Prison Phone Justice

IN THE CIRCUIT COURT OF RANKIN COUNTY, MISSISSIPPI

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r FEB -8 2017

JIM HOOD, ATTORNEY GENERAL OF
THE STATE OF MI~SISSIPPI, ex rel.
THE STATE OF MISSISSIPPI,
Plaintiff,

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v.
CIVIL ACTION NO.: ---'/_r_-_;;z_--"-']_ _
GLOBAL TEL*LINK
CORPORATION; CHRISTOPHER
B. EPPS; SAM WAGGONER and
DEFENDANT DOES 1 through 5,
Defendants.

COMPLAINT

COMES NOW, the Plaintiff, Jim Hood, Attorney General of the State of Mississippi, ex
rel. the State of Mississippi (hereinafter the "State" or "Plaintiff') and brings this cause of action

against Global Tel*Link Corporation (hereinafter "GTL"); Christopher B. Epps; Sam Waggoner
and Defendant Does I through 5 (collectively "Defendants"), and alleges as follows:
INTRODUCTION

1.

This action arises from one of the largest and longest-running criminal and civil

consprrac1es in Mississippi government history.

For approximately seven years, multiple

individuals and business entities, including one high-ranking government official, were involved
in a conspiracy, scheme and/or enterprise (hereinafter "conspiracy") that included bribery,
kickbacks, misrepresentations, fraud, concealment, money laundering and other wrongful
conduct-all with the intent to defraud and deprive the State of hundreds of millions of dollars in
proceeds from public contracts awarded by the Mississippi Department of Corrections
(hereinafter "MDOC") and paid for by the State. (See Exhibit "A" - indictment for United States

vs. Christopher B. Epps and Cecil McCrory; Exhibit "B" - indictment for United States vs. Carl
Reddix; Exhibit "C" - inforrp.ation for United States vs. Sam Waggoner; Exhibit "D" - indictment

for United States vs. lrb Benjamin; Exhibit "E" - information for United States vs. Mark
Longoria; Exhibit "F" - indictment for United States vs. Teresa Malone; Exhibit "G" -

indictment for United States vs. Guy E. "Butch" Evans; Exhibit "H" - information for United
States vs. Robert Simmons; and Exhibit I - indictment for United States vs. William Martin).

2.

During this time Defendant GTL, the largest provider of inmate telephone,

communications and payment systems in the United States, paid hundreds of thousands of
dollars in so-called "consulting fees" to Defendant Sam Waggoner, and through Waggoner these
fees were used to pay bribes and kickbacks to then-MDOC Commissioner Christopher B. Epps.
Because of these bribes and kickbacks, Commissioner Epps awarded, directed and/or extended
public contracts, paid for by the State, to Defendant GTL.
3.

This action seeks compensatory damages, punitive damages, civil penalties,

disgorgement of all ill-gotten funds, gains and profits, restitution, and all other appropriate relief
on behalf of the State, which bore the cost and suffered significant losses as a result of
Defendants' conspiratorial scheme. Defendants' actions restrained or restricted trade; artificially
fixed, raised and stabilized prices and denied free and open competition. Accordingly, this
action seeks all forms of relief available for each violation under applicable law.
4.

Attorney General Jim Hood brings this action on ·behalf of-the State in its

proprietary capacity, and on behalf of local governmental entities within the State, pursuant to
the Attorney General's authority under Miss. Code§§ 7-5-1, 75-21-1 et seq., 97-43-1 et seq. and
25-4-105. The State brings this action exclusively under the laws of Mississippi, and to the
extent any claim or factual assertion herein may be construed as stating a federal claim, the State

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disavows that claim. The claims asserted are brought solely by the State and are independent of
any claims that individual

~itizens

may have against Defendants. Accordingly, any attempt by

Defendants to remove this case to federal court would be without a basis in fact or law.
PARTIES

5.

The foregoing paragraphs are incorporated here by reference, as if set forth in full.

6.

Plaintiff, the State of Mississippi, is a body politic created by the Constitution and

laws of the State; as such, it is not a citizen of any state. Jim Hood is the State's duly-elected
Attorney General. The Attorney General brings this action on the State's behalf, pursuant to the
authority granted to his office by Miss. Const. art. 6, § 173 (1890) and by Miss. Code§ 7-5-1.
7.

