j lester alexander affidavit in word … · 17/10/2018 · case no. 3:18-cv-00679 ... with 28...

Exhibit 1

Case 3:18-cv-00679-CWR-FKB Document 16-1 Filed 10/17/18 of 3

Case 3:18-cv-00679-CWR-FKB Document 16-1 Filed 10/17/18 of 3

1371973v.2

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF MISSISSIPPI

NORTHERN DIVISION

ALYSSON MILLS, IN HER CAPACITY AS RECEIVER FOR ARTHUR LAMAR ADAMS AND MADISON TIMBER PROPERTIES, LLC,

Plaintiff,

v.

MICHAEL D. BILLINGS and

MDB GROUP, LLC;

TERRY WAYNE KELLY, JR. and

KELLY MANAGEMENT, LLC;

and WILLIAM B. MCHENRY, JR. and

FIRST SOUTH INVESTMENTS, LLC,

Defendants.

Case No. 3:18-cv-00679

Arising out of Case No. 3:18-cv-252, Securities and Exchange Commission v. Arthur Lamar Adams and Madison Timber Properties, LLC

Hon. Carlton W. Reeves, District Judge

DECLARATION OF J. LESTER ALEXANDER, III IN SUPPORT OF PLAINTIFF’S MOTION FOR TEMPORARY RESTRAINING ORDER AND

PRELIMINARY INJUNCTION AGAINST MICHAEL D. BILLINGS, MDB GROUP, LLC, WILLIAM B. MCHENRY JR., and FIRST SOUTH

INVESTMENTS, LLC

I, J. Lester Alexander, III, do hereby declare under penalty of perjury and in accordance

with 28 U.S.C. § 1746 that this declaration is made of my own personal knowledge, that I am

competent to testify as to the matters stated herein, and that the following statements are all true

and correct.

1. I am the Chief Executive Officer and founder of AEA Group, LLC, formerly known

as Accounting, Economics & Appraisal Group, LLC (“AEA Group”), a forensic accounting and

valuation firm located in Houston and Birmingham. I am a Certified Public Accountant and

Exhibit 2

Case 3:18-cv-00679-CWR-FKB Document 16-2 Filed 10/17/18 Page 1 of 9

1371973v.2

Certified Fraud Examiner. In addition, I am Certified in Financial Forensics and Accredited in

Business Valuation by the American Institute of Certified Public Accountants (“AICPA”). I also

am a Chartered Global Management Accountant. I have more than three decades of professional

experience performing audit, tax and consulting services. I have been admitted as an expert

forensic accountant on the subject of the existence, payment history, original amount, disposition

of collateral and the outstanding balance of a company’s debts in Federal and various state courts.

I have been admitted as an expert forensic accountant on a variety of financial topics including

making solvency determinations, tracing the source and use of cash and other assets, evaluating

the timing and value of consideration received in exchange for payments made to creditors and the

course of conduct between a debtor and its creditors and other matters in various Federal courts,

including the U.S. District Court for the Middle District of Alabama. I am a former partner of

PricewaterhouseCoopers LLP and its legacy firm, Coopers & Lybrand, LLP, where I served as the

leader of its Southeastern regional forensic accounting practice with offices in Dallas, Houston,

Atlanta, Louisville, Birmingham, Tampa and Miami.

2. I was engaged by the Receiver, Alysson L. Mills, in Securities and Exchange

Commission v. Arthur Lamar Adams and Madison Timber Properties, LLC, Cause No. 3:18-CV-

252 (the “Receivership Proceeding”), pending in the United States District Court for the Southern

District of Mississippi, to serve as a forensic accountant. I submit this Declaration in support of

the Plaintiff’s Motion for Temporary Restraining Order and Preliminary Injunction in the above-

captioned proceeding.

