IN THE COURT OF APPEALS FOR THE STATE OF MISSISSIPPI NO. 201S-CA CA-00739

Similar documents
IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI NO: 2015-CA COA VICTOR BYAS AND MARY BYAS CERTIFICATE OF INTERESTED PARTIES

IN THE SUPREME COURT OF MISSISSIPPI. No.2009-CA APPEAL FROM THE CHANCERY COURT OF WASHINGTON COUNTY, MISSISSIPPI

IN THE COURT OF APPEALS STATE OF MISSISSIPPI APPEAL FROM THE SPECIAL COURT OF EMINENT DOMAIN OF WAYNE COUNTY, MISSISSIPPI

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI JAMES CRAIG PALCULICT REPLY BRIEF OF APPELLANT

E-Filed Document May :25: CA Pages: 18. IN THE SUPREME COURT OF THE STATE OF MISSISSIPPI No.: 2013-CA-01006

APPELLEE'S MOTION FOR RECONSIDERATION

IN THE SUPREME COURT OF MISSISSIPPI No TS CURTIS RAY MCCARTY, JR. RESPONSE IN OPPOSITION TO MOTION FOR REHEARING

REPLY IN SUPPORT OF BRIEF OF APPELLEE/CROSS APPELLANT H&E EQUIPMENT SERVICES, INC. ORAL ARGUMENT NOT REQUESTED

V. CASE NO CA-00669

IN THE MISSISSIPPI COURT OF APPEALS 2015-CA JOSHUA HOWARD Appellant-Defendant v. THE STATE OF MISSISSIPPI, Appellee-Plaintiff

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI NO.2014-CA COA

IN THE SUPREME COURT OF THE STATE OF MISSISSIPPI IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI CAUSE NO CA-00442

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI. No CA COA

E-Filed Document Dec :19: CA Pages: 17

APPELLANT'S BRIEF. Case No CA ORAL ARGUMENT NOT REQUESTED IN THE SUPREME COURT OF MISSISSIPPI RHONDA B. (KITTRELL) FARRIOR APPELLANT

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI CERTIFICATE OF INTERESTED PERSONS

IN THE SUPREME COURT OF THE STATE OF MISSISSIPPI NO.2009-CP APPEAL FROM THE CIRCUIT COURT OF LAUDERDALE COUNTY, MISSISSIPPI BRIEF OF APPELLEE

THE SUPREME COURT OF MISSISSIPPI

IN THE SUPREME COURT OF MISSISSIPPI No TS CURTIS RAY MCCARTY, JR. RESPONSE IN OPPOSITION TO PETITION FOR CERTIORARI

IN THE SUPREME COURT OF MISSISSIPPI CASE NO IA-1414-SCT CONSOLIDATED WITH CASE NO IA SCT BRIEF OF APPELLANTS (NO.

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI NO CP COA STATE OF MISSISSIPPI BRIEF FOR THE APPELLEE

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI NO CP-0239-COA STATE OF MISSISSIPPI BRIEF FOR THE APPELLEE

IN THE SUPREME COURT OF MISSISSIPPI CAUSE NO: 2009-CA AMERICA'S HOME PLACE, INC. APPELLEE'S BRIEF

BRIEF OF THE APPELLEE

IN THE SUPREME COURT OF MISSISSIPPI NO CT DAVID GLENN NUNNERY, ET AL. V. ON APPEAL FROM THE CHANCERY COURT OF PIKE COUNTY, MISSISSIPPI

BRIEF OF APPELLEES I CROSS-APPELLANTS

IN THE SUPREME COURT OF MISSISSIPPI

IN THE SUPREME COURT OF MISSISSIPPI NO.200B-CA APPEAL FROM THE CHANCERY COURT OF LOWNDES COUNTY, MISSISSIPPI APPELLANTS' REPLY BRIEF

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI PATRICK DANTRE FLUKER BRIEF FOR THE APPELLEE APPELLEE DOES NOT REQUEST ORAL ARGUMENT