Defendant Christopher B. Epps was the Commissioner of MDOC during all

relevant times in this action and is a resident citizen of Rankin County, MS. He is currently in
federal custody and awaits sentencing in 2017.
8.

Defendant Sam Waggoner is a businessman and resident citizen of Leake County,

MS, whose physical address is 2421 Red Dog Road, Carthage, MS 39051. He was sentenced to
60 months in federal prison and will begin serving his sentence in 2017.
9.

Defendant GTL is a Delaware corporation, with its principal place of business

located at 12021 Sunset Hills Road, Reston, VA 20190.

Service can be made to InCorp

Services, Inc. at 302 Enterprise Drive, Suite A, Oxford, MS 38655.
10.

Defendant Does 1 through 5 are individuals, corporations, limited liability

companies, partnerships or other entities that participated in the conspiracy. The identities of
these Defendants are unknown to the State until adequate discovery is allowed.

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JURISDICTION AND VENUE
11.

The foregoin_g paragraphs are incorporated here by reference, as if set forth in full.

12.

This Court has jurisdiction over the subject matter of this action pursuant to Miss.

Const. art. 6, § 156 (1890) and Miss. Code§ 9-7-81, because the amount in controversy exceeds
$200 and the subject matter is not exclusively cognizable in some other court.
13.

This Court has personal jurisdiction over those Defendants who are resident

citizens of Mississippi and over GTL because it has engaged in systematic and continuous
business activity in Mississippi, and because a substantial amount of its conspiratorial and
unlawful acts occurred in Mississippi and were intended to-and in fact did-cause substantial
harm to the State.
14.

This Court is the proper venue under Miss. Code § ll-ll-3(l)(a)(i), because

Defendant Christopher Epps resides in Rankin County, Mississippi and substantial acts and
omissions complained of herein occurred in Rankin County, Mississippi.
FACTS
15.

The foregoing paragraphs are incorporated here by reference, as if set forth in full.

16.

From approximately 2011through2014-Defendants Christopher B. Epps, Sam

Waggoner and GTL knowingly and intentionally conspired to devise schemes using overt acts
such as bribery, kickbacks, unfair and deceptive trade practices, misrepresentations, fraud,
concealment, money laundering, fraudulent use of "sole source" contracts when competitive
bidding was required and other wrongful conduct, all with the intended purpose, and effect, of
defrauding the State of at least $6,000,000.
17.

In essence, the scheme worked like this: then-Commissioner Epps, Waggoner and

GTL had a "backroom" relationship or agreement. GTL paid Waggoner $309,582 in so-called

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"consulting fees." Waggoner then paid a portion of those fees as bribes and kickbacks to Epps,
in exchange for MDOC

~warding

approximately $6,000,000 in public contracts to GTL.

Defendant GTL was a willful participant in the scheme insofar as it knew-had every reason to
know or should have known-that the money it was paying Waggoner was being used to pay
bribes and kickbacks to Epps for the purpose of obtaining and retaining public contracts.
Defendants' Scheme to Defraud the State

18.

Defendant Christopher B. Epps worked for MDOC for 32 years and was

appointed Commissioner of MDOC in 2002. As Commissioner, Epps was "responsible for the
management of affairs of the correctional system and for the proper care, treatment, feeding,
clothing and management of the offenders confined therein." Miss. Code§ 47-5-23.
19.

In December of 2005, GTL was awarded a public contract from the State to

provide inmate phone services to several MDOC facilities, including Mississippi State
Penitentiary, Central Mississippi Correctional Facility and South Mississippi Correctional
Facility.
20.

Subsequently, Defendant GTL sought to retain these public· contracts with the

State as it related to inmate phone services, by hiring Defendant Sam Waggoner as a so-called
"paid consultant" for GTL. (See Exhibit "C" at if 3).
21.

Then-Commissioner Epps and Defendant Waggoner entered into a "backroom"

relationship or agreement with Defendant GTL, pursuant to which GTL would pay Waggoner
"consulting fees" in the amount of five percent (5%) of all revenues generated by GTL's public
contracts, from which Waggoner would use these fees to pay Defendant Epps bribes and
kickbacks. (See Exhibit "C" at ifif 4 - 6).
22.

Epps received approximately $108,000 in bribes and kickbacks from the $309,582

in so-called "consulting fees" Defendant GTL paid Sam Waggoner.
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23.

During this time, then-Commissioner Epps awarded, directed and/or extended

public contracts, paid for by_ the State, to Defendant GTL totaling approximately $6,000,000.
24.