INFORMATION UTILIZED

3. I have received and analyzed Madison Timber Properties, LLC’s business records,

including without limitation, the Madison Timber Account Statements and the Madison Timber


1371973v.2

Electronic Accounting Files, as described in the Declaration of Alysson L. Mills. I have also

reviewed the MDB Group Account Statements and First South Electronic Accounting Files, as

described in the Declaration of Alysson L. Mills.

FINDINGS

4. Based on my review of Madison Timber Properties, LLC’s business records, the

MDB Group Account Statements, and the First South Electronic Accounting Files, I have

concluded that Defendant MDB Group, LLC received $3,513,780 in transfers from Madison

Timber and Defendant First South Investments, LLC received $3,473,320 in transfers from

Madison Timber. Attached as Exhibit A to this affidavit is a spreadsheet summarizing all of those

transfers.

I declare under penalty of perjury and in accordance with 28 U.S.C. § 1746 that the

foregoing is true and correct.

EXECUTED this 17th day of October, 2018.

__________________________________________ J. Lester Alexander, III


Exhibit A

First South Commissions MDB Group, LLC Commissions

Date Amount Date Amount

02/09/2010 15,000.00$ 12/16/2013 30,000.00$ 02/16/2010 7,500.00 12/27/2013 3,000.00 03/26/2010 3,125.00 01/02/2014 10,000.00 05/21/2010 1,620.00 01/27/2014 6,750.00 06/29/2010 6,500.00 02/03/2014 10,000.00 06/29/2010 250.00 02/14/2014 9,000.00 07/09/2010 7,000.00 03/03/2014 10,000.00 08/03/2010 3,500.00 03/13/2014 22,500.00 09/08/2010 9,000.00 03/21/2014 4,500.00 09/13/2010 8,000.00 03/26/2014 3,000.00 10/18/2010 8,500.00 04/01/2014 10,000.00 10/26/2010 4,000.00 04/24/2014 22,500.00 11/05/2010 10,000.00 05/01/2014 10,000.00 11/29/2010 4,225.00 05/12/2014 3,000.00 12/03/2010 10,000.00 05/23/2014 22,500.00 12/07/2010 10,250.00 06/02/2014 10,000.00 04/01/2011 15,000.00 06/30/2014 6,750.00 05/27/2011 10,000.00 07/01/2014 10,000.00 06/06/2011 15,000.00 07/01/2014 10,000.00 06/20/2011 10,000.00 07/17/2014 6,375.00 07/05/2011 5,000.00 07/30/2014 3,000.00 07/12/2011 10,000.00 08/01/2014 10,000.00 07/14/2011 10,000.00 08/04/2014 6,000.00 09/16/2011 10,000.00 08/29/2014 11,250.00 09/30/2011 15,100.00 09/02/2014 10,000.00 10/25/2011 10,000.00 09/16/2014 6,000.00 11/22/2011 10,000.00 10/01/2014 10,000.00 12/08/2011 15,000.00 10/22/2014 3,000.00 12/15/2011 5,000.00 10/30/2014 3,750.00 01/10/2012 10,000.00 11/03/2014 10,000.00 01/25/2012 15,000.00 11/14/2014 7,500.00 02/14/2012 10,000.00 11/26/2014 5,250.00 02/23/2012 10,000.00 12/01/2014 10,000.00 03/14/2012 10,000.00 12/12/2014 6,000.00 03/16/2012 10,000.00 01/02/2015 22,500.00 03/22/2012 10,000.00 01/02/2015 10,000.00 06/08/2012 5,000.00 02/02/2015 10,000.00 07/05/2012 15,000.00 02/02/2015 4,500.00 07/11/2012 10,000.00 02/05/2015 3,000.00 07/13/2012 10,000.00 02/12/2015 7,500.00 07/24/2012 10,000.00 02/27/2015 6,000.00 08/08/2012 10,000.00 03/02/2015 10,000.00 08/17/2012 10,000.00 03/06/2015 3,000.00 08/27/2012 10,000.00 03/17/2015 3,750.00 09/04/2012 10,000.00 04/01/2015 33,750.00 09/19/2012 10,000.00 04/01/2015 10,000.00 10/03/2012 10,000.00 04/06/2015 3,750.00 10/09/2012 10,000.00 05/01/2015 10,000.00