IN THE SUPREME COURT OF MISSISSIPPI No.2013 CT SCT 2013-CT SCT. MILTON TROTTER, Appellant. STATE OF MISSISSIPPI, Appellee

IN THE SUPREME COURT OF MISSISSIPPI NO: 2016-TS SCT

IN THE SUPREME COURT OF MISSISSIPPI CERTIFICATE OF INTERESTED PARTIES

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI NO CA COA WINN-DIXIE MONTGOMERY, LLC

IN THE COURT OF APPEALS FOR THE STATE OF MISSISSIPPI. v. NO CA COA R.M. SMITH INVESTMENTS, L.P.

v. CAUSE NO CA-01920

IN THE SUPREME COURT OF MISSISSIPPI NO.: 2013-IA SCT BRIEF OF APPELLANT INTERLOCUTORY APPEAL. ERIC C. HAWKINS Post Office Box 862

REPLY BRIEF IN THE SUPREME COURT OF MISSISSIPPI NO CA FRANKLIN CORPORATION AND EMPLOYERS INSURANCE COMPANY OF WAUSAU

REPLY BRIEF OF APPELLANTS

V. NO KA COA STATE OF MISSISSIPPI MOTION FOR REHEARING STANDARD OF REVIEW ARGUMENT

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI NO.2015-CA-00903

SUPREME COURT OF MISSISSIPPI COURT OF APPEALS OF MISSISSIPPI 2011-CA-OI040

IN THE SUPREME COURT OF THE STATE OF MISSISSIPPI 2008-CP STEVEN EASON APPELLANT. On Appeal From the Circuit Court of Greene County, Mississippi

SUPREME COURT OF MISSISSIPPI COURT OF APPEALS OF THE STATE OF MISSISSIPPI CAUSE NO CA STEVENS AUCTION COMPANY and JOHN D.

llpage IN THE SUPREME COURT OF MISSISSIPPI COURT OF APPEALS OF THE STATE OF MISSISSIPPI NO.2009-CA APPELLANT BENNIE E. BRASWELL, JR.

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI OTTIS J. CUMMINGS, JR. NO CP COA STATE OF MISSISSIPPI BRIEF FOR THE APPELLEE

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI DONALD GREGORY CHAMBLISS NO CP COA STATE OF MISSISSIPPI BRIEF FOR THE APPELLEE

IN THE SUPREME COURT OF THE STATE OF MISSISSIPPI CASE N ca NO.2014-ca-00984

IN THE COURT OF APPEAL OF THE STATE OF MISSISSIPPI FILED OFFICE OF THE CLERK SUPREME COURT COURT OF APPEALS BRIEF FOR THE APPELLEE

IN THE. SUPREME COURT OF THE STATE OF MISSISSIPPI NO.2011-CA AND MISSISSIPPI STATE OIL AND GAS BOARD, ET AL

APPELLATE BRIEF IN SUPPORT OF POST-CONVICTION RELIEF

IN THE SUPREME COURT OF MISSISSIPPI COURT OF APPEALS OF THE STATE OF MISSISSIPPI 2010-CA-OI624-COA BRIEF OF APPELLEES

IN THE SUPREME COURT OF THE STATE OF MISSISSIPPI NO CA-0547 STATE OF MISSISSIPPI SUPPLEMENTAL BRIEF FOR THE APPELLEE

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI

IN THE MISSISSIPPI COURT OF APPEALS No.2016-KP COA No.2016-KP COA

BRIEF OF APPELLEE BEFORE THE COURT OF APPEALS FOR THE STATE OF MISSISSIPPI BELL SOUTH TELECOMMUNICATIONS, INC. VS. LARRY B.

v. No CA SCT DOROTHY L. BARNETT, et al. ON APPEAL FROM THE CIRCUIT COURT OF HINDS COUNTY NO CIV ORAL ARGUMENT NOT REQUESTED