At all relevant times, Defendant Sam Waggoner was acting in the course and

scope of his employment and/or in furtherance of the interests of GTL. Defendant Waggoner
was an actual or apparent agent, acting with actual or apparent authority, on behalf of GTL.
Therefore, Defendant GTL is liable for the actions of Waggoner as an employee, statutory
employee or agent. Moreover, Defendant GTL and Waggoner pursued a common plan and
course of conduct, acted in concert with, aided and abetted and otherwise conspired with one
another, in furtherance of their common scheme to defraud the State.
25.

Defendant GTL knew, or should have known, that the "consulting fees" it was

paying Defendant Waggoner were being used to pay bribes and kickbacks to assure that
Defendant Epps would award and/or extend public contracts, paid for by the State, to GTL.
Criminal Charges and Guilty Pleas

26.

Epps resigned as Commissioner of MDOC on November 5, 2014, and the next

day he was indicted on federal charges for participating in the conspiracy described herein. He
pleaded guilty on February 4, 2015. (See Exhibit "J" - Plea Agreement for United States vs.
Christopher B. Epps).

27.

Defendant Waggoner was charged by information on August 19, 2015, on federal

charges for participating in the conspiracy described herein. He, too, pleaded guilty on August
21, 2015. (See Exhibit "K" - Plea Agreement for United States vs. Sam Waggoner).
Mississippi's Competitive Bidding Requirements

28.

Miss. Code § 31-7-13 sets forth the mandatory bidding requirements for State

purchases of $50,000 or more. It sets out broadly what purchases require competitive bidding
and narrowly what purchases are exceptions to that requirement.
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The purposes of the

Mississippi system of "competitive bidding" are to obtain the lowest price, to create a level
playing field for suppliers, and above all, to frustrate corrupt conspiracies.
29.

Contrary to Miss. Code § 31-7-13, Defendant Epps, as needed to benefit

Defendant GTL, made findings that exceptions to the "competitive bidding requirement" were
applicable to some or all of the contracts described herein, when in fact,_ there were no
circumstances justifying the award of "no-bid" contracts. In fact, multiple qualified contractors
would have been available to perform all of the services for which the "no-bid" contracts were
awarded to GTL. In truly competitive markets, vendors would have had to compete with many
potential rivals for the Mississippi contracts.
Proceeds Derived from Defendants' Conduct

30.

Defendants' conspiratorial scheme was successful. During this time, Defendant

GTL received approximately $6,000,000 in proceeds from public contracts paid for by the State.
31.

Defendants knew, or should have known, that they were participating in a

conspiracy to defraud the State, through the payment of "consulting fees" that were being used to
pay bribes and kickbacks to a State official in exchange for public contracts ("no-bid" I "sole
source procurement" or otherwise), awarded by MDOC, and paid for by the State.
32.

Moreover, by retaining Sam Waggoner as an agent to obtain these contracts,

Defendant GTL is liable not only for its own wrongful actions, but also for the wrongful actions
of its agent, Waggoner.

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CLAIMS FOR RELIEF
COUNT I
VIOLATIONS OF MISS. CODE§ 25-4-105
33.

The foregoing paragraphs are incorporated here by reference, as if set forth in full.

34.

At all relevant times, Defendant Epps was a "public servant" within the meaning

of Miss. Code§ 25-4-103(p)(i).
35.

Defendant Epps, while a public servant, "use[d] his official position to obtain, or

attempt to obtain, pecuniary benefit for hlli1self other than that compensation provided for by
law," in violation of Miss. Code§ 25-4-105(1).
36.

Defendant Epps, while a public servant, was "interested, directly or indirectly,

during the term for which he shall have been chosen ... in [several] contract[s] with the [S]tate,"
in violation of Miss. Code§ 25-4-105(2).
37.

Defendant Epps, while a public servant, performed services for "compensation

during his term of office or employment by which he attempt[ed] to influence decision[s] of the
authority ofthe_governmental entity of which he [wa]s a member," in violation of Miss. Code§
25-4-105(3)(d).
38.

Pursuant to Miss. Code § 25-4-113, the Attorney General is entitled to bring this

action "against the public servant or other person or business violating the provisions of this
article for recovery of damages suffered as a result of such violations."
39.

The Attorney General brings this action against Defendants Epps, Waggoner, and

GTL pursuant to Miss. Code §§ 25-4-105 and 25-4-113, and demands recovery of all money
paid by the State as a result of the aforesaid misconduct.
40.