1 of 6


Exhibit A



10/18/2012 10,000.00 05/04/2015 6,000.00 10/28/2012 5,000.00 05/08/2015 2,500.00 11/20/2012 10,000.00 05/15/2015 7,500.00 11/23/2012 10,000.00 05/29/2015 11,250.00 12/11/2012 20,000.00 06/01/2015 12,500.00 12/13/2012 15,000.00 06/26/2015 22,500.00 01/09/2013 15,000.00 07/01/2015 12,500.00 01/31/2013 10,000.00 07/01/2015 8,250.00 02/15/2013 20,000.00 07/17/2015 11,250.00 03/05/2013 10,000.00 07/31/2015 14,250.00 03/28/2013 10,000.00 08/03/2015 12,500.00 04/09/2013 10,000.00 08/07/2015 9,000.00 04/30/2013 10,000.00 08/12/2015 13,500.00 05/08/2013 5,000.00 08/13/2015 3,000.00 05/15/2013 10,000.00 09/01/2015 12,500.00 05/17/2013 10,000.00 09/16/2015 6,000.00 05/31/2013 20,000.00 10/01/2015 30,750.00 06/03/2013 5,000.00 10/01/2015 12,500.00 06/21/2013 10,000.00 10/29/2015 9,750.00 06/26/2013 15,000.00 11/02/2015 12,500.00 07/02/2013 10,000.00 11/05/2015 6,000.00 07/17/2013 10,000.00 11/13/2015 9,750.00 08/01/2013 10,000.00 11/18/2015 4,500.00 08/05/2013 10,000.00 12/01/2015 12,500.00 08/14/2013 10,000.00 12/03/2015 24,375.00 08/28/2013 10,000.00 01/04/2016 12,500.00 09/04/2013 10,000.00 01/04/2016 30,750.00 09/10/2013 15,000.00 01/13/2016 9,000.00 09/26/2013 10,000.00 01/29/2016 18,750.00 10/16/2013 15,000.00 02/01/2016 12,500.00 10/22/2013 5,000.00 02/16/2016 9,750.00 10/31/2013 10,000.00 03/01/2016 12,500.00 11/04/2013 10,000.00 03/03/2016 16,350.00 11/25/2013 10,000.00 03/04/2016 7,500.00 12/05/2013 10,000.00 03/30/2016 34,500.00 12/18/2013 10,000.00 04/01/2016 12,500.00 12/30/2013 10,000.00 05/02/2016 12,500.00 01/08/2014 10,000.00 05/03/2016 12,750.00 01/21/2014 30,000.00 05/16/2016 14,250.00 01/23/2014 10,000.00 05/25/2016 75,000.00 02/03/2014 1,400.00 06/01/2016 12,500.00 02/05/2014 3,150.00 06/02/2016 26,250.00 02/12/2014 15,000.00 06/09/2016 8,000.00 02/13/2014 30,000.00 06/10/2016 6,000.00 02/13/2014 15,000.00 06/30/2016 58,000.00 02/27/2014 10,000.00 07/01/2016 12,500.00 03/12/2014 10,000.00 07/15/2016 3,000.00