E-Filed Document Oct :50: CA Pages: 16 IN THE SUPREME COURT OF MISSISSIPPI COURT OF APPEALS OF THE STATE OF MISSISSIPPI

IN THE SUPREME COURT OF THE STATE OF MISSISSIPPI 2007-CP JOHN HENRY ADAMS APPELLANT. vs. GLORIA GIBBS, DIRECTOR OF RECORDS APPELLEE

REPLY BRIEF OF THE APPELLANTS

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI NO CP COA STATE OF MISSISSIPPI BRIEF FOR THE APPELLEE

IN THE SUPREME COURT OF MISSISSIPPI CASE NO CA-00742

IN THE SUPREME COURT OF MISSISSIPPI BRIEF OF APPELLANT JOHN OAKS ORAL ARGUMENT NOT REQUESTED

PETITION FOR REHEARING

IN THE COURT OF APPEALS OF TENNESSEE AT NASHVILLE October 13, 2011 Session. THE FARMERS BANK v. CLINT B. HOLLAND, ET AL.

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI

J-O 11- L~-/3f&;,3 -- toile'

IN THE SUPREME COURT OF MISSISSIPPI NO CT SCT WILLIAM MICHAEL JORDAN STATE OF MISSISSIPPI SUPPLEMENTAL BRIEF OF APPELLANT

IN THE SUPREME COURT OF THE STATE OF MISSISSIPPI LOWE S HOME CENTER, INC. BRIEF OF APPELLANT ORAL ARGUMENT REQUESTED

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI NO CP STATE OF MISSISSIPPI BRIEF FOR THE APPELLEE

Rules of Appellate Procedure, and files this Motion for Rehearing of the decision rendered by the

IN THE SUPREME COURT OF MISSISSIPPI NO CA-01079

IN THE SUPREME COURT OF MISSISSIPPI APPELLEE'S SUPPLEMENTAL BRIEF IN RESPONSE TO PLAINTIFF'S REPLY BRIEF

IN THE SUPREME COURT OF THE STATE OF MISSISSIPPI NUMBER 2015-KA STATE OF MISSISSIPPI BRIEF FOR APPELLANT

IN THE SUPREME COURT FOR THE STATE OF MISSISSIPPI BRIEF OF APPELLANT, MARSHALL COUNTY BOARD OF SUPERVISORS

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI CASE NO.: 201S-TS ON APPEAL FROM THE CHANCERY COURT OF JACKSON COUNTY, MISSISSIPPI

REPLY BRIEF OF THE APPELLANT

IN THE SUPREME COURT OF THE STATE OF MISSISSIPPI

IN THE COURT OF APPEALS OF TENNESSEE AT JACKSON October 28, 2015 Session

IN THE SUPREME COURT OF MISSISSIPPI & IN THE COURT OF APPEALS FOR THE STATE OF MISSISSIPPI 2016-CA-188-COA STATE OF MISSISSIPPI

IN THE SUPREME COURT OF THE STATE OF MISSISSIPPI CASE NO CA CITY OF JACKSON, MISSISSIPPI APPELLANT

IN THE SUPREME COURT OF MISSISSIPPI CASE NO CP-00950

COMES NOW Appellant, Douglas Michael Long, Jr. (hereinafter Doug ), by

IN THE SUPREME COURT OF THE STATE OF MISSISSIPPI GENERAL MOTORS CORPORATION CERTIFICATE OF INTERESTED PERSONS

NO KA COA IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI BRYN ELLIS APPELLANT, STATE OF MISSISSIPPI APPELLEE.

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI

IN THE SUPREME COURT OF FLORIDA. IN RE: ESTATE OF CASE NO. SC04- Lower Tribunal No. 2D ALVARADO KELLY,

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI 2015-CA STATE OF MISSISSIPPI MOTION FOR REHEARING

IN THE SUPREME COURT OF MISSISSIPPI COURT OF APPEALS OF THE STATE OF MISSISSIPPI V. CAUSE NO CA COA STATE OF MISSISSIPPI

IN THE SUPREME COURT OF THE STATE OF MISSISSIPPI FILED MAY Suprem. Court Court 0' Appeal. BRIEF FOR THE APPELLEE

