of 1934.2
3. The S.E.C. requested that the Court appoint a receiver for the estates of Adams and
Madison Timber.3 As the Court that appointed the Receiver, this Court has jurisdiction over any
claim brought by the Receiver in the execution of her duties. “[I]t is well-settled that when an
initial suit results in the appointment of the receiver, any suit that the receiver thereafter brings in
the appointment court in order to execute h[er] duties is ancillary to the main suit.” U.S. Small Bus.
Admin. v. Integrated Envtl. Sols., Inc., No. 05-cv-3041, 2006 WL 2336446, at *2 (S.D. Tex. Aug.
10, 2006) (citing Haile v. Henderson Nat’l Bank, 657 F.2d 816, 822 (6th Cir. 1981)). See also 28
U.S.C. § 1692 (“In proceedings in a district court where a receiver is appointed for property, real,
personal, or mixed, situated in different districts, process may issue and be executed in any such
district as if the property lay wholly within one district . . . ”).
4. Consistent with that precedent, Chief U.S. District Judge Daniel P. Jordan III has
ordered that all “cases filed by the duly appointed Receiver . . . which . . . arise out of or relate to
2
Doc. 3, Securities & Exchange Commission vs. Adams, et al., No. 3:18-cv-00252 (S.D. Miss).
3
Docs. 11, 21, Securities & Exchange Commission vs. Adams, et al., No. 3:18-cv-00252 (S.D. Miss).
3
[Securities & Exchange Commission v. Arthur Lamar Adams and Madison Timber Properties,
LLC, No. 3:18-cv-252-CWR-FKB] shall be directly assigned by the Clerk of Court to U.S. District
Judge Carlton W. Reeves and U.S. Magistrate Judge F. Keith Ball.”4 In compliance with Chief
Judge Jordan’s order, the Receiver shall separately file, contemporaneously with this complaint, a
notice of relatedness.
PARTIES
5. Plaintiff Alysson Mills is the Court-appointed Receiver for the estates of Adams and
Madison Timber. The Court’s order of appointment vests in her the power to, among other things:
investigate and . . . bring such legal actions based on law or equity in

any state, federal, or foreign court as the Receiver deems necessary
or appropriate in discharging her duties as Receiver.5
The Receiver brings this civil action in her capacity as Receiver and pursuant to the powers vested
in her by the Court’s orders and applicable law. The Receiver has standing to pursue, inter alia,
claims against third parties whose actions contributed to the success of the Madison Timber Ponzi
scheme, and therefore to the debts of the Receivership Estate.
6. Defendant Butler Snow LLP (with Butler Snow Advisory Services, LLC, “Butler
Snow”) is a Delaware limited liability partnership doing business in Mississippi.
7. Defendant Butler Snow Advisory Services, LLC (with Butler Snow LLP, “Butler
Snow”) is a Mississippi limited liability company doing business Mississippi.
8. Defendant Matt Thornton is an adult resident of Jackson, Mississippi. He is
founder, President, and CEO of Butler Snow Advisory Services, LLC.
4
5
Doc. 33, Securities & Exchange Commission vs. Adams, et al., No. 3:18-cv-00252 (S.D. Miss). By order dated
August 22, 2018, the Court eliminated the requirement that the Receiver obtain “prior approval of this Court upon ex
parte request” before bringing any legal action. Doc. 38, Securities & Exchange Commission vs. Adams, et al., No.
3:18-cv-00252 (S.D. Miss).
4
9. Defendant Baker, Donelson, Bearman, Caldwell & Berkowitz, PC (“Baker
Donelson”) is a Tennessee professional corporation doing business in Mississippi.
10. Defendant Alexander Seawright, LLC is a Mississippi limited liability company
doing business in Mississippi.
11. Defendant Brent Alexander is an adult resident of Jackson, Mississippi. He is a
“Senior Public Policy Advisor” for Baker Donelson. With Jon Seawright, he owns Alexander
Seawright, LLC.
12. Defendant Jon Seawright is an adult resident of Jackson, Mississippi. He is a
shareholder of Baker Donelson and a member of its national governing Board of Directors. With
Brent Alexander, he owns Alexander Seawright, LLC.
13. For more than ten years, Adams, through Madison Timber, operated a Ponzi
scheme that purported to purchase timber from Mississippi landowners and resell it to Mississippi
lumber mills at higher prices.
14. Investors in Madison Timber delivered to Madison Timber large sums of money,
typically in excess of $100,000 dollars, in reliance on the promise that Madison Timber would
repay them their principal plus interest of not less than 12% per annum, and sometimes as much as
20% per annum. The promised interest invariably far exceeded the interest any investor might
receive on any other collateralized investment.
15. Investors believed that Madison Timber would use their money to acquire timber
deeds and cutting agreements from Mississippi landowners; that Madison Timber would then sell
the timber to Mississippi lumber mills at a higher price; and that with the proceeds of those sales
Madison Timber would repay investors their principal and promised interest.
5
16. In exchange for their investments, investors in the Madison Timber Ponzi scheme
received a promissory note in the amount of their investment, payable in twelve monthly
installments together with the promised interest; twelve pre-dated checks, each in the amount of
the installment due under the promissory note; a timber deed and cutting agreement by which a
named landowner purported to grant to Madison Timber the rights to harvest timber on the land
described in the deed; and a timber deed and cutting agreement by which Madison Timber
purported to grant its own rights to the investor.
17. In fact, the timber deeds and cutting agreements were fake. Madison Timber had
no rights to harvest timber and no timber to cut and sell. Because Madison Timber had no
revenues whatsoever, investors were being repaid with new investors’ money.
18. Each month, Madison Timber required more and more new investors to repay
existing investors. Like any Ponzi scheme, Madison Timber had to continuously grow. To grow
Madison Timber, Adams relied on recruiters, including Defendants, to attract new investors.
19. In 2011, Madison Timber took in approximately $10 million from investors. By
2018 that number had grown by a factor of 16.
20. In April 19, 2018, on the heels of investigations of him by the F.B.I. and the U.S.
Attorney’s Office for the Southern District of Mississippi, Adams turned himself in. In the
one-year period prior to April 19, 2018, Madison Timber took in approximately $164.5 million.
As of April 19, 2018, Madison Timber had 501 outstanding promissory notes, reflecting debts to
investors of more than $85 million.6
6
The evidence at Adams’s sentencing established that of the $164.5 million that Madison Timber received in its last
year of operation, it paid back approximately $79.5 million, leaving an $85 million difference. The outstanding
principal and interest owed to investors is necessarily higher.
6
21. Adams pleaded guilty to the federal crime of wire fraud and “admit[ted] to all of the
conduct of the entire scheme and artifice to defraud.”7 On October 30, 2018, he was sentenced to
a term of imprisonment of 235 months.8
22. The S.E.C. separately charged Adams with violations of the Securities Act of 1933
and Securities & Exchange Act of 1934, alleging in its complaint that “[b]eginning in
approximately 2004,” Adams, through Madison Timber, “committed securities fraud by operating
a Ponzi scheme.”9
23. The promissory notes sold by Madison Timber to investors were “securities,” as
that term is defined under 15 U.S.C.A. §78(c)(A)(10) and Miss. Code Ann. § 75-71-102(28).
24. As alleged in the complaint in the underlying action SEC v. Arthur Lamar Adams et
al., No. 3:18-cv-252 (S.D. Miss.), and in the bill of information filed against Adams in U.S. v.
Arthur Lamar Adams, No. 3:18-c-188 (S.D. Miss.), Adams, Madison Timber, and their affiliates,
including Defendants, facilitated sales of promissory notes to investors through material
misstatements and omissions; employed a device, scheme, or artifice to defraud; and engaged in
acts, practices, or courses of business that operated or would operate as a fraud or deceit, all in
violation of Section 17(a) of the Securities Act of 1933, 15 U.S.C. § 77q(A); Section 10(b) of the
Securities Exchange Act of 1934, 15 U.S.C. § 78j(b), and Rule 10b-5, 17 C.F.R. § 240.10b-5,
thereunder; as well as the Mississippi Securities Act, Miss. Code Ann. § 75-71-501.
25. The sales furthermore violated the Securities Act of 1933 and the Mississippi
Securities Act because there were no registration statements for the promissory notes, see Section
5 of the Securities Act of 1933, 15 U.S.C § 77e, and Miss. Code Ann. § 75-71-301; and the
7
Doc. 11, United States v. Adams, No. 3:18-cr-00088 (S.D. Miss).
8
Doc. 21, United States v. Adams, No. 3:18-cr-00088 (S.D. Miss).
9
7
promissory notes were not exempt from registration, see Section 5 of the Securities Act of 1933,
15 U.S.C § 77e, and Miss. Code Ann. §§ 75-71-201 through 75-71-203.
BUTLER SNOW
26. Adams and Madison Timber’s relationship with Butler Snow began in 2009 and
continued until Adams turned himself in on April 19, 2018.
The first engagement
27. Adams had made a name for himself as someone who understood the timber
industry and made money brokering timber sales. For many years Adams brokered legitimate
timber sales—but by 2009 he had figured out that he could fake things, and he saw an opportunity
to go big.
28. Adams previously had done business with Pinnacle Trust, a financial services
company in Madison, Mississippi. He and Pinnacle Trust discussed ways to maximize Adams’s
business. They decided to form an investment fund and engaged Butler Snow law firm to draft the
private placement memorandum, or PPM.
29. The investment fund was named Madison Timber Fund, LLC. Its aim would be to
raise $10,000,000 by selling 100 units at $100,000 each. Lawyers at Butler Snow spent months
working with Adams on the PPM and its accompanying documents.
30. The resulting PPM, drafted by Butler Snow, described the fund as follows:
MADISON TIMBER FUND, LLC, a Mississippi limited liability company (the