2 of 6


Exhibit A



03/28/2014 10,000.00 07/25/2016 12,000.00 04/10/2014 15,000.00 08/01/2016 12,500.00 04/18/2014 10,000.00 08/02/2016 4,000.00 04/18/2014 7,500.00 08/15/2016 13,000.00 05/06/2014 10,000.00 09/01/2016 12,500.00 05/22/2014 10,000.00 09/02/2016 36,000.00 06/03/2014 20,000.00 09/14/2016 4,000.00 06/05/2014 25,000.00 09/16/2016 4,000.00 07/01/2014 10,000.00 09/30/2016 44,000.00 07/04/2014 10,000.00 10/03/2016 12,500.00 07/16/2014 10,000.00 11/01/2016 12,500.00 07/25/2014 15,000.00 12/19/2016 5,000.00 07/29/2014 10,000.00 01/03/2017 12,500.00 08/07/2014 20,000.00 01/04/2017 38,000.00 08/29/2014 10,000.00 02/01/2017 12,500.00 09/03/2014 10,000.00 02/02/2017 73,500.00 09/04/2014 10,000.00 02/16/2017 84,530.00 09/22/2014 5,000.00 03/01/2017 12,500.00 09/29/2014 10,000.00 03/09/2017 35,000.00 10/10/2014 20,000.00 04/01/2017 12,500.00 10/14/2014 10,000.00 04/03/2017 5,000.00 10/15/2014 10,000.00 04/04/2017 117,000.00 10/30/2014 15,000.00 05/01/2017 12,500.00 11/04/2014 6,000.00 05/02/2017 18,000.00 11/26/2014 10,000.00 05/18/2017 53,000.00 12/01/2014 15,000.00 06/01/2017 12,500.00 12/05/2014 10,000.00 06/02/2017 110,000.00 12/08/2014 10,000.00 06/07/2017 60,000.00 12/10/2014 30,000.00 06/16/2017 19,800.00 01/05/2015 10,000.00 06/26/2017 50,000.00 01/09/2015 15,000.00 06/30/2017 56,900.00 01/21/2015 15,000.00 07/01/2017 12,500.00 01/30/2015 30,000.00 08/01/2017 12,500.00 01/30/2015 12,500.00 08/03/2017 32,000.00 02/11/2015 10,000.00 08/10/2017 90,000.00 02/18/2015 7,500.00 08/18/2017 20,000.00 02/25/2015 20,000.00 08/29/2017 21,000.00 03/04/2015 10,000.00 09/01/2017 10,000.00 03/25/2015 20,000.00 09/01/2017 12,500.00 03/26/2015 15,000.00 09/12/2017 120,000.00 04/15/2015 7,500.00 10/01/2017 12,500.00 04/17/2015 10,000.00 10/04/2017 24,800.00 04/24/2015 10,000.00 10/13/2017 24,000.00 05/05/2015 10,000.00 10/18/2017 100,000.00 05/07/2015 10,000.00 10/27/2017 20,000.00 05/13/2015 10,000.00 11/01/2017 12,500.00 05/27/2015 10,000.00 11/03/2017 10,000.00

3 of 6


Exhibit A



06/03/2015 20,000.00 11/10/2017 96,000.00 06/08/2015 5,000.00 11/27/2017 120,000.00 06/10/2015 5,000.00 12/01/2017 12,500.00 06/17/2015 15,000.00 12/04/2017 79,200.00 06/18/2015 15,000.00 12/27/2017 30,000.00 07/10/2015 10,000.00 01/15/2018 12,500.00 07/28/2015 10,000.00 01/17/2018 20,000.00 08/04/2015 15,000.00 01/26/2018 62,000.00 08/11/2015 10,000.00 02/01/2018 12,500.00 08/21/2015 10,000.00 02/02/2018 16,000.00 08/21/2015 15,000.00 02/14/2018 13,000.00 08/27/2015 10,000.00 03/01/2018 12,500.00 09/08/2015 10,000.00 03/02/2018 121,000.00 09/10/2015 10,000.00 03/09/2018 34,000.00 09/15/2015 15,000.00 03/19/2018 34,000.00 09/25/2015 11,000.00 04/02/2018 12,500.00 09/25/2015 10,000.00 04/02/2018 71,000.00 10/08/2015 20,000.00 04/17/2018 88,700.00 10/28/2015 15,000.00 10/30/2015 10,000.00 Total 3,513,780.00$