ORAL ARGUMENT REQUESTED

IN THE COURT OF APPEALS OF OHIO THIRD APPELLATE DISTRICT CRAWFORD COUNTY PLAINTIFFS-APPELLEES, CASE NO

IN THE SUPREME COURT OF THE STATE OF MISSISSIPPI MARGIE EDNA (GALLOWAY) MALLETT WILSON V. DOCKET NO.: 2008-CA BYRON KEITH MALLETT

IN THE SUPREME COURT OF MISSISSIPPI. ARTHUR GERALD HUDSON and LINDA S. HUDSON APPELLANTS. v. Cause No CA LOWE S HOME CENTERS, INC.

NO CA Brenda Franklin v. Cornelius Turner MOTION FOR RECONSIDERATION

BRIEF OF THE APPELLEE/CROSS-APPELLANT

REPLY BRIEF FOR APPELLANTS

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI NO KA COA STATE OF MISSISSIPPI BRIEF FOR THE APPELLEE

No.2007-IA BRIEF OF APPELLEES LA TISHA MCGEE. ET AL.

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI NO CA COA STATE OF MISSISSIPPI BRIEF FOR THE APPELLEE

Transcription:

E-Filed Document Nov 1 2016 10:30:50 2015-CA-00739-COA Pages: 10 IN THE COURT OF APPEALS FOR THE STATE OF MISSISSIPPI NO. 201S-CA-00739 2015-CA-00739 SHELBY J. KILPATRICK APPELLANT/CROSS-APPELLEE v. V. HOUSTON T. JARVIS, JR. & WILLIAM C. JARVIS APPELLEES/CROSS APPELLANTS RESPONSIVE BRIEF OF APPELLEES/CROSS-APPELLANTS HOUSTON T. JARVIS, JR., AND WILLIAM C. JARVIS TO REPLY BRIEF MARK A. SCARBOROUGH P. 0 O.. BOX 3662 MERIDIAN, MS 39303 TELEPHONE: 601/483-4042 FACSIMILE: 601/483-4242 6011483-4242 masatty82@att.net MSB #6501

IN THE COURT OF APPEALS FOR THE STATE OF MISSISSIPPI NO. 2015-CA-00739 SHELBY J. KILPATRICK APPELLANT/CROSS-APPELLEE V. HOUSTON T. JARVIS, JR. & WILLIAM C. JARVIS APPELLEES/CROSS APPELLANTS CERTIFICATE OF INTERESTED PERSONS The undersigned counsel of record certifies that the following listed persons have an interest in the outcome of this case. These representations are made in order that the justices of the Supreme Court and/or the judges of the Court of Appeals may evaluate possible disqualification or recusal. Shelby Jean Kilpatrick- Defendant/ Appellant/Cross-Appellee Spinks Law Inc.-Attorneys for Appellant/Cross-Appellee George H. Spinks-Attorney for Appellant/Cross-Appellee Houston T. Jarvis, Jr., and William C. Jarvis-Plaintiffs/Appellees/Cross Appellants Mark A. Scarborough-Attorney for Plaintiffs/ Appellees/Cross Appellants Hon. Joseph Kilgore- Chancellor, Trial Corni s/ Mark A. Scarborough Mark A. Scarborough MSB #650J Mark A. Scarborough, Attorney P. 0. Box 3662 Meridian, MS 39303 Phone No.: 601/483-4042 Fax No.: 601/483-4242 masatty82@att.net