“Fund”), has been formed for the objective of achieving income and capital
preservation through investment in timber-producing real estate and other interests
in timber.
8
31. The PPM identified Adams and Madison Timber Company, Inc. as the fund’s
“Manager” and advised that the fund’s “Business Strategy” depended on the Manager’s “network
of contacts”:
[T]he Fund purchases the standing timber directly from the landowner and
then sells or arranges for the sale of the tree harvest. The purchase is made by the
execution of a “Timber Deed,” which is consequently filed in the real estate records
of the county where the land is located. The Timber Deed commonly allows for a
24 to 36 month period to actually harvest the timber. . . .
***
Using its network of contacts cultivated over 20 years, the Manager
regularly receives opportunities to purchase land tracts with timber. Typically, the
Manager has the opportunity to purchase before these tracts go on the “market.”
This gives the Manager a first-look pricing advantage. . . .
***
The Manager also has a number of established relationships with various
lumber mills, which includes knowledge of the mills’ preferred specialty type of
lumber needs from hardwoods to pine. These mills also offer the Manager referrals
for timber purchases. The Manager’s Timber Deeds are designed to protect the
Fund from liability for cleanup, property damage, road repair and other harvesting
challenges.
***
[T]he Manager has developed a timber purchase format that allows the
Manager to control the cyclical aspects of the business. By securing various
term-length contracts, the Manager is able to even out its supplies of timber for its
mill purchasers. The Manager intentionally purchases short-term contracts (3 to 6
month harvest), mixed with mid-term (6 to 12 months) and longer-term tracts (24 to
36 months) to enable the Manager to have a steady three-year supply of harvestable
inventory.
In addition, the Manager tracks the needs of its regular mill customers to
better supply the type of product they need.
***
The Manager believes that its competitive advantage is its flexibility in
choosing both wood sources and wood processing mills. By not having an in-house
mill, the Manager is able to obtain raw timber from various locations and match it
to buyers and mills that are geographically compatible with the mill location. . . .
The Manager’s pricing philosophy is to offer its mills a highly competitive
product. The Manager can offer lower pricing in exchange for a contributing
stream of referrals from its mill customers. The Manager is able to maintain a
highly competitive pricing strategy because it operates with low overhead costs,
9
outsources its harvesting operations with a network of loggers and owns very little
equipment.
32. The PPM identified several “Timber Investment Risks,” including “Timber Price
Volatility.” The PPM explained:
The Fund’s revenues will be affected by the cyclical nature of the forest
products industry. Prices for timber can experience significant variation and have
been historically volatile. The Fund will have little control over the timing and
extent of price changes for timber products. The demand for timber and wood
products is affected primarily by the level of new/residential construction activity,
the supply of manufactured timber products, including imported timber products,
and other uses of timber products. These activities are subject to variation because
of changes in economic conditions, interest and currency rates, population growth
and changing demographics and seasonal weather cycles and storm activity.
33. The PPM also identified several “General Investment Risks,” one of which was
“Reliance on the Manager.” The PPM explained that the fund’s success is “substantially
dependent on the Manager”—therefore the fund might fail if Adams quits or dies. The PPM
disclosed the fund “does not currently own key-person insurance on the life of Lamar Adams” but
will “purchase such a policy within twelve months.”
34. Ultimately the fund itself did not attract any investors, and the PPM was shelved for
the time being.
35. Adams, however, continued to broker purported timber sales and make money
entering “joint ventures” with individual investors to purchase purported stand-alone timber tracts
that he called “standing tracts.” In 2011, Madison Timber took in approximately $10 million from
investors.
36. By this time the Madison Timber Ponzi scheme had been perfected. The consistent,
uniform returns of 12% to 14% attracted dozens of investors with between $100,000 and $200,000
to invest—but like any Ponzi scheme, each month Madison Timber required more and more new
10
investors to repay the old ones. Adams would have to continuously grow Madison Timber to keep
up.
The second and third engagements
37. To continuously grow Madison Timber, Adams turned again to Butler Snow.
38. Butler Snow markets itself to clients as “the only resource you need.” To provide
business services to its law firm’s clients, in 2011 Butler Snow launched Butler Snow Advisory
Services, “a wholly owned subsidiary that provides non-legal business advice.” Butler Snow’s
website boasts that Butler Snow Advisory provides “executive-level strategic guidance” to closely
held businesses:
Closely held businesses face many of the same challenges as large, public
companies without the advantage of strategic advisors. This can make it more
difficult to those business owners to make informed decisions regarding their
business strategy.
Butler Snow Advisory specializes in providing executive-level strategic guidance
to private, family owned and closely held companies. We’ve built a diverse,
experienced team of professionals that are uniquely positioned to leverage industry
knowledge and real-world experience to work for our clients from day one.
Members of the BSA team are dedicated to understanding the goals of your
company and crafting actionable strategies for success, all while identifying
opportunities and mitigating risks.
39. Butler Snow’s website boasts that Butler Snow Advisory “utilize[s] resources from
across the Butler Snow network to match your business needs”:
In addition to our team’s expertise, as a part of the larger Butler Snow family, BSA
has the advantage of access to resources and networks that put our company ahead
of the competition. Our team approach allows us to utilize resources from across
the Butler Snow network to match your business needs with the expertise required.
As a result, our clients benefit from strategic counsel, innovative solutions and
efficient execution – all from an extensive, reputable network of professionals.
A few of the Butler Snow advantages include access to a legal network that boasts:
x 325+ attorneys
x 24 offices across the United States and in Asia and the United Kingdom
11
x client representation in all 50 states and the District of Columbia, as well as

internationally in more than 25 countries around the globe
x extensive business knowledge in a wealth of industries, including
telecommunications, technology, banking and finance, healthcare, oil and
gas and manufacturing
40. Under the leadership of Matt Thornton, its President and CEO, Butler Snow
Advisory sought to “fast-track” its own business by acquiring “top-level talent.” In April 2012,
Thornton announced that Mike Billings would join the team as a “strategic advisor”:
Michael Billings is a strategic advisor for Butler Snow Advisory Services,