11/12/2015 17,500.00 11/13/2015 10,000.00 11/27/2015 10,000.00 11/27/2015 15,000.00 11/30/2015 10,000.00 12/07/2015 20,000.00 01/06/2016 20,000.00 01/13/2016 10,000.00 01/21/2016 8,000.00 02/03/2016 15,000.00 02/08/2016 25,000.00 02/24/2016 10,000.00 02/29/2016 10,000.00 02/29/2016 5,000.00 03/02/2016 7,500.00 03/09/2016 6,000.00 03/10/2016 15,000.00 03/11/2016 15,000.00 04/01/2016 10,000.00 04/05/2016 30,000.00 04/12/2016 25,000.00 04/28/2016 20,000.00 05/10/2016 10,000.00 05/12/2016 20,000.00 05/17/2016 10,000.00 05/31/2016 10,000.00 06/14/2016 10,000.00

4 of 6


Exhibit A



06/21/2016 5,000.00 06/29/2016 10,000.00 07/07/2016 8,000.00 07/14/2016 15,000.00 07/14/2016 20,000.00 07/21/2016 20,000.00 08/02/2016 10,000.00 08/02/2016 6,500.00 08/10/2016 10,000.00 08/15/2016 5,000.00 08/22/2016 15,000.00 08/30/2016 10,000.00 09/13/2016 10,000.00 09/28/2016 10,000.00 10/04/2016 20,000.00 10/07/2016 15,000.00 10/19/2016 10,000.00 10/25/2016 15,000.00 10/31/2016 10,000.00 11/02/2016 20,000.00 11/10/2016 10,000.00 11/22/2016 15,000.00 12/01/2016 10,000.00 12/06/2016 10,000.00 12/13/2016 7,500.00 01/04/2017 10,000.00 01/10/2017 10,000.00 01/13/2017 15,000.00 01/19/2017 15,000.00 01/25/2017 25,000.00 01/26/2017 20,000.00 02/07/2017 20,000.00 02/14/2017 10,000.00 02/28/2017 20,000.00 03/09/2017 10,000.00 03/16/2017 31,500.00 03/25/2017 10,000.00 03/29/2017 15,000.00 04/13/2017 15,000.00 04/27/2017 30,000.00 05/01/2017 15,000.00 05/09/2017 20,000.00 05/18/2017 10,000.00 05/25/2017 10,000.00 06/07/2017 10,000.00 06/19/2017 15,000.00 06/29/2017 20,000.00

5 of 6


Exhibit A



07/10/2017 30,000.00 07/14/2017 20,000.00 07/14/2017 15,000.00

07/19/2017 10,000.00 07/19/2017 25,000.00 08/02/2017 17,500.00 08/03/2017 15,000.00 08/07/2017 10,000.00 08/17/2017 10,000.00 08/30/2017 25,000.00 09/01/2017 10,000.00 09/01/2017 10,000.00 09/08/2017 10,000.00 09/21/2017 10,000.00 10/03/2017 20,000.00 10/10/2017 1,200.00 10/12/2017 20,000.00 10/18/2017 10,000.00 11/01/2017 45,000.00 11/28/2017 10,000.00 11/29/2017 10,000.00 11/29/2017 10,000.00 12/05/2017 20,000.00 12/28/2017 10,000.00 01/08/2018 15,000.00 01/10/2018 10,000.00 01/18/2018 20,000.00 01/29/2018 15,000.00 01/30/2018 15,000.00 01/31/2018 35,000.00 02/01/2018 10,000.00 02/05/2018 7,000.00

2/9/2018 10,000.00 2/21/2018 10,000.00 2/27/2018 20,000.00 3/2/2018 10,000.00 3/7/2018 5,000.00

3/16/2018 5,000.00 3/30/2018 5,000.00 3/30/2018 20,000.00 4/4/2018 10,000.00 4/5/2018 10,000.00

4/13/2018 10,000.00 4/18/2018 10,000.00

Total 3,473,320.00$

6 of 6


1

Begin forwarded message:

From: Michael Billings <[email protected]>Date: May 19, 2015 at 2:33:57 PM CDTTo:Cc: Lamar Adams <[email protected]>Subject: Re: Madison Timber Properties, LLC on behalf of

Hey ...yes, absolutely, I'm happy to connect you to references. As to the ones inparticular to which you refer, I'm precluded by NDA from disclosing one, and theprincipal of the other is currently in France, due back in Dallas on May 24. I will be morethan happy to connect you (and he will be more than happy to visit with you) once he'sback home. He and I are slated to get together a day or so after his return, and I will teeyou up for a visit with him at that time.

Thanks so much!

Mike

Sent from my iPhone

On May 19, 2015, at 1:31 PM, wrote:

Hello Lamar,Thanks for your thoughts below, and for your time.

Mike,You mentioned that a number of your TX Family Offices have performeddue diligence on Lamar. Are there any references you can connect us toas a final step in our due diligence process, who have invested in thisstructure for a meaningful amount of time?

Thanks again gentlemen!

Best,

Exhibit 3


2

<image001.png>

From: Lamar Adams [mailto:[email protected]]Sent: Tuesday, May 19, 2015 9:32 AMTo: [email protected];Subject: Madison Timber Properties, LLC on behalf of

Since going to this current formatMadison Timber Properties, LLC haspurchased approximately 572 tracts oftimber. We have not had anytransaction not pay out as structured toour Joint Venture Partners.We have had 2 instances where we hadInsurance claims on those tractsbecause of an ice storm. However,those did not affect our Joint VenturePartner’s return.

If there is a cause of death with me, ourAttorneys will handle my Estate. As faras remaining payments to MadisonTimber Properties, LLC and the JointVenture Partners, nothing will change.We have Contracts in place with theMills and those wires will continue untilthe end of the term of the Contracts.The same will apply to our JointVenture Partners, the wires willcontinue until end of term.

Thanks,Lamar Adams


1

From: Michael Billings <[email protected]>Sent: Friday, February 19, 2016 9:10 AMTo: Madison TimberCc: Lamar AdamsSubject: Re: Upcoming Funding

I thank you and Lamar - you two make it all possible for me to do what I do - Team!!!

FYI I'm planning to travel to Jackson on Monday (I may push a day or two if the weather is bad on eitherend - I don't like sitting for hours at DFW), and will be there thru most of March. Lets get a lunch on thecalendar for late next week if you're both around!!

Sent from my iPhone

> On Feb 19, 2016, at 9:04 AM, Madison Timber <[email protected]> wrote:>> Thanks Mike! That all sounds great.. Wish you the best and thanks for all your hard work! Team!!!Have a great weekend!!>> Sent from my iPhone>>> On Feb 19, 2016, at 8:59 AM, Michael Billings <[email protected]> wrote:>>>> Yes, thus far that is absolutely correct. may decide to push to May 1 because of the skippedmonth, but I've told him this week that unless he tells us differently we have him in the que for$250,000 on April 1.>>>> has been in Napa all week, en route to NY this morning for lunch, back this afternoon andhas promised me his info ASAP. You will have it as soon as I do.>>>> I had three very important meetings this week and I believe we are about to get add some new Dallasfolks...as you know, I don't like to talk about them until they are "done", but I think a couple may be inthe initial $500,000 range, so pls just have that in the back of your mind over the next 30-60 days.>>>> I will be with at a party this evening in Dallas and may have more info after that, but he hasindicated verbally that both he and are loving their investment(s) with us and are planning more inthe April timeframe. I'd guess in similar amounts as what they've been doing - but one never knows,they could up the ante!>>>> I will of course keep you both posted as these things continue to evolve...have a great weekend!!>>>> Thanks,>>>> Mike>>>> Sent from my iPhone