TABLE OF CASES, RULES AND OTHER AUTHORITIES Mississippi Cases Allgood v. Allgood, 473 So.2d 416 (Miss. 1985)....,............ 2 Brooks v.brooks, 882 So.2d 230, 233 (Miss. 2004).......................... 3 Calcote v. Calcote, 583 So.2d 197, 199 (Miss. 1991)...........,........ 2 Cooper et al v. Gilder et ai, No. 2007-CA-00793-COA.......,......,....... 2 Curtis v. Curtis, 59 So.3d 623, 629 (Miss. 2011)...,............... 2,3 Griffin v. Armana, 687 So.2d 1188, 1194-1195 (Miss. 1996)................... 2 In Re Atkins v. Sartin, 42 So.2d 754 (Miss. 1982)........................... 2 In Re Bodman v. Bodman, 674 So.2d 1245 (Miss. 1996)..................... 3 McBride v. McBride, 110 So.3d 356, 360 (Miss. 2013)........................ 3 Perkins v. Perkins, 787 So.2d 1256, 1261 (Miss. 2001)........................ 2 Sojourner v. Sojourner, 247 Miss. 342, 153 So.2 803 (Miss. 1963).............. 2

TABLE OF CONTENTS Cross!Appellants' Summary of Res]?onsive Argument.......................... 1 Cross! Appellants' Responsive Argument.................................... 2 Cross! Appellants' Conclusion............................................. 5 Cross! Appellants' Certificate of Service..................................... 6

SUMMARY OF RESPONSIVE ARGUMENT The trial court's failure to include Jeanie's $83,452.19 Certificate of Deposit as an asset of Bud's Estate was a clear error oflaw and manifest injustice, and warrants reversal on that lssue.

CROSS-APPELLANTS' RESPONSIVE ARGUMENT The trial court erred in failing to grant that part of the Cross-Appellants' Amended Motion for New Trial or Amendment of Judgment that sought the imposition of a constructive trust on additional sums of money. The trial court was faced with the task of determining what assets were a part of Bud's Estate. The trial court found that the balances remaining in Bud's checking account and liquid CD on the date of his death should be assets of his Estate, and the trial court brought them into the Estate by the imposition of a constructive trust. "A constructive trust is a fiction of equity" and "... a formula through which the conscience of equity finds expression." Griffin v. Armana, 687 So. 2d 1188, 1194-1195 (Miss. 1996). "Constructive trusts are created for the purpose of preventing unjust enrichment...". Allgoodv. Allgood, 473 So.2d 416 (Miss. 1985). The constructive trust cases have been cited in other parts of our brief, and those arguments are also adopted and incorporated herein by reference. See also Calcote v. Calcote, 583 So.2d 197, 199 (Miss. 1991), and Cooper v. Gilder et ai., No. 2007-CA-793-COA, quoting Sojourner v. Sojourner, 153 So.2d 803 (Miss. 1963). Houston and Bill's motion under Rule 59 of the Mississippi Rules of Civil Procedure gave the trial court a chance to reconsider its prior [mdings on certain matters. The trial court denied the Rule 59 motion in part, but granted it in part. The trial court granted Houston and Bill a constructive lien against Jeanie's interest in the real property that formerly belonged to Bud. The significance of that ruling was not readily apparent at the time. "An appeal from a denial of a Rule 59 motion may address the merits of the entire underlying proceeding...". Curtis v. Curtis, 59 So.3d 623, 629 (Miss. 2011), citing Perkins v. Perkins, 787 So.2d 1256, 1261 (Miss. 2001). This appellate Court "... must ask whether (the