specializing in strategic business development – helping clients identify optimal
business opportunities, then designing and implementing business development
strategies to gain a competitive advantage within the sector. He has years of
experience serving in a business development, consulting and advisory capacity to
a number of large companies in the Dallas, Texas area.
41. Butler Snow Advisory was young, and Billings was brand new, when in May 2012
the opportunity to “strategically advise” Madison Timber arose. Adams wanted assistance with a
“$30-50 million capital raise.” Thornton alerted Don Cannada and Barry Cannada, a senior
partner and the Vice Chair of Butler Snow, respectively, to the prospects of this new business.
42. A series of meetings followed at Butler Snow’s Ridgeland office. After, Thornton
told Adams “I have thoroughly enjoyed getting to know you and believe we could be a piece of the
puzzle in terms of strategic business growth and the associated financing/capital strategies to
accompany growth.” Thornton proposed that Adams engage Butler Snow Advisory to provide
“strategic business development, strategic financing/capital strategies and overall management
advisory services” and, separately, engage Butler Snow law firm to update the preexisting PPM.
43. Internally Thornton and Billings discussed how Butler Snow Advisory would be
compensated. They proposed a monthly fee of $3,500 “to assist in strategic business
development” plus a “success fee” for “individual projects.” If Thornton and Billings succeeded
12
in establishing a fund, they proposed to receive half of Madison Timber’s management fee plus
33% (later reduced to 25%) of Madison Timber’s carried interest. At the time, Billings wrote
Thornton of Adams’s “insatiable appetite for cash”:
As Lamar [Adams] has a seemingly insatiable appetite for cash, all the way up to a
couple hundred $ Million, in theory we would be engage[d] and be paid the $3,500
retainer until he says “uncle” and does not have the capacity to do any more
volume.
Thornton agreed that they should “lock that down for at least a year.”
44. In August 2012, at Thornton’s urging, Adams formally engaged Butler Snow
Advisory to “focus on strategic business development” and, separately, formally engaged Butler
Snow law firm to update the preexisting PPM.10
The pitch
45. While lawyers at Butler Snow updated the preexisting PPM, Thornton and Billings
began pitching Madison Timber to high net-worth clients. During this time they often copied
Barry Cannada on their emails to keep him apprised of their progress.
46. They had early success with a high net-worth client in New Orleans. The investor
was not interested in investing in a fund, but he was willing to entertain a “joint venture” in a
“standing tract.” Billings and Adams made a presentation to the investor that falsely represented
that Madison Timber had “timber sales” of $9,576,252 in 2009; $8,087,072 in 2010; and
$10,034,024 in 2011. The impressed investor wired Madison Timber $450,000, and Madison
Timber delivered to Butler Snow an $8,000 “commission check.” One month later, after the same
10
The “BSA – Standard Terms and Conditions” that accompanied the August 8, 2012 engagement letter for the
“Engagement of Butler Snow Advisory” includes an arbitration clause, but the letter itself, signed by Lamar Adams
for Madison Timber and Martin Willoughby for Butler Snow Advisory, expressly states that “The state and federal
courts in Mississippi shall have exclusive jurisdiction in relation to any claim, dispute or difference concerning this
Engagement Contract and any matter arising from it. The parties hereto irrevocably waive any right they may have to
object to any action being brought in that Court, to claim that the action has been brought to an inconvenient forum or
to claim that that Court does not have jurisdiction.”
13
investor wired Madison Timber another $1,050,000, Madison Timber delivered to Butler Snow a
$15,750 “commission check.”
47. Buoyed by this early success, Billings introduced Adams to two “billion-dollar”
“family offices” in Texas. Thornton gushed at this “tremendous ‘start.’” On the same day, eager
to please Adams, and worried his counterparts at Butler Snow law firm were not meeting Adams’s
needs, Thornton complained to Barry Cannada that an associate in Butler Snow’s Memphis office
had failed to return Adams’s call and caused Adams to submit a bid for a tract of land “without
legal review.” Thornton lamented that “we continue to have the same scenario occur
over-and-over again with respect to Advisory asking the law firm to assist in a timely, efficient &
within scope manner.”
48. While lawyers at Butler Snow continued to work on the updated PPM, Thornton
and Billings looked for other investors who, like the high net-worth client in New Orleans, might
prefer to invest in a “standing tract” only. They were aware that Madison Timber offered a
consistent, uniform return of 12% to 14%. They made a list of thirty-plus mostly local individuals
and families to target as “Small Investor Madison Timber Prospects.” Many of the individuals on
their list became investors in Madison Timber.
49. In February 2013 lawyers at Butler Snow finalized the updated PPM. The fund
would now aim to raise up to $100,000,000 by selling 1,000 units at $100,000 each. Notably, the
fund’s “Business Strategy” and “Timber Investment Risks”—reproduced above, both of which
were false or misleading—were unchanged. Nevertheless, Thornton represented that he personally
“reread from a non-legal language standpoint and all business, market and organizational aspects
remain in-tact.”
14
50. With the PPM in hand, Thornton made pitches to bigger, institutional clients. He
told them that “Madison Timber (Lamar Adams, President) is a very good client of ours” that “has
been vetted by several $1.5 billion family office(s) in Texas, encompassing a 75+ day due
diligence period [and] as you would imagine, Lamar passed with flying colors!” In fact, the two
“family offices” in Texas had chosen not to invest in Madison Timber.
51. One institutional client to whom Thornton pitched Madison Timber candidly
remarked that “First blush says there has been some inventory build over the last four years.” But
instead of addressing the question raised by the remark, Thornton continued his pitch: “‘Inventory
Build-Up’ . . . great question and one major topic we would like to discuss ‘face-to-face’ . . . we
believe Madison Timber’s business model, strategic partnerships and forward-thinking
supply/demand philosophy is a real differentiator.”
52. Thornton often emphasized non-disclosure agreements both to reinforce the
exclusivity of Madison Timber’s purported “strategic partnerships” and to justify Madison
Timber’s inability to provide requested information. He told one potential investor “we have had
entities sign NDA(s) prior to providing financial information . . . we certainly did this with the two
multi-billion $ family office entities in Dallas.” He told another potential investor, “As we
discussed extremely confidential information relative to Madison Timber’s relationships with
mills, financing structure and the like, we certainly appreciate very much your team’s treating
today’s discussion and information provided in the STRICTLY CONFIDENTIAL category under
the NDA umbrella.” These comments had the effect of impressing upon the potential investor that
Madison Timber represented a uniquely lucrative investment opportunity.
53. Thornton told yet another potential investor who asked about mill contracts:
“Lamar [Adams] has an extremely stringent NDA with his mill partners [and] due to this
15
extremely stringent NDA, we have not shared any mill names/profiles with any potential investors
to date.” Of course, this representation was false because Adams did not have any “mill partners”
therefore there was no “extremely stringent NDA” and no “mill names/profiles” to share. But
Thornton went on:
Additionally, as the investor has a contract with Madison Timber (and NOT with
the mill directly) via promissory note issued from Madison Timber that has
assigned timber deed worth twice as much as their invested dollars. So, investors
would be looking to Madison Timber for payment (not the mill), and in the event of
a default by Lamar, the investors simply file the deed / resell the timber.
Thornton thus assured the potential investor that he should not worry about the mills, because his
contract would be with Madison Timber—a company backed by Butler Snow’s reputation.
54. Ultimately, no investor chose to invest in the fund for which the PPM had been
updated and through which Butler Snow and Adams had hoped to raise $100,000,000. But many
individuals and institutional clients to whom Thornton and Billings made a pitch did invest in
purported “standing tracts” only, and for each of these investments, Madison Timber delivered to
Butler Snow a “commission check.”
55. For all of these transactions, Thornton, Billings, and Butler Snow acted as
unlicensed brokers, in violation of federal and state law. A broker is “any person engaged in the
business of effecting transactions in securities for the account of others.” See Section 3(4) of the
Securities Exchange Act of 1934, 15 U.S.C. § 78c. The S.E.C.’s public website states that the
receipt of transaction-related commissions is a key indicator that a broker must be registered.11 A
recent search using the Financial Industry Regulatory Authority’s public online BrokerCheck
confirms that neither Thornton, Billings, nor Butler Snow have ever registered with the S.E.C.
11
Guide to Broker-Dealer Registration, U.S. SECURITIES & EXCHANGE COMMISSION, https://www.sec.gov/reports
pubs/investor-publications/divisionsmarketregbdguidehtm.html.
16
56. Butler Snow knew or should have known what it was doing was unlawful. Among
the notes in Butler Snow’s Madison Timber files is this comment from Don Cannada in 2009:
“Very broad definition of what a broker is . . . Includes one who for a commission procures a
purchaser or prospect etc. See 73-35-31 for penalties. Says you can’t pay an unlicensed broker,
but doesn’t provide any penalty if you do so.”
57. Investors might fairly question what Butler Snow did for them to earn their
commissions. The answer is not much. While they extolled Madison Timber’s “strategic
partnerships and forward-thinking supply/demand philosophy,” neither Thornton nor Billings, nor
anyone at Butler Snow, conducted an even cursory inspection of Madison Timber’s operations. If
they had, they would have been forced to face the reality that Madison Timber was nothing more
than a Ponzi scheme.
58. Instead, Butler Snow aided and abetted Madison Timber’s growth, lending Adams
and Madison Timber their influence, professional expertise, and clients. Butler Snow’s
imprimatur was powerful, and they knew it. They even agreed to serve as a “referral” for other
firms’ clients. In July 2013 “Baker Donelson” sought “a few referrals” to validate Madison
Timber. Thornton responded within minutes: “No problem by me – thanks!” Billings exclaimed:
“You are more than welcome to include me as a reference for anything at any time . . . highest
marks possible!!”
Red flags
59. Not only did Thornton, Billings, and Butler Snow broker Madison Timber
investments without a license and fail to independently confirm that the timber and rights in
question were real, they also recklessly ignored numerous red flags.
17
60. Indeed, the timber deeds and cutting agreements between landowners and Madison
Timber were fake. The landowners’ signatures, forged by Adams, often looked the same. A call to
any one of the purported landowners, or a simple check of the title for any one of the purported
tracts of land, would have confirmed the truth. Neither Thornton nor Billings, nor anyone at Butler
Snow, ever called a landowner or checked a tract’s title.
61. Madison Timber also had no real contracts with any mills. A call to any one of the
mills for which Madison Timber purported to have contracts would have confirmed the truth.
Neither Thornton nor Billings, nor anyone at Butler Snow, ever called a mill. Worse, having
conducted no due diligence themselves, they falsely represented to potential investors that they
could not disclose Madison Timber’s “mill partners” due to an “extremely stringent NDA.”
62. Adams required that an investor agree that he or she would not record the deed by
which Madison Timber purported to grant its own rights to the investor unless and until Madison
Timber failed to make a payment due under the promissory note. Incredibly, notwithstanding the
suspicious “agreement not to record,” neither Thornton nor Billings, nor anyone at Butler Snow,
questioned this requirement.
63. The “profit” that Adams promised was 300% to 400% better than that payable by
any other fully collateralized investment and was uniform and consistent. This fact should have
been a glaring warning sign standing alone, particularly for individuals such as Thornton and
Billings who touted decades of business experience. It is all the more incredible that neither
Thornton nor Billings, nor anyone at Butler Snow, ever questioned it, given that the PPM drafted
by Butler Snow, which Thornton professed to have read, expressly disclosed the risk of “Timber
Price Volatility.”
18
Another engagement
64. By December 2013 Adams had grown tired of paying Butler Snow Advisory the
monthly fee of $3,500 plus travel expenses. Separately Billings saw potential to make more money
recruiting new investors to Madison Timber fulltime. Adams and Billings informed Thornton that
they would “proceed on a direct basis,” meaning Billings would leave Butler Snow Advisory to
work for Adams fulltime, effective January 1, 2014. Thornton told Adams he had “thoroughly
enjoyed” Madison Timber” and to “please let me know if I or BSAS can ever be of service again.”
65. Butler Snow, however, did not cease servicing Adams. In 2015 Adams engaged
Butler Snow to assist Oxford Springs, LLC, of which he effectively was the managing member,
with “regulatory permitting and compliance matters.” Butler Snow thus continued to lend its
influence to Adams, this time with government bodies. Indeed, Butler Snow was still sending
invoices to Adams after Adams turned himself in.
66. Notwithstanding its attorney-client relationships with Adams and Madison Timber,
not to mention its own role in perpetuating the Ponzi scheme, after Adams turned himself in Butler
Snow purported to represent investors in their demands of Madison Timber. These investors were
led to believe that Butler Snow could and would represent their best interests. At the same time,
however, Butler Snow also purported to represent Billings—whose interests clearly were adverse
to investors.
67. On May 11, 2018, Butler Snow sent Adams a letter titled “Disengagement”
advising that “recent events” made it “appropriate for us to withdraw from the representation.”
19
BAKER DONELSON
68. Adams and Madison Timber’s relationship with Baker Donelson began in 2011 and
continued until Adams turned himself in on April 19, 2018.
A joint venture
69. In 2011, Brent Alexander and Jon Seawright, a lawyer and lobbyist at the Baker
Donelson law firm in Jackson, were looking to start a new investment fund.
70. Alexander and Seawright made acquaintances with Adams and a partnership
quickly formed. Alexander and Seawright would create an LLC that would pool other people’s
money to invest in Madison Timber, and Adams would share the returns with Alexander and
Seawright. From Seawright’s perspective, it was “a virtually risk free deal”:
I feel pretty good about this . . . Please explain to me why this is not a virtually risk
free deal. There is no pricing risk – everything is tied down on the front end. The
only risk I see is (i) mill defaults, but you still own the land, (ii) Lamar is a fraud,
but no evidence of that, or (iii) such a fundamental collapse of the timber industry
that mill defaults and uncut timber is less than purchase price, but investor is
oversecured almost 2:1, so there would have to be catastrophic collapse. Jds
71. Alexander and Seawright saw a big opportunity in Madison Timber, but to raise
“significant capital” for Adams, they needed to do some “smaller investments to prove out the
income earning potential.” They pitched the first investment to a client of Baker Donelson.
Seawright told the client that Alexander and Seawright would be responsible for everything:
We would be responsible for papering everything, liaison with Lamar, monitoring