Miss. Code § 25-4-113, provides that the State is entitled to a declaration by this

Court that all pecuniary benefits "received by" Defendant Epps, or "given by" Epps to the other
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Defendants, irrespective of actual damages, "shall be declared forfeited by a circuit court of
competent jurisdiction for the benefit of the governmental entity injured." The State demands
under said law, the forfeiture to the State of all money paid to Epps as alleged herein, and the
forfeiture to the State of all money (approximately $6,000,000) paid by the State to Defendant
GIL.
41.

Pursuant to Miss. Code§ 25-4-113, the State, at the discretion of the Court, may

also be awarded costs of court and reasonable attorneys' fees, and the State demands such costs
and fees from Defendants.
COUNT II
VIOLATIONS OF RACKETEER INFLUENCED
AND CORRUPT ORGANIZATION ACT

42.

The foregoing paragraphs are incorporated here by reference, as if set forth in full.

43.

At all relevant times, Defendants were or are an enterprise within the meaning of

Miss. Code§ 97-43-3(c).
44.

Beginning in 2011 and continuing through 2014, the exact dates being as yet

unknown, Defendants associated together to establish a criminal partnership with the common
goal of circumventing State laws on competitive bidding and trading cash for State contracts.
Defendants accomplished this goal through a pattern of racketeering activity, in violation of
Miss. Code§ 97-43-1 et seq.
45.

Defendants conspired to commit and then actually committed a pattern of

racketeering activity---a series of crimes including, but not necessarily limited to, commercial
bribery in violation of Miss. Code § 97-9-10 and bribery to conceal offenses in violation of Miss.
Code § 97-9-9, with the intended purpose of compelling the State to pay approximately
$6,000,000 to GIL. Predicate offenses include, but are not necessarily limited to, (1) each

9

periodic payment made by Defendant GTL to Defendant Waggoner and/or to persons or entities
affiliated with Waggoner, apd (2) each transfer of funds made by Waggoner to or for the benefit
of Defendant Epps.

Through their pattern of racketeering activity, Defendants directly and

indirectly conducted and participated in the affairs of MDOC and acquired and maintained an
interest in, and control of, MDOC. Acting with criminal intent, they also used the proceeds
derived from this pattern ofracketeering activity in the operation ofMDOC.
46.

As a direct and proximate result of Defendants' conduct, the State has been

harmed and has suffered damages.

Also pursuant to § 97-43-9(2), the State is entitled to

forfeiture by the Defendants of all property "derived from, or realized through, conduct in
violation" of Miss. Code § 97-43-1 et seq. The State demands judgment for all such damages
and demands the forfeiture of all funds wrongly paid to GTL by the State.
COUNT III
VIOLATIONS OF THE MISSISSIPPI ANTITRUST ACT

47.

The foregoing paragraphs are incorporated here by reference, as if set forth in full.

48.

The Defendants' actions violated provisions of Mississippi law governing "Trusts

and Combines in Restraint or Hindrance of Trade," or the Mississippi Antitrust Act (Miss. Code

§ 75-21-1 et seq.).
49.

As described herein, Defendants entered into a continuing agreement,

understanding or conspiracy to restrain trade and to artificially fix, raise and stabilize prices for
various goods and services sold to the State.
50.

The Defendants' anticompetitive conduct prevented competitive bidding, and

thus, precluded competition on price and quality in the inmate phone services market. Other
vendors would have been available to compete for the above-referenced contracts.

GTL's

payments of bribes and kickbacks to Epps also caused GTL to incur higher costs, which were
10

passed on to the State. GTL's conduct thus prevented the State from obtaining a competitive
market price for the

service~

it purchased, raising prices above competitive levels, as described

herein.
51.

But for the Defendants' anticompetitive acts, the State would have been able to

purchase these services at lower prices or at legal and competitive prices.
52.

The State is entitled to damages pursuant to Miss. Code§ 75-21-9 and to penalties

pursuant to Miss. Code§§ 75-21-7, 75-21-9 and 75-21-15.
53.

Defendants' unlawful and unfair business practices have therefore caused the

State to pay supra-competitive and artificially-inflated prices for services, and each purchase
constitutes a violation of the Mississippi Antitrust Act, for which damages the State demands
payment from Defendants.
COUNT IV
VIOLATIONS OF MISS. CODE§ 31-7-13-BIDDING REQUIREMENTS

54.