ruling of the trial court) was legal error or manifest injustice...". Curtis at page 629. The appellate Court's review can "... encompass both the denial of reconsideration and the underlying judgment...". McBride v. McBride, 110 So.3d 356, 360 (Miss. 2013). On page 17 of her Reply Brief, Jeanie misquotes Brooks v. Brooks, 882 S02.230, 233 (Miss. 2004). She states that under a Rule 59 motion the movant must show the"... (iii) need to correct a clear error oflaw or to prevent manifest justice" in order to prevail. This was clearly a typographical error, but it serves to remind us ofthe trial court's function. The trial court, being a court of equity, was trying to prevent manifest injustice by using the tools and remedies available to it. A constructive trust was an available remedy, and was the one employed by the trial court. The trial court found that Jeanie would be "unjustly enriched" (CP 297) if the remaining account balances became hers. Providing care for Bud was something that Jeanie chose to do, and she "... benefitted greatly in a financial sense from Bud's assets." (CP 295). The balances that remained in Bud's accounts were no longer needed for his necessities, and equity required that those funds come back into Bud's Estate. But, the trial court's failure to bring the proceeds from the Jeanie's Certificate of Deposit back into the Estate"... was legal error or manifest injustice...". Curtis v. Curtis, 59 So.3d 623,629 (Miss. 2011). Houston and Bill submit that this was also contrary to the reasoning found in the cases they cited previously: In Re Bodman v. Bodman, 674 So.2d 1245, 1250 (Miss. 1996), and In Re Atkins v. Sartin, 422 So.2d 754, 756 (Miss. 1982). Jeanie, much like the Convservator in Bodman, "... violated her fiduciary duty by neglecting the intent of the ward and unlawfully invading the beneficiaries' accounts." (Bodman at page 1250). Jeanie terminated the Certificates of Deposit that Bud owned with both Houston and Bill jointly and also as payable on death beneficiaries, and she used those funds as she chose. Yet she tried to preserve 3

the funds that might come to her upon Bud's death, and she did not contribute any of those funds toward her ward's necessities. The Citizens Bank CD #171080825 in the amount of$83,452.19 was paid to Jeanie in May of2012. (CP 47, Ex. 47). It would be legal error or a manifest injustice if Jeanie was allowed to keep those proceeds. This Court should reverse the trial court on that issue, and find that those proceeds ($83,452.1 9) are a part of Bud's Estate. A reversal on that issue and an affirmance of the trial court on all other matters would produce an interesting and equitable result. If one adds the amount of the CD Jeanie withheld ($83,452.19) to the sums that are already subject to the trial court's constructive trust ($157,706.71), the resulting total is $241,158.70. If that total is divided by three-one share each for Jeanie, Houston, and Bill- the result is $80,386.23 per beneficiary. That would practically restore the CDs that Bud owned with Houston and Bill as payable on death beneficiaries, before the CDs were terminated by Jeanie, and it would allow Jeanie to keep all but $3,000.00 or so of the CD that she held out for herself. Also, Houston and Bill would have the right to enforce their constructive lien if Jeanie was unable to pay back the account balances that are subject to the constructive trust. The trial court's finding on the Rule 59 motion is worth repeating here: "The court fmds that this request is well-taken and grants the petitioners (Houston and Bill) a lien upon the real property formerly owned by Houston T. Jarvis, Sr. (Bud's full name) in the amount of$157,706.7l. (CP 319). A result along these lines would achieve both an equitable result and the "manifest justice" that Jeanie mentioned in her brief.

CONCLUSION "Manifest justice" would be served and an equitable result would be reached by a finding that Jeanie's $83,452.19 CD was an asset of Bud's Estate. The triaj court's failure to include this asset was a clear error of law in both its original Judgment and again in its denial in part of Houston and Bud's Rule 59 motion, and resulted in manifest injustice. The triaj court should be affirmed on its finding that the balances in the checking account and the liquid CD, totaling $157,706.71 as of the date of Bud's death, were assets of Bud's Estate. The trial court's imposition of a constructive lien in favor of Houston and Bill in the amount of $157,706.71 and against Jeanie's interest in the reaj property should also be affirmed.

CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Responsive Brief of Appellee/Cross Appellants, Houston T. Jarvis, Jr. and William C. Jarvis, was served on the trial Judge in this cause by Certified Mail, and served electronically on the following counsel of record on November 1, 2016, by the Mississippi Electronic Court System: Judge Joseph Kilgore P. 0. Box 1006 Philadelphia, MS 39350 Hon. George H. Spinks Counsel for Appellant/Cross-Appellees P. 0. Box478 DeKalb, MS 39328 spinkslaw@hotmail.com j s_r WITNESS MY SIGNATURE on this the day of November, 2016. Mark A. Scarborough MSB #6501 Mark A. Scarborough, Attorney P. 0. Box 3662 Meridian, MS 39303 Phone No.: 601/483-4042 Fax No.: 601 /483-4242 masatty82@att.net b