process of sale of timber, acquisition of timber rights, proper recording of
documents, etc., distribution of loan repayments and otherwise managing the
investment.
Seawright told the client that “[r]unning funds through us or BD [Baker Donelson] escrow is not a
problem,” and all “legal and other admin expenses” would “come out of our share.”
20
72. Alexander and Seawright’s “share” would include a portion of each investment’s
return, what Adams called a “birddog fee.” Adams told Alexander and Seawright that he could
ensure a 14% “profit” with a 2% “birddog fee” built-in, but Alexander and Seawright could decide
“how you guys want the split done.”
73. Seawright proposed instead that each investment’s promissory note bear 13%
interest, of which investors would receive 10% and Alexander and Seawright would keep 3%.
Separately Alexander and Seawright negotiated an additional 3% commission for themselves. As
a result, Alexander and Seawright’s “share” of each investment’s return included the 3% they
disclosed to investors, plus an extra undisclosed 3% that Adams paid them directly.
74. Seawright drafted subscription agreements and accompanying documents for the
sales of units in what was then called Alewright Investments, LLC, later renamed Alexander
Seawright Timber Fund I, LLC. From 2011 until April 2018, Alexander and Seawright used their
fund to invest other people’s money in Madison Timber and split the “profits” with Adams.
The pitch
75. Throughout this time period Alexander and Seawright pitched their fund to
potential investors, including Baker Donelson clients, as an exclusive “friends and family” fund.
Alexander often used the phrase “simple, elegant and profitable” to describe the fund. He told
investors that “we are in it”— a lie; neither Alexander nor Seawright invested their own money in
the fund—“our neighbors, lots of physicians, many of the attorneys at Baker Donelson and other
firms, a United States Senator etc.”
76. Alexander was a persistent salesman. His pitch varied slightly depending on his
audience—for some investors the minimum was $25,000; for others, $50,000—but he always
promised a “rock stable” and “oversecured” 10% return, in a fund “safe enough for friends and
21
family.” If an investor said he could invest “either 25k or 30,” Alexander responded “$50k would
be better for you . . . The more you get in circulation, the more you can compound each quarter.”
77. If a potential investor was noncommittal Alexander applied pressure. He told
investors the fund “sells out quick” and “is moving fast.” To one such person he texted: “[You]
need to invest in the timber fund. We have figured the math and can get you 14 percent fully
secured if you reinvest your principle [sic] and interest every quarter. It compounds like you
would not believe,” followed by, “Are you going to invest in this timber round? You need to put
your money to work. No pressure at all, just smart advice in this climate.”
78. Alexander and Seawright specifically targeted individuals who had recently sold
assets because they knew those individuals had money to invest. Such individuals included clients
for whom Baker Donelson had recently closed transactions.
Backed by Baker Donelson
79. Investors reasonably believed that their investment in Madison Timber, through
Alexander Seawright Timber Fund I, LLC, was backed and promoted by, and had been vetted by,
Baker Donelson.
80. Alexander and Seawright relied heavily on their affiliation with Baker Donelson in
securing investments. Alexander and Seawright described the fund to potential investors who were
clients of Baker Donelson as a fund for preferred Baker Donelson clients and partners.
81. Alexander and Seawright referred potential investors to Baker Donelson’s website,
which shows that Jon Seawright is not merely a shareholder in Baker Donelson’s Jackson office
but an elected member of the firm’s national governing Board of Directors. Baker Donelson is a
law firm, not an investment advisory firm, but its website touts Jon Seawright’s advanced degree
in taxation and “extensive experience” in business development and capital formation. Its website
22
presents Brent Alexander as a “Senior Public Policy Advisor” who is qualified by regulators to
serve as a principal in, or advisor to, hedge funds and who has a “rapidly growing” practice in
“advising venture capital and related investors.”
82. Baker Donelson knew Alexander and Seawright relied on their affiliation with
Baker Donelson in securing investments and allowed it.
83. Alexander and Seawright used Baker Donelson’s Jackson office’s address for
official business. They and Adams held “closings” at Baker Donelson’s Jackson office. They used
Baker Donelson’s runners to pick up investors’ checks.
84. Alexander and Seawright enlisted their colleagues at Baker Donelson, including in
offices in other states, to introduce them to potential investors. They asked their colleagues to
“[h]elp us get a meeting if you’re able,” adding “[i]f you can get us in the door, it would mean a
great deal.” Their colleagues obliged.
Easy money
85. Investors were led to believe that they could rely on Alexander and Seawright to
evaluate each investment using their professional expertise and judgment, which was backed by
Baker Donelson’s reputation. In fact Alexander and Seawright undertook no meaningful
evaluation of the investments they pushed on unwitting persons, including Baker Donelson’s
clients. At the beginning of their partnership with Adams, Seawright asked questions such as
“Who bears the loss with respect to the destruction of timber? For example, if there is fire, beetles,
hurricane, whatever, who is on the hook? Is it an insured risk?” But he accepted Adams’s answers
to his questions without follow-up. Adams told Seawright that Madison Timber had “umbrella
[insurance] on all tracts” (he added, “Expensive, don’t need it but have it”). Seawright never asked
to inspect the insurance, which did not exist.
23
86. Investors were led to believe that Alexander and Seawright personally inspected
the timber underlying each investment. Of course they did not. Alexander and Seawright gave
investors “Equity Term Sheets” that described each upcoming investment opportunity. An
“Equity Term Sheet” dated March 5, 2017, for instance, explained that for the “minimum
investment” of $25,000, an investor would share in the “cutting rights on tracts of land in various
counties (the ‘Timber Rights’).” Like all of Alexander and Seawright’s “Equity Term Sheets,” the
“Equity Term Sheet” dated March 5, 2017, expressly represented that Alexander and Seawright
would personally inspect the property in question:
Company [Alexander and Seawright] will inspect the property related to the
Timber Rights, must receive the original, executed Note and timber deed and will
inspect the executed agreement(s) with the timber mill(s).
Alexander and Seawright could not and did not inspect the property in question—nor “the
executed agreement(s) with the timber mill(s)”—because such did not exist. These representations
were patently false.
87. Alexander and Seawright even devised a “Timber Rights Investment Closing
Checklist” that included among its list of things to do “Review Mill Contract” and “Review Land
re Timber.” Alexander and Seawright could not and did not review any “Mill Contract” or “Land
re Timber” because there was no “Mill Contract” or “Land re Timber” to review.
88. On information and belief, Alexander and Seawright “inspected” a purported
timber tract only once or twice, at the very inception of their partnership with Adams. The
“inspection” was hardly professional. Email traffic indicates “inspection” meant “[grab] a cooler
of beer and make a loop.”
24
89. Between 2011 and April 2018, Alexander and Seawright withdrew over $980,000
from the Alexander Seawright Timber Fund I, representing their “shares” of investors’ returns. In
addition Adams separately paid them over $600,000 representing undisclosed “birddog fees.”
90. On information and belief, Adams also sometimes paid Alexander and Seawright
bonuses, including Christmas bonuses in cash that he had delivered to Alexander and Seawright at
their Baker Donelson office.
91. For all this time, Alexander and Seawright acted as unlicensed brokers, in violation
of federal and state law. A broker is “any person engaged in the business of effecting transactions
in securities for the account of others.” See Section 3(4) of the Securities Exchange Act of 1934, 15
U.S.C. § 78c. The S.E.C.’s public website states that the receipt of transaction-related
commissions is a key indicator that a broker must be registered.12 A recent search using the
Financial Industry Regulatory Authority’s public online BrokerCheck confirms that neither
Alexander nor Seawright have ever registered with the S.E.C.
92. Investors might fairly question what Alexander and Seawright did to investigate the
investment. The reality is not much. In October 2017, Alexander bragged to a potential investor
that “to our surprise, we have now financed the purchase of about $60 million in timber . . . It has
worked so well that we simply send out an email on the 15th of each month and some hours later
have collected the investment we need for the next round.”
93. Neither Alexander nor Seawright, nor anyone at Baker Donelson, conducted an
even cursory inspection of Madison Timber’s operations. If they had, they would have realized
what should have been obvious—that the money was too good to be true because Madison Timber
12
Guide to Broker-Dealer Registration, U.S. SECURITIES & EXCHANGE COMMISSION https://www.sec.gov/reports
pubs/investor-publications/divisionsmarketregbdguidehtm.html
25
was nothing more than a Ponzi scheme. Instead, they aided and abetted Madison Timber’s growth,
providing Adams and Madison Timber their influence and their clients.
Red flags
94. Not only did Alexander and Seawright and Baker Donelson fail to independently
confirm that the timber and rights in question were real, they recklessly ignored numerous red
flags.
95. The timber deeds and cutting agreements between landowners and Madison
Timber were fake. The landowners’ signatures, forged by Adams, often looked the same. A call to
any one of the hundreds of purported landowners, or a simple check of the title for any one of the
hundreds of purported tracts of land, would have confirmed the truth. Neither Alexander nor
Seawright, nor anyone at Baker Donelson, ever called a landowner or checked a tract’s title.
96. Madison Timber also had no real contracts with any mills. A call to any one of the
mills for which Madison Timber purported to have contracts would have confirmed the truth.
Neither Alexander nor Seawright, nor anyone at Baker Donelson, ever called a mill.
97. Adams required that an investor agree that he or she would not record the deed by
which Madison Timber purported to grant its own rights to the investor unless and until Madison
Timber failed to make a payment due under the promissory note. Seawright quipped that “I have
been clear that I am no timber expert”—but he is unquestionably a lawyer to whom his clients and
investors looked to evaluate the investment’s risks. Incredibly, notwithstanding the suspicious
“agreement not to record,” neither Alexander nor Seawright, nor anyone at Baker Donelson,
questioned this requirement.
98. The “profit” that Adams promised was 300% to 400% better than that payable by
any other fully collateralized investment and was uniform and consistent. This fact should have
26
been a glaring warning sign but Alexander, who Baker Donelson presents as a qualified and
experienced advisor, turned this warning sign into a selling point. Alexander bragged about his
“six year perfect track record” of consistent uniform returns under his “beautiful, albeit simple,
financial model.”
99. Adams purported to have identified mills with an insatiable demand for timber at
uniform prices. The market price for timber is readily available from multiple sources, and any one
of those sources would have confirmed that the market price for timber actually rises and falls,
sometimes dramatically, over short periods of time. Neither Alexander nor Seawright, nor anyone
at Baker Donelson, ever evaluated the investment in light of such information. To the contrary,
Seawright gloated that “[Adams] has stated that volume is not problem and indicates there are
enough opportunities for him to soak up as much capital as we can raise.”
100. In 2014 Adams decided that he did not want to have to manage Madison Timber
during the month of December. He told his “bird dogs,” including Alexander and Seawright, that
Madison Timber would not issue checks in December going forward; what had been a 12-month
payoff would become a 13-month payoff, skipping the last month of the year. Seawright blindly
passed on to investors the dubious explanation that mills shut down in December for OSHA
inspections:
In December 2014, we were notified that the mills intended to shut down
operations in December to allow a break for the holidays and complete OSHA
required inspections. With their operations down, they requested that no payment
be made in December. The broker we worked with agreed to this, but on the
condition that the interest rate is increased by 1%, which they agreed to. This
increase is passed on to investors, so now all rounds pay out in 12 payments over 13
months, with a total interest of 13%. The result is the annual effective interest rate
increased to 10.15%, so while the payments are stretched out by a month, the
interest rate is better.
27
Neither Alexander nor Seawright, nor anyone at Baker Donelson, did anything to verify this false
information.
Alexander Seawright Timber Fund II
101. In 2015 Alexander and Seawright had an idea. They had been making monthly
investments with Adams of between $100,000 and $500,000 using other people’s money.
Alexander proposed that “[we] systemize this a little and take it to the next level.” Over the next
two years Alexander and Seawright would brainstorm a new model that could make Alexander
and Seawright rich. Alexander estimated that if a fund put $1 million in Madison Timber and then
reinvested the principal and interest each month for ten years it would make $17 to $18 million.
What if the fund put $10 million in?
102. The idea consumed Alexander. He texted Seawright, “Woke at [sic] at 2 thinking
about the structure of the timber pool. We pull this off, we get rich.” Using Baker Donelson’s
conference rooms and resources, he hosted meetings with and made presentations to accountants,
investors, and advisors to push his idea and debate the merits of a five-year versus ten-year model.
He reported the models gave people “much more level headed” than he “an orgasm as to its
potential.” Fearing that “now that they have seen up our skirts” people will “try to cut us out,” he
had prospective partners execute a non-disclosure agreement that Seawright drafted.
103. Alexander and Seawright gave their new model a new company and named it
Alexander Seawright Timber Fund II, LLC. They made a pitchbook for prospective investors. As
always, in it they emphasized their affiliation with Baker Donelson:
Brent Alexander is a senior public policy advisor at Baker, Donelson, Bearman,