Exhibit 4


2

>>>>> On Feb 19, 2016, at 8:41 AM, Wayne Kelly <[email protected]> wrote:>>>>>> Mike,>>> Lamar and I were talking yesterday about upcoming funding, and I want to make sure the followingcommitments are correct. If their is anyone we need to add or delete just let me know.>>>>>> Thanks,>>> Wayne>>>>>> March 1st:>>>>>> 1. 600k>>> 2. 200k>>> 3. 200k>>>>>> April 1st:>>>>>> 1. 1.5>>> 2. 300k>>> 3. 200k>>> 4. 200k


1


From: Michael Billings <[email protected]> Date: April 29, 2015 at 6:22:30 PM CDT To: Lamar Adams <[email protected]> Subject: Re: Fwd: RE:

And more, and more and more!!

Sent from my iPhone

On Apr 29, 2015, at 6:21 PM, Lamar Adams <[email protected]> wrote:

Sent from my iPhone


From: Date: April 29, 2015 at 5:58:26 PM CDT To: Lamar Adams <[email protected]> Subject: RE:

Glad to be doing more business with you.

From: Lamar Adams [mailto:[email protected]] Sent: Tuesday, April 28, 2015 1:34 PM To: Subject:

Hope all is well with you and your family and the crew at . Here are the executed Docs for your review. I will have the Originals Fedexed to you this afternoon.

Please contact me if you have any questions. Thanks for your partnership,

Lamar

Exhibit 5


2

601-942-0369


1

From: Lamar Adams <[email protected]>

Sent: Tuesday, July 14, 2015 10:38 AM

To: 'Michael Billings'

Cc: 'Madison Timber'

Subject: Re: New Tracts

Awesome! Great job Mike

Sent from my iPhone

On Jul 14, 2015, at 11:34 AM, Michael Billings <[email protected]> wrote:

Hey guys, please add to the list below as confirmed for $200,000 on September 30...thank you!!

If you add $500,000 yesterday to it, that's a total of $4,150,000 between now and the end of September...we are on a roll - and looking for more!

Thx,

M

Sent from my iPhone


From: Michael Billings <[email protected]> Date: July 14, 2015 at 9:03:42 AM CDT To: Lamar Adams <[email protected]>, Madison Timber <[email protected]> Subject: Fwd: New Tracts

Hey guys, just responded and would like to do $400,000 on August 1, and an additional $200,000 on October 1. So that makes my revised group schedule look like this:

$250,000 - 7/17 $250,000 - 7/31

$400,000 - 8/1 $250,000 - 8/14

$500,000 - 8/14 $200,000 - 9/14

$200,000 - 10/1 $1,500,000 - 10/1

I will update as I hear back or more from anyone else...but please book the preceding.

Thank you!!

Exhibit 6


2

M

Sent from my iPhone


From: Michael Billings <[email protected]> Date: July 14, 2015 at 7:55:46 AM CDT To: Lamar Adams <[email protected]>, Madison Timber <[email protected]> Subject: New Tracts

Hey Guys,

FYI I've confirmed for another $250,000 investment on or just prior to August 14, and for another $200,000 on or just prior to September 15.

So just to recap, here is who I have confirmed thus far in the next couple of months:

$250,000 - 7/17 $250,000 - 7/31

$250,000 - 8/14 $500,000 - 8/14

$200,000 - 9/14 $1,500,000 - 10/1

In addition, I'm anticipating for an additional $250,000, and potentially for another $500,000, both in September -

has a tract maturing 9/1 and on 9/15. I've emailed both and am awaiting replies. I will let you know when confirmed. I'm also thinking that will be ready for another tract in the September time frame, as he'd indicated he wants to invest on a regular quarterly basis, but I'm waiting to hear back regarding the UCC/mill contract issue prior to calling him to arrange a visit. I will confirm him at that time.

Thank you both so much!

Mike

Sent from my iPhone


j lester alexander affidavit in word … · 17/10/2018 · case no. 3:18-cv-00679 ... with 28...

Documents