The foregoing paragraphs are incorporated here by reference, as if set forth in full.

55.

D_efendants' "no-bid" contracts violated Mississippi's system of open bidding.

56.

Miss. Code § 31-7-13 sets forth the mandatory bidding requirements for State

purchases of $50,000 or more. It sets out broadly what purchases require competitive bidding
and narrowly what purchases are exceptions to that requirement.

The purposes of the

Mississippi system of "competitive bidding" are to obtain the lowest price, to create a level
playing field for suppliers, and above all, to frustrate corrupt conspiracies.
57.

As set forth herein, Defendants' conduct caused the State to enter into wrongful

"no-bid" and/or "sole source" contracts. Defendants used untrue and fabricated circumstances as
justification for using wrongful "no-bid" contracts.

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58.

Defendants succeeded in their wrongful "no-bid" contracting, costing the State

large sums in overpayment.. Defendants derived, directly or indirectly, the fruits of that effort.
Therefore, the State demands a return of all profits and reimbursement of all excess costs, for
which the Defendants were responsible through their wrongful actions.
COUNTV
BREACH OF FIDUCIARY DUTY AND AIDING
AND ABETTING BREACH OF FIDUCIARY DUTY

59.

The foregoing paragraphs are incorporated here by reference, as if set forth in full.

60.

Defendant Epps, at all times pertinent hereto, owed fiduciary duties of, inter alia,

care and loyalty, to the State.
61.

Defendant Epps breached those fiduciary duties by accepting bribes and

kickbacks from persons and/or entities seeking public contracts or through their agents, by
causing public contracts to be awarded to such entities and by causing public contracts to be
awarded without following procedures required by law.
62.

The Defendants (other than Epps), at all pertinent times, had knowledge of Epps'

fiduciary duties to the State and provided substantial assistance to Epps that allowed him to
breach his fiduciary duties to the State.
63.

As a direct and proximate result of Defendant Epps' breaches of fiduciary duty,

aided and abetted by the other Defendants, the State has been harmed and has suffered damages,
for which demand is made.
COUNT VI
VIOLATIONS OF MISS. CONST. ART. 4, § 109

64.

The foregoing paragraphs are incorporated here by reference, as if set forth in full.

65.

At all relevant times, Defendant Epps was a "public officer" within the meaning

of Miss. Const. art. 4, § 109.
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66.

Defendant Epps had a pecuniary interest, directly or indirectly, in the above-

described contracts entered

~etween

the State and Defendant GTL, in violation of Miss. Const.

art. 4, § 109.
67.

The Attorney General brings this action against Defendants Epps, Waggoner and

GTL pursuant to Miss. Const. art. 4, § 109 and demands recovery of all money paid by the State
as a result of the aforesaid misconduct.
COUNT VII
COMMON LAW FRAUD

68.

The foregoing paragraphs are incorporated here by reference, as if set forth in full.

69.

Defendants agreed to, and did participate in, a common scheme to defraud the

State. Defendants intended to deceive the State by securing public contracts without disclosing
the payments to and between Defendants and Epps. Defendants concealed, or misrepresented by
omission, the existence of these underlying bribes and kickbacks paid to Epps-if the existence
of these payments had been disclosed, the public contracts would not have been awarded or
would have been rescinded.
70.

As a direct and proximate result of Defendants' acts of fraud against the State, the

State has been harmed and has suffered damages, for which demand is made.
COUNT VIII
CIVIL CONSPIRACY

71.

The foregoing paragraphs are incorporated here by reference, as if set forth in full.

72.

The Defendants' actions constitute a combination or conspiracy of entities to

accomplish an unlawful purpose or to accomplish a lawful purpose unlawfully.

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73.

As set forth herein, Defendants have committed torts and other wrongful acts

against the State, including acts of fraud, breaches of fiduciary duty, unjust enrichment and
violations of antitrust laws.
74.

Defendants agreed to participate m a common scheme to defraud the State.

Defendants intentionally participated in the furtherance of a plan or purpose to obtain funds from
the State. And in furtherance of this plan or purpose, Defendants committed overt and unlawful
acts, including acts of racketeering as described herein.
75.

As a direct and proximate result of Defendants' conspiracy, the overt acts

committed in furtherance of that conspiracy and the torts committed against the State, the State
has been harmed and has suffered damages, for which demand is made.
COUNT IX
UNJUST ENRICHMENT - RESTITUTION

76.