Caldwell and Berkowitz (“Baker Donelson”) one of the nation’s largest law firms.
He provides strategic business consulting for the firm’s clients and serves as a
national recognized lobbyist both regionally and federally. . . .
28
Jon Seawright is a senior shareholder at Baker Donelson and a member of the

firm’s Board of Directors. Seawright has been deemed by peer-reviewed Super
Lawyers as a Rising Star, as well as one of the nation’s top attorneys, and represents
a range of national and regional clients, specializing in complex business
transactions, mergers and acquisitions and taxation. . . .
104. The 15-page pitchbook extolled the “elegant, simple and highly profitable” model
by which Alexander and Seawright had already “invest[ed] more than $20 million to facilitate the
purchase of over $50 million in timber.” The pitchbook falsely represented that an investment
would be “over-secured” and the timber would be “insured.” The pitchbook called the opportunity
to compound both principal and interest in the new fund “a nice trick indeed”:
Similar in almost all respects in operation to Alexander Seawright Timber Fund I,

Alexander Seawright Timber Fund II will use a pool of dedicated funds to allow
Alexander Seawright, not individual investors, the authority to systematically
control the reinvestment of all of the returned principal and interest in each
subsequent round of the fund. This will dramatically increase returns without
increasing risk.
On a fully secured investment.
This is a nice trick indeed.
105. The feedback was not all good. One prospective investor observed that Alexander
and Seawright could count “the respect we have for Baker” “to the good”—but the investment
presented at least ten concrete concerns, the first of which he called the “John Grisham novel
problem”:
To the concerning . . .
1. The structure seems very difficult – bordering on uninvestable in its current form
– for institutional managers, which is to say those managing money for others. Were
this to go bad in any way, there’s a beginning to a John Grisham novel problem here:
two lawyers drove up from Jackson, MS, to Memphis, TN, to pitch yield hungry
investors on a double digit, nearly riskless opportunity. The opportunity was
unaudited, and the lawyers did the tax work. . . .
But Alexander brushed off the criticism. (“I’m not sure he is a particularly artful or cogent writer,”
he told Seawright.)
29
106. The same prospective investor questioned why Alexander and Seawright
themselves were not invested in their own fund. “Your interest in the incentive is noteworthy, but,
it is derived from sweat, not money you stand to lose,” he wrote. Alexander replied, “We do have
skin in the game, at least in the way we characterize it”:
We do have skin in the game, at least in the way we characterize it, in that we have
fronted the expenses for the design, implementation, operation and management of
Alexander Timber Fund I, with little direct compensation because we knew that if
we were successful in building a track record, the opportunity to create a larger fund
would follow. . . . [O]ur incentives under this model are perfectly aligned with our
investors. If they don’t make money, we really don’t make money. That’s about the
best we can do.
What Alexander’s reply did not acknowledge was the obvious: Investors stood to lose their own
money, but Alexander and Seawright did not.
107. The same prospective investor pressed Alexander and Seawright on the question of
“margin”—that is, how did their broker (Adams) guarantee such uniform and consistent profits?
He asked “what are we missing to understand here that a broker exists which [sic] such large
spreads/ margins?”:
Gents – in doing some research on this strategy, I spoke to a friend who is more
familiar with timber. I described the model this opportunity works under, which
was foreign to him. What he is used to seeing is the forester working as an agent of
the landowner, where the forester is incented by receiving (if they are really good)
5-10% of the sales price. In this model, the forester markets the timber directly to
the mills and, in some cases, literally opens the bids up in front of everyone. Both
the concept of a broker and the 30ish % margins discussed seemed unfamiliar (and
this is a very experienced guy).
Notwithstanding this meaningful input, neither Alexander nor Seawright, nor anyone at Baker
Donelson, did anything to slow things down, nor even made a cursory analysis of their and
Adams’s business.
108. Instead Alexander and Seawright speeded things up with more forceful
presentations. They now argued Alexander Seawright Timber Fund II, LLC was for investors
30
“with brains and balls.” Meanwhile they continued to invest other people’s money in Alexander
Seawright Timber Fund I, LLC.
109. In late 2017, Alexander and Seawright finally secured a “key investor” to “seed”
Alexander Seawright Timber Fund II, LLC with $6 million. Alexander wanted $12 million to start
but figured he would raise the remaining $6 million by “bootstrapping.” Eventually he hoped “to
raise an additional $36 [million] over the life of the fund and let it roll for ten years.”
110. The “key investor” was a Baker Donelson client who would fund his investment
with the proceeds from the sale of a major asset. Seawright represented him in the sale. Alexander
told him, “I think you know us well enough to trust us, and if anything were ever go wrong, the
fund would simply unwind, at a profit.” He continued:
As you know, we are extremely confident in the model which is why we are
investing and reinvesting our earnings along with you under the same conditions.
Every deal has risk, but the only way that the numbers would be affected would be
if we for some reason could not close the rounds on a monthly basis (and I am very
confident we will). . . .
The purchase from the timber owner and the sale to the mill are executed
simultaneously Remember on the sale, we are over-secured by 50 percent. We put
up half the money, but have rights to the entire tract of timber. So, that gives us a
lot of margin to sell to someone else should there be a default. We have never
experienced a default, but we have a lot of wiggle room should one occur.
111. Anticipating their launch, Alexander and Seawright opened a new bank account for
Alexander Seawright Timber Fund II, LLC. Alexander wrote Adams to advise that starting May 1,
2018, they would “start deploying at $1 million a month beginning May 1”:
[W]e have a signed commitment for $6 million that we plan to start deploying at $1
million a month beginning May 1. . . . [I]t is safe to assume that we will invest $1
million an month increasing to $1.5 million a month. . . . Also, this investment,
which will be made under Alexander Seawright Timber Fund II, will be in addition
to the on-going investment in Alexander Seawright Timber Fund I, so plan on an
average of about $350,000 -$500,000 per month in Alexander Seawright Timber
Fund I. We are excited about the opportunity to provide a regular, consistent and
31
predictable volume of capital to your company and look forward to growing in

cooperation with you over the next 5 years.
112. Just days before Alexander and Seawright would have deployed their “key
investor” and client’s money, Adams turned himself in. As news spread, the investor sought
information from Alexander. Alexander told the investor that Alexander and Seawright were
victims:
Investor: How did you get hooked with him?

Alexander: My clients are hanging with me. They know I am a victim.
Investor: To think I was almost out of my entire life earnings makes me shiver
Alexander: Everyone knew him. Country club fixture.
Alexander: Would not let you lose your savings.
Investor: Man it was close . . . a day or two . . .
***
Alexander: To be clear, Jon and I were the victims of fraud.
CAUSES OF ACTION
COUNT I
FOR CIVIL CONSPIRACY
113. The Receiver re-alleges each of the foregoing paragraphs as though stated fully
herein.
114. Mississippi law defines a civil conspiracy as a “combination of persons for the
purpose of accomplishing an unlawful purpose or a lawful purpose unlawfully.” Shaw v.
Burchfield, 481 So. 2d 247, 255 (Miss. 1985).
115. Defendants conspired with Adams to commit the tortious acts alleged in this
complaint.
116. Defendants agreed to assist Adams by recruiting new investors to Madison Timber.
32
117. Madison Timber was a Ponzi scheme; therefore Defendants and Adams’s purpose
was unlawful.
118. In addition, Defendants acted unlawfully. Defendants were unlicensed brokers of
securities, in violation of federal and state law. The securities that Defendants sold were not
exempt from registration but were unregistered, in violation of federal and state law.
119. In furtherance of their unlawful purpose, among other overt acts, Defendants
pitched Madison Timber to potential investors, including their clients; consummated sales of
Madison Timber to investors; and received commissions from Adams for their assistance in
growing Madison Timber’s business.
120. Defendants need not have known that Madison Timber was a Ponzi scheme to
unlawfully conspire with Adams. Nevertheless, in view of the numerous red flags described in this
complaint, Defendants knew or should have known that Madison Timber was a Ponzi scheme.
121. Numerous red flags notwithstanding, Defendants lent their influence, their
professional expertise, and even their clients to Adams. They made a fraudulent enterprise a
fraternity. Madison Timber grew from an approximately $10 million-a-year Ponzi scheme in 2011
to an approximately $164.5 million-a-year Ponzi scheme as of April 19, 2018.
122. Defendants were essential to the growth of the Madison Timber Ponzi scheme. But
for Defendants’ encouragement and assistance, Madison Timber would not have continuously
grown—it would have failed before ensnaring hundreds of new unwitting investors.
123. Defendants contributed to Madison Timber’s success over time, and therefore to
the Receivership Estate’s liabilities today. Defendants and Adams’s civil conspiracy is a
proximate cause of the debts of the Receivership Estate.
33
124. Defendants are jointly and severally liable for the debts of the Receivership Estate,
which their and Adams’s civil conspiracy proximately caused.
125. Because Defendants acted with reckless disregard of the wellbeing of others, and in
specific instances described in this complaint committed actual fraud, punitive damages are
appropriate.
COUNT II
FOR AIDING AND ABETTING
herein.
127. The Restatement (Second) of Torts § 876(b) (1979) provides that a defendant is
liable if he “knows that the other’s conduct constitutes a breach of duty and gives substantial
assistance or encouragement to the other so to conduct himself.” Stated differently, a defendant is
liable for aiding and abetting the wrongful conduct of another.
128. Defendants aided and abetted Adams in committing breaches of duties owed by
Adams to Madison Timber and in other tortious conduct alleged in this complaint.
129. In view of the numerous red flags described in this complaint, Defendants knew or
should have known that Madison Timber was a Ponzi scheme.
130. Numerous red flags notwithstanding, Defendants gave substantial assistance and
encouragement to Adams. Defendants lent their influence, their professional expertise, and even
their clients to Adams. They made a fraudulent enterprise a fraternity. Madison Timber grew from
an approximately $10 million-a-year Ponzi scheme in 2011 to an approximately $164.5
million-a-year Ponzi scheme as of April 19, 2018.
34
131. Defendants were essential to the growth of the Madison Timber Ponzi scheme. But
for Defendants’ substantial assistance and encouragement, Madison Timber would not have
continuously grown—it would have failed before ensnaring hundreds of new unwitting investors.
132. Defendants contributed to Madison Timber’s success over time, and therefore to
the Receivership Estate’s liabilities today. Defendants’ substantial assistance and encouragement
is a proximate cause of the debts of the Receivership Estate.
133. Defendants are jointly and severally liable for the debts of the Receivership Estate,
which their substantial assistance and encouragement proximately caused.
134. Because Defendants acted with reckless disregard of the wellbeing of others, and in
specific instances described in this complaint committed actual fraud, punitive damages are
appropriate.
COUNT III
FOR RECKLESSNESS, GROSS NEGLIGENCE, AND AT A MINIMUM NEGLIGENCE
herein.
136. “Negligence is a failure to do what the reasonable person would do under the same
or similar circumstances.” Estate of St. Martin v. Hixson, 145 So. 3d 1124, 1128 (Miss. 2014).
137. While negligence is the failure to exercise due care, recklessness “is a failure or
refusal to exercise any care.” Maldonado v. Kelly, 768 So. 2d 906, 910 (Miss. 2000).
138. Defendants were in advantageous positions to discover Adams’s fraud. In view of
the numerous red flags described in this complaint, a reasonable person in the same or similar
circumstances would have discovered Adams’s fraud.
35
139. Defendants not only failed to exercise due care, they failed or refused to exercise
any care at all in their dealings with Adams.
140. Defendants’ recklessness, or at a minimum negligence, allowed Madison Timber to
continuously grow. Madison Timber grew from an approximately $10 million-a-year Ponzi
scheme in 2011 to an approximately $164.5 million-a-year Ponzi scheme as of April 19, 2018.
141. But for Defendants’ recklessness, or at a minimum negligence, Madison Timber
would not have continuously grown—it would have failed before ensnaring hundreds of new
unwitting investors.
142. Defendants by their recklessness, or at a minimum negligence, contributed to
Madison Timber’s success over time, and therefore to the Receivership Estate’s liabilities today.
Defendants’ recklessness, or at a minimum negligence, is a proximate cause of the debts of the
Receivership Estate.
143. Defendants are liable for the debts of the Receivership Estate, which their
recklessness, or at a minimum negligence, proximately caused.
144. Because Defendants acted with gross negligence evincing a reckless disregard of
the wellbeing of others, punitive damages are appropriate.
COUNT IV
FOR VIOLATIONS OF MISSISSIPPI’S FRAUDULENT TRANSFER ACT
herein.
146. The Receiver may avoid any transfer made in violation of the Mississippi Uniform
Fraudulent Transfer Act (the “Act”), MISS. CODE ANN. §15-3-101, et seq.
36
147. Pursuant to § 107 of the Act, the Receiver may recover from any party any funds
that Madison Timber transferred with the actual intent to hinder, delay, or defraud any of its
creditors. Because Madison Timber was a Ponzi scheme, by definition all transfers by Madison
Timber were made with the actual intent to hinder, delay, or defraud its creditors.
148. The Receiver is entitled to avoid all “commissions,” fees, and other such payments
paid by Adams or Madison Timber to Defendants Butler Snow Advisory, Thornton, Alexander
Seawright, Alexander, and Seawright, and to the entry of a judgment against Defendants Butler
Snow Advisory, Thornton, Alexander Seawright, Alexander, and Seawright for the amount of all
such monies received by them.
149. Alternatively, the Receiver is entitled to recover all monies paid to Defendants
Butler Snow Advisory, Thornton, Alexander Seawright, Alexander, and Seawright because
(i) Madison Timber was insolvent when it paid those commissions because its net liabilities far
exceeded the value of its (nonexistent) assets and (ii) Madison Timber received no value for the
commissions paid to Defendants Butler Snow Advisory, Thornton, Alexander Seawright,