The foregoing paragraphs are incorporated here by reference, as if set forth in full.

77.

Under common law and the Mississippi Code, Defendants must repay any and all

funds, gains and profits from the sale of goods or services that were purchased, directly or
indirectly, by the State through the contracts described herein.
78.

Defendants have enriched themselves unjustly at the State's expense, by engaging

in the acts and practices described herein. Therefore, the State demands disgorgement of all illgotten funds, gains and profits received by Defendants as a result of their actions.
DAMAGES AND OTHER RELIEF SOUGHT

79.

The foregoing paragraphs are incorporated here by reference, as if set forth in full.

80.

As a result of Defendants' aforesaid misconduct, the State seeks recovery of all

available damages, including-but not limited to--compensatory, punitive and exemplary.

14

81.

Because Defendants' conduct constitutes willful, egregious, reckless, fraudulent

and wrongful acts against t~e State, 'the State seeks punitive damages under Miss. Code § 11-165, in an amount that is appropriate and necessary.
82.

The State seeks forfeiture of all money received by Defendants, directly or

indirectly, through the conduct alleged herein.
83.

The State seeks rescission of all illegally awarded contracts and/or forfeiture of all

pecuniary benefits received by Defendants, or otherwise realized by them, directlv or indirectly,
through the conduct alleged herein, including but not limited to, all money paid by the State from
all public contracts.
84.

The State seeks restitution of all illegally obtained or ill-gotten funds and gains

paid by the State to Defendants.
85.

The. State seeks pre-judgment interest, post-judgment interest, attorneys' fees,

court costs, investigative costs, expert-witness fees, deposition fees and any other expenses or
damages which this Court deems proper.
86.

The State reserves the right to amend this complaint to allege further damages.
RIGHT TO AMEND PURSUANT TO MISS. R. CIV. P.15

87.

Under Rule 15 of the Mississippi Rules of Civil Procedure, the State reserves the

right to name additional defendants should later facts establish that others are liable.
JURY TRIAL DEMAND

88.

The State demands a jury trial.
PRAYER

Given the above, the State requests that upon final trial hereof, the State be entitled to
recover from Defendants all the relief that is sought-including but not limited to, compensatory,

15

punitive and exemplary damages, forfeiture, disgorgement of all ill-gotten funds, civil penalties,
pre- and post-judgment interest, attorneys' fees, court costs, investigative costs, expert-witness
fees, deposition fees and any other expenses or damages which this Court deems proper.
Respectfully submitted, this the

8

day of

(:: ..,\cl>Jc-.\ '-\
l

'2017.

JIM HOOD, ATTORNEY GENERAL
OF THE STATE OF MISSISSIPPI, ex
rel. THE STATE OF MISSISSIPPI
By: ,!,. ~~- 7>/diiiL.,,_:w
George W~eville, Esq. (MSB' # 3822)
Geoffrey Morgan, Esq. (MSB # 3474)
S. Martin Millette, III, Esq. (MSB # 102416)
Jacqueline H. Ray, Esq. (MSB # 100169)
OFFICE OF THE ATTORNEY GENERAL
Post Office Box 220
Jackson, Mississippi 39205-0220
Tel: (601) 359-3680 I Fax: (601) 359-2003
Email: gnevi@ago.state.ms.us
Email: gmorg@ago.state.ms.us
Email: mamil@ago.state.ms.us
Email: jacra@ago.state.ms.us

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OF COUNSEL:

Don Barrett
DON BARRETT, P.A.
P.O.Box927
404 Court Square North
Lexington, Mississippi 39095
Telephone: (662) 834-2488
Toll Free: (877) 816-4443
Facsimile: (662) 834-2628
Email: donbarrettpa@gmail.com
Richard R. Barrett
LAW OFFICE OF RICHARD R. BAP.RETT, PLLC
2086 Old Taylor Road, Suite lOll
Oxford, Mississippi 38655
Telephone: (662) 380-5018
Facsimile: (866) 430-5459
Email: rrb@rrblawfirm.net
Gerald M. Abdalla, Jr.
ABDALLA LAW, PLLC
602 Steed Road, Suite 200
Ridgeland, Mississippi 39157
Telephone: (601) 487-4590
Facsimile: (601) 487-4595
Email: jerry@abdalla-law.com

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