Alexander, and Seawright.
COUNT V
FOR VIOLATIONS OF MISSISSIPPI’S RACKETEER INFLUENCED
AND CORRUPT ORGANIZATION ACT
herein.
37
151. Mississippi’s RICO statute provides: “It shall be unlawful for any person to
conduct, organize, supervise or manage, directly or indirectly, an organized theft or fraud
enterprise.” MISS. CODE ANN. § 97-43-3.1.
152. Madison Timber was a “fraud enterprise” within the meaning of Mississippi’s
RICO statute because “fraud enterprise” includes one conducted by “mail or other means of
communication,” MISS. CODE ANN. § 97-43-3.1, and Adams was convicted of wire fraud.
153. Mississippi’s RICO statute further provides: “It is unlawful for any person
employed by, or associated with, any enterprise to conduct or participate, directly or indirectly, in
such enterprise through a pattern of racketeering activity. . . .” MISS. CODE ANN. § 97-43-5
(emphasis added). “‘Racketeering activity’ means to commit, to attempt to commit, to conspire to
commit . . . any crime which is chargeable under [Mississippi’s RICO statute],” MISS. CODE ANN.
§ 97-43-3, including wire fraud.
154. Defendants Butler Snow Advisory, Thornton, Alexander Seawright, Alexander,
and Seawright participated, directly or indirectly, in the Madison Timber “fraud enterprise.”
155. Their participation allowed the Madison Timber “fraud enterprise” to continuously
grow. Madison Timber grew from an approximately $10 million-a-year Ponzi scheme in 2011 to
an approximately $164.5 million-a-year Ponzi scheme as of April 19, 2018.
156. But for their participation, the Madison Timber “fraud enterprise” would not have
continuously grown—it would have failed before ensnaring hundreds of new unwitting investors.
157. By their participation, they contributed to Madison Timber’s success over time, and
therefore to the Receivership Estate’s liabilities today. Their participation is a proximate cause of
the debts of the Receivership Estate.
38
158. Defendants Butler Snow Advisory, Thornton, Alexander Seawright, Alexander,
and Seawright therefore are liable for “threefold the actual damages sustained” by the
Receivership Estate, punitive damages, and attorneys’ fees.
COUNT VI
FOR JOINT VENTURE LIABILITY
AGAINST ALEXANDER SEAWRIGHT, ALEXANDER, AND SEAWRIGHT
herein.
160. “[A] joint venture can be defined as a single purpose partnership.” Duggins v.
Guardianship of Washington ex rel. Huntley, 632 So. 2d 420, 427 (Miss. 1993). “Profit sharing is
the most important factor in determining whether a joint venture exists.” Walker v. Williamson,
131 F. Supp. 3d 580, 591 (S.D. Miss. 2015). “Where a joint venture exists, its members are bound
by the acts of the other members acting in the course and scope of the joint venture.” Braddock
Law Firm, PLLC v. Becnel, 949 So. 2d 38, 50 (Miss. Ct. App. 2006).
161. Defendants Alexander Seawright, Alexander, and Seawright formed a joint venture
with Adams and Madison Timber, as evidenced by their stated intent to form a fund to invest other
people’s money in Madison Timber and to split the “profits” with Adams.
162. Defendants Alexander Seawright, Alexander, and Seawright did invest other
people’s money in Madison Timber and did split the “profits” with Adams.
163. As Adams and Madison Timber’s joint venturers, Defendants Alexander
Seawright, Alexander, and Seawright are liable for debts incurred within the scope of their joint
venture, which was still ongoing on April 19, 2018, the date Adams turned himself in.
39
164. Defendants Alexander Seawright, Alexander, and Seawright therefore are jointly
and severally liable for the debts of the Receivership Estate.
COUNT VII
FOR ATTORNEY MALPRACTICE
AGAINST BUTLER SNOW
herein.
166. “Lawyers owe their clients a duty to protect them from liability in every possible
way.” Official Stanford Inv’rs Comm. v. Greenberg Traurig, LLP, No. 3:12-cv-4641, 2014 WL
12572881, *3 (N.D. Tex. Dec. 17, 2014).
167. Adams and Madison Timber had a lawyer-client relationship with Defendant
Butler Snow. Adams twice engaged Defendant Butler Snow to draft a private placement
memorandum, or PPM, for Madison Timber.
168. The PPMs drafted by Defendant Butler Snow contained numerous false and
misleading statements, including but not limited to those described in this complaint, regarding
Madison Timber’s “Business Strategy” and “Timber Investment Risks.”
169. In view of the numerous red flags described in this complaint, a reasonable lawyer
in the same or similar circumstances would have discovered Adams’s fraud.
170. Defendant Butler Snow not only failed to exercise due care, it failed or refused to
exercise any care at all in its dealings with Adams. Defendant Butler Snow was not merely
negligent, but reckless, in its handling of legal affairs to which it was entrusted.
171. Although no investor chose to invest in the funds for which the PPMs were drafted,
many relied on the PPMs in choosing to invest in purported “standing tracts” only.
40
172. Defendant Butler Snow’s recklessness, or at a minimum negligence, allowed
Madison Timber to continuously grow. Madison Timber grew from an approximately $10
million-a-year Ponzi scheme in 2011 to an approximately $164.5 million-a-year Ponzi scheme as
of April 19, 2018.
173. But for Defendant Butler Snow’s recklessness, or at a minimum negligence,
Madison Timber would not have continuously grown—it would have failed before ensnaring
hundreds of new unwitting investors.
174. Defendant Butler Snow by its recklessness, or at a minimum negligence,
contributed to Madison Timber’s success over time, and therefore to the Receivership Estate’s
liabilities today. Defendant Butler Snow’s recklessness, or at a minimum negligence, is a
proximate cause of the debts of the Receivership Estate.
175. Defendant Butler Snow is liable for the debts of the Receivership Estate, which its
recklessness, or at a minimum negligence, proximately caused.
176. Because Defendant Butler Snow acted with gross negligence evincing a reckless
disregard of the wellbeing of others, punitive damages are appropriate.
COUNT VIII
FOR NEGLIGENT RETENTION AND SUPERVISION
AGAINST BUTLER SNOW AND BAKER DONELSON
herein.
178. “[A]n employer will be liable for negligent hiring or retention of his employee
when an employee injures a third party if the employer knew or should have known of the
41
employee’s incompetence or unfitness.” Backstrom v. Briar Hill Baptist Church, Inc., 184 So. 3d
323, 327 (Miss. Ct. App. 2016).
179. Agents of Defendants Butler Snow and Baker Donelson agreed to assist Adams by
recruiting new investors to Madison Timber, thereby acting as unlicensed brokers of securities, in
violation of federal and state law.
180. In view of the numerous red flags described in this complaint, Defendants Butler
Snow and Baker Donelson knew or should have known of their agents’ incompetence or unfitness.
181. Defendants Butler Snow and Baker Donelson were reckless, or at a minimum
negligent, in retaining their agents and failing to supervise their agents’ dealings.
182. Defendants Butler Snow and Baker Donelson’s recklessness, or at a minimum
negligence, allowed Madison Timber to continuously grow. Madison Timber grew from an
approximately $10 million Ponzi scheme in 2011 to an approximately $164.5 million Ponzi
scheme on April 19, 2018.
183. But for Defendants Butler Snow and Baker Donelson’s recklessness, or at a
minimum negligence, Madison Timber would not have continuously grown—it would have failed
before ensnaring hundreds of new unwitting investors.
184. Defendants Butler Snow and Baker Donelson, by their recklessness, or at a
minimum negligence, contributed to Madison Timber’s success over time, and therefore to the
Receivership Estate’s liabilities today. Defendants Butler Snow and Baker Donelson’s
recklessness, or at a minimum negligence, is a proximate cause of the debts of the Receivership
Estate.
185. Defendants Butler Snow and Baker Donelson are liable for the debts of the
Receivership Estate, which their recklessness, or at a minimum negligence, proximately caused.
42
186. Because Defendants Butler Snow and Baker Donelson acted with gross negligence
evincing a reckless disregard of the wellbeing of others, punitive damages are appropriate.
LIABILITY OF BUTLER SNOW

FOR BUTLER SNOW ADVISORY
187. Defendant Butler Snow is liable for the acts of Butler Snow Advisory, and
therefore the acts of Thornton and Billings, because Defendant Butler Snow authorized or directed
those acts; had knowledge of, or gave consent to, those acts; or acquiesced in those acts when it
knew or should have known that it should have taken steps to prevent them.
188. Defendant Butler Snow is liable for the acts of Butler Snow Advisory because the
two effectively operate as a single business enterprise, and Butler Snow and Butler Snow Advisory
are alter egos.
189. The Receiver is entitled to a declaratory judgment holding, inter alia, that
Defendant Butler Snow is liable for payment of all damages or other relief awarded in favor of the
Receiver and against Defendant Butler Snow Advisory.
LIABILITY OF ALEXANDER AND SEAWRIGHT

FOR ALEXANDER SEAWRIGHT
190. Defendants Alexander and Seawright are liable for the acts of Alexander Seawright
because they authorized or directed all acts of Alexander Seawright.
191. Defendants Alexander and Seawright are liable for the acts of Alexander Seawright
because the three are alter egos.
Defendants Alexander and Seawright are personally liable for payment of all damages or other
relief awarded in favor of the Receiver and against Defendant Alexander Seawright.
43
BUTLER SNOW’S AND BAKER DONELSON’S VICARIOUS LIABILITY
193. The apparent backing of Defendants Butler Snow and Baker Donelson enabled
Thornton and Billings, and separately Alexander and Seawright, respectively, to recruit new
investors to Madison Timber. Defendants Butler Snow and Baker Donelson are liable for the
negligent and reckless acts of their agents, including but not limited to Thornton and Billings, and
Alexander and Seawright, respectively.
Defendant Butler Snow is liable for payment of all damages or other relief awarded in favor of the
Receiver and against Defendants Butler Snow Advisory and Thornton, and that Defendant Baker
Donelson is liable for payment of all damages or other relief awarded in favor of the Receiver and
against Defendants Alexander and Seawright.
___________________
WHEREFORE, the Receiver respectfully requests that, after due proceedings, the Court
enter judgments:
1. awarding damages in her favor and against Butler Snow LLP;

Butler Snow Advisory Services, LLC; Matt Thornton; Baker,
Donelson, Bearman, Caldwell & Berkowitz, PC; Alexander
Seawright, LLC; Brent Alexander; and Jon Seawright, jointly
and severally;
2. awarding any and all attorney’s fees, costs, and interest

allowed by contract or law; and
3. awarding any and all other relief as may be just and equitable.
44
December 19, 2018

/s/ Lilli Evans Bass /s/ Brent B. Barriere

BROWN BASS & JETER, PLLC FISHMAN HAYGOOD, LLP
Lilli Evans Bass, Miss. Bar No. 102896 Admission pro hac vice pending
LaToya T. Jeter, Miss. Bar No. 102213 Brent B. Barriere, Primary Counsel
1755 Lelia Drive, Suite 400 Jason W. Burge
Jackson, Mississippi 39216 Kristen D. Amond
Tel: 601-487-8448 Rebekka C. Veith
Fax: 601-510-9934 201 St. Charles Avenue, Suite 4600
bass@bbjlawyers.com New Orleans, Louisiana 70170
Receiver’s counsel Tel: 504-586-5253
Fax: 504-586-5250
bbarriere@fishmanhaygood.com
jburge@fishmanhaygood.com
kamond@fishmanhaygood.com
rveith@fishmanhaygood.com
Receiver’s counsel
45

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Case 3:18-cv-00866-CWR-FKB Document 56 Filed 11/04/19 Page 1 of 3

IN THE UNITED STATES DISTRICT COURT

ALYSSON MILLS, IN HER CAPACITY PLAINTIFF

vs. CASE NO. 3:18-cv-866-CWR-FKB

BUTLER SNOW LLP; BUTLER SNOW DEFENDANTS

NOTICE OF SUGGESTION OF BANKRUPTCY

bankruptcy action is docketed as Case No. 19-03921.

judgment, order, or ruling entered in violation of the automatic stay.

bankruptcy, please contact Mr. Seawright’s bankruptcy counsel:

Dated: November 4, 2019.

ALEXANDER SEAWRIGHT, LLC; BRENT

By: /s/ Cody C. Bailey

R. David Kaufman (MSB #3526)

notification of such filing to all counsel of record and registered participants.

Dated: November 4, 2019.

/s/ Cody C. Bailey

Fill in this information to identify your case:

United States Bankruptcy Court for the:

SOUTHERN DISTRICT OF MISSISSIPPI

Case number (if known) Chapter you are filing under:

Official Form 101

Part 1: Identify Yourself

About Debtor 1: About Debtor 2 (Spouse Only in a Joint Case):

1. Your full name

Write the name that is on Jon

2. All other names you have

3. Only the last 4 digits of

Debtor 1 Jon Darrell Seawright Case number (if known)

About Debtor 1: About Debtor 2 (Spouse Only in a Joint Case):

4. Any business names and

Include trade names and Business name(s) Business name(s)

5. Where you live If Debtor 2 lives at a different address:

4247 Crane Boulevard

6. Why you are choosing Check one: Check one:

I have another reason. I have another reason.

Debtor 1 Jon Darrell Seawright Case number (if known)

Part 2: Tell the Court About Your Bankruptcy Case

9. Have you filed for No.

10. Are any bankruptcy No

11. Do you rent your No. Go to line 12.

Debtor 1 Jon Darrell Seawright Case number (if known)

Part 3: Report About Any Businesses You Own as a Sole Proprietor

12. Are you a sole proprietor

14. Do you own or have any No.

For example, do you own

Debtor 1 Jon Darrell Seawright Case number (if known)

Part 5: Explain Your Efforts to Receive a Briefing About Credit Counseling

About Debtor 1: About Debtor 2 (Spouse Only in a Joint Case):

Active duty. Active duty.

Debtor 1 Jon Darrell Seawright Case number (if known)

Part 6: Answer These Questions for Reporting Purposes

No. Go to line 16b.

Yes. Go to line 17.

18. How many Creditors do 1-49 1,000-5,000 25,001-50,000

Part 7: Sign Below

Executed on November 3, 2019 Executed on

Debtor 1 Jon Darrell Seawright Case number (if known)

R. Michael Bolen Miss. Bar 3615

Hood & Bolen, PLLC

Contact phone (601)923-0788 Email address rmb@hoodbolen.com

United States Bankruptcy Court

VERIFICATION OF CREDITOR MATRIX

Date: November 3, 2019 /s/ Jon Darrell Seawright

Fill in this information to identify your case: