Columbus Bank & Trust vs. Michael A. Eddings Lawsuit: Docket, Notice of Removal, Complaint, Exhibit A

U.S.
District Court [LIVE AREA]

Georgia Middle District (Columbus)
CIVIL DOCKET FOR CASE #: 4:11-cv-00184-MSH
COLUMBUS BANK AND TRUST COMPANY v. LAW
OFFICE OF MICHAEL A EDDINGS PC et al
Assigned to: US Mag Judge Stephen Hyles
Cause: 28:1441 Petition for Removal- Torts to Land
Date Filed: 11/23/2011
Jury Demand: None
Nature of Suit: 290 Real Property: Other
Jurisdiction: U.S. Government Defendant
Date Filed # Docket Text
11/23/2011 1 NOTICE OF REMOVAL by UNITED STATES OF AMERICA from Superior Court of
Muscogee County, case number SU11CV3875, consisting of Petition for Interpleader,
Answers, Motions, and Orders (Attachments: # 1 Exhibit A - State Court File, # 2 Civil
Cover Sheet)(tlf). (Entered: 11/23/2011)
11/23/2011 2 MOTION for Disbursement of Funds by TRC GLOBAL SOLUTIONS INC filed by
William Alan Buchanan, Benjamin Arthur Land(tlf). (Entered: 11/23/2011)
11/23/2011 3 Consent Form (28 USC 636(c)(1)) sent (tlf). (Entered: 11/23/2011)
11/28/2011 Case reassigned to Judge W. Louis Sands. Judge Clay D. Land no longer assigned to the
case (tlf). (Entered: 11/28/2011)
11/28/2011 4 NOTICE OF FILING by WELLS FARGO BANK, N.A., TRUSTEE, JPMORGAN
CHASE BANK, N.A. re 1 Notice of Removal, (Attachments: # 1 Exhibit A)(Jared,
Julie) (Entered: 11/28/2011)
12/02/2011 5 AMENDED ANSWER by TRC GLOBAL SOLUTIONS INC. (Land, Benjamin)
(Entered: 12/02/2011)
12/02/2011 6 ANSWER to Complaint by UNITED STATES OF AMERICA. (Attachments: # 1
Verification, # 2 Certificate of Service)(Wall, Sheetul) (Entered: 12/02/2011)
12/09/2011 7 ANSWER to Complaint by Primary Residential Mortgage, Inc.. (Attachments: # 1
Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D)(Franzen, Therese) (Entered:
12/09/2011)
12/09/2011 8 MOTION for Disbursement of Funds by Primary Residential Mortgage, Inc. filed by
Therese G. Franzen. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4
Exhibit D)(Franzen, Therese) (Entered: 12/09/2011)
12/19/2011 9 ANSWER to Complaint by Gregory Watkins.(Spence, O) (Entered: 12/19/2011)
12/19/2011 10 ANSWER to Complaint by Federal National Mortgage Association. (Attachments: # 1
Exhibit A, # 2 Exhibit A-1, # 3 Exhibit B)(Olson, Frank) (Entered: 12/19/2011)
12/20/2011 11 RESPONSE filed by UNITED STATES OF AMERICA re 8 MOTION for
Disbursement of Funds, 2 MOTION for Disbursement of Funds (Byrd, Charles)
CM/ECF LIVE - U.S. District Court:gamd https://ecf.gamd.uscourts.gov/cgi-bin/DktRpt.pl?205851990154892-L_4...
1 of 4 2/5/2012 3:53 PM
(Entered: 12/20/2011)
12/22/2011 12 RESPONSE filed by JEROME ROGERS re 8 MOTION for Disbursement of Funds
(Allison, Ray) (Entered: 12/22/2011)
12/22/2011 13 RESPONSE filed by JEROME ROGERS re 2 MOTION for Disbursement of Funds
(Allison, Ray) (Entered: 12/22/2011)
12/22/2011 14 CONSENT TO PROCEED BEFORE THE U.S. MAGISTRATE JUDGE (Byrd,
Charles) Modified on 12/22/2011 (tlf). (Entered: 12/22/2011)
12/22/2011 15 NOTICE OF ASSIGNMENT. Case reassigned to Magistrate Judge US Mag Judge
Stephen Hyles for all further proceedings (tlf). (Entered: 12/22/2011)
12/22/2011 16 RESPONSE filed by UNITED STATES OF AMERICA re 8 MOTION for
Disbursement of Funds (Byrd, Charles) (Entered: 12/22/2011)
12/29/2011 17 RESPONSE filed by TRC GLOBAL SOLUTIONS INC re 8 MOTION for
Disbursement of Funds (Land, Benjamin) (Entered: 12/29/2011)
01/03/2012 18 MOTION to Deposit Funds by UNITED STATES OF AMERICA filed by Charles W.
Byrd. (Attachments: # 1 Text of Proposed Order)(Byrd, Charles) (Entered: 01/03/2012)
01/04/2012 19 RESPONSE filed by TRC GLOBAL SOLUTIONS INC re 18 MOTION to Deposit
Funds (Land, Benjamin) (Entered: 01/04/2012)
01/04/2012 20 RESPONSE filed by PRIMARY RESIDENTIAL MORTGAGE INC re 18 MOTION to
Deposit Funds (Franzen, Therese) (Entered: 01/04/2012)
01/05/2012 21 RESPONSE filed by JEROME ROGERS re 18 MOTION to Deposit Funds (Allison,
Ray) (Entered: 01/05/2012)
01/05/2012 22 RESPONSE filed by COLUMBUS BANK AND TRUST COMPANY re 18 MOTION
to Deposit Funds (Tucker, William) (Entered: 01/05/2012)
01/05/2012 23 RESPONSE filed by FBMC MORTGAGE CORPORATION re 18 MOTION to
Deposit Funds (Attachments: # 1 Certificate of Service)(Spence, O) (Entered:
01/05/2012)
01/05/2012 24 RESPONSE filed by WILLIAM REMBERT re 18 MOTION to Deposit Funds
(Attachments: # 1 Certificate of Service)(Spence, O) (Entered: 01/05/2012)
01/05/2012 25 RESPONSE filed by GREGORY WATKINS re 18 MOTION to Deposit Funds
(Attachments: # 1 Certificate of Service)(Spence, O) (Entered: 01/05/2012)
01/06/2012 NOTICE of SETTING Hearing. Status Conference set for 1/19/2012 01:30 PM in
Columbus before US Mag Judge Stephen Hyles. (tls) (Entered: 01/06/2012)
01/18/2012 26 ANSWER to Complaint, COUNTERCLAIM against All Parties by LAW OFFICE OF
MICHAEL A EDDINGS PC.(POYDASHEFF, ROBERT) (Entered: 01/18/2012)
01/18/2012 27 NOTICE of filing Verification by Federal National Mortgage Association re 10 Answer
to Complaint (OLSON, FRANK) (Entered: 01/18/2012)
2 of 4 2/5/2012 3:53 PM
01/19/2012 28 Minute Entry for proceedings held before US Mag Judge Stephen Hyles: Status
Conference held on 1/19/2012, and continued to January 30, 2012. ( Status Conference
set for 1/30/2012 01:30 PM in Columbus before US Mag Judge Stephen Hyles) (FTR
Gold, 1:30 PM) (tls) (Entered: 01/19/2012)
01/19/2012 29 ORDER granting 18 Motion to Deposit Funds. Ordered by US Mag Judge Stephen
Hyles on 1/19/12. (tls) (Entered: 01/19/2012)
01/26/2012 30 AMENDED DOCUMENT by PRIMARY RESIDENTIAL MORTGAGE
INC,amending 7 Answer to Complaint (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3
Exhibit C, # 4 Exhibit D)(Franzen, Therese) (Entered: 01/26/2012)
01/27/2012 31 NOTICE of Attorney Appearance by Therese G. Franzen on behalf of Crescent
Mortgage Company (Franzen, Therese) (Entered: 01/27/2012)
01/27/2012 32 NOTICE of Attorney Appearance by Dewan Sharmin Arefin on behalf of Crescent
Mortgage Company (Arefin, Dewan) (Entered: 01/27/2012)
01/27/2012 33 MOTION for Summary Judgment by JEROME ROGERS filed by Ray L. Allison.
(Attachments: # 1 Memorandum in Support)(Allison, Ray) (Entered: 01/27/2012)
01/30/2012 34 ANSWER to Complaint by CRESCENT MORTGAGE COMPANY. (Attachments: # 1
Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E)(Franzen, Therese)
(Entered: 01/30/2012)
01/30/2012 35 Minute Entry for proceedings held before US Mag Judge Stephen Hyles: Status
Conference held on 1/30/2012. Proposed Scheduling/Discovery Order should be
submitted no later than close of business 02/22/2012. (esl) [Mr. Flowers called as local
counsel by Mr. Olson.] (Entered: 01/30/2012)
01/30/2012 This is a text only entry; no document issued.ORDER re 26 Answer to Complaint,
Counterclaim filed by LAW OFFICE OF MICHAEL A EDDINGS PC. Upon inquiry at
the status conference in this hearing on 1/30/12 regarding its Counterclaim, Respondent
Law Office of Michael A. Eddings P.C. dismissed his Counterclaim in open court. Said
counterclaim is no longer pending and has been dismissed. Ordered by US Mag Judge
Stephen Hyles on 1/30/12. (lws) (Entered: 01/30/2012)
01/31/2012 36 Arbitration Referral Letter sent 1/31/2012 (hrm) (Entered: 01/31/2012)
02/01/2012 37 NOTICE of Attorney Appearance by Therese G. Franzen on behalf of USAA Federal
Savings Bank (Franzen, Therese) (Entered: 02/01/2012)
02/01/2012 38 NOTICE of Attorney Appearance by Dewan Sharmin Arefin on behalf of USAA
Federal Savings Bank (Arefin, Dewan) (Entered: 02/01/2012)
PACER Service Center
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Description: Docket Report Search Criteria: 4:11-cv-00184-MSH
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IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF GEORGIA
COLUMBUS DIVISION

COLUMBUS BANK AND TRUST :
COMPANY, A DIVISION OF SYNOVUS :
BANK, :
:
Petitioner, :
:
v. : Case No. _________________
:
LAW OFFICE OF MICHAEL A. EDDINGS, :
P.C., FIRST AMERICAN TITLE INSURANCE :
COMPANY, FIRST AMERICAN TITLE :
COMPANY, JEROME ROGERS, LACHONE :
TRICE, IKE A. NWAOBI, UNITED STATES :
OF AMERICA, FOR US CORPS OF :
ENGINEERS, FEDERAL NATIONAL :
MORTGAGE ASSOCIATION, TRC GLOBAL :
SOULTIONS, INC., ELIZABETH WALLER, :
ET AL., :
:
Respondents. :
_________________________________________

NOTICE OF REMOVAL

TO: The Honorable Judges of the United States District Court for the Middle District of
Georgia, Columbus Division

COMES NOW, respondent United States Army Corps of Engineers, an agency of the
United States of America, by and through the United States Attorney for the Middle District of
Georgia and respectfully represents:
1.
That an agency of the United States is a respondent in the above-captioned civil action now
pending in the Superior Court of Muscogee County as case number SU11-CV-3875. No trial has
yet been had in this action.

Case 4:11-cv-00184-MSH Document 1 Filed 11/23/11 Page 1 of 5
4-11-cv-184
2.
Petitioners interpleader and first amendment thereto shows that The Law Office of
Michael A. Eddings, P.C. has been and currently is a customer of Petitioner. Said Respondent has
maintained a depository IOLTA Trust Account with Petitioner and the account is believed to
contain funds belonging to one or more of the Respondents.
4.
The United States is also a respondent in the above-referenced interpleader action. The
IOLTA Trust Account at issue in this case contains funds belonging to the United States, and
payment of these funds are at risk.
5.
An Order on Interpleader entered on October 28, 2011, directs Petitioner to interplead the
funds held in the account therein into the registry of the Court. Said funds are currently held by
the Clerk of Muscogee Superior Court, and may be transferred to this Court if deemed appropriate.
6.
That to the extent an agency of the United States has been sued for any act under color of
such office or on account of any right, title or authority claimed under any Act of Congress for
collection of the revenue, the matter is removable from state to federal court under 28 U.S.C. '
1442.
7.
As required by 28 U.S.C. ' 1446(a), the documents comprising Exhibit A are copies of all
the documents received by the United States in this action. There may be additional documents
filed with the Clerk of Superior Court of Muscogee County, and upon direction of this Court, the
complete record in this case may be transferred in accordance with the provisions of 28 U.S.C.
1447(b).
8.
Pursuant to 28 U.S.C. ' 1446(d), written notice of this removal will be provided to all
adverse parties, and a copy of this notice of removal will be filed with the Clerk of Superior Court
of Muscogee County.
9.
The filing of this Notice of Removal is timely, pursuant to 28 U.S.C. ' 1446(b).

WHEREFORE, respondent United States of America removes Case Number
SU11-CV-3875 currently pending in the Superior Court of Muscogee County to this Court for
such further proceedings as may be appropriate.
Respectfully submitted, this 23
nd
day of November, 2011.
MICHAEL J. MOORE
UNITED STATES ATTORNEY

BY: s/Charles W. Byrd
Charles W. Byrd
Assistant United States Attorney
Georgia Bar No. 100850

BY: s/Sheetul S. Wall
Sheetul S. Wall
Assistant United States Attorney

U. S. Attorneys Office
Middle District of Georgia
P.O. Box 2568
Columbus, GA 31902
Ph: (706) 649-7700
Fax: (706) 649-7667


CERTIFICATE OF SERVICE
This is to certify that I have this date filed the Notice of Removal with the Clerk of
United States District Court using the CM/ECF system which will send notification of such filing
to the following: N/A
I also certify that I have this date mailed by United States Postal Service the document and
a copy of the Notice of Electronic Filing to the following non-CM/ECF participant:
Law Office of Michael A. Eddings, P.C.
c/o Michael A. Eddings, As Registered Agent
860 Brookestone Center Parkway, Suite B
Columbus, GA 31904

Jeffrey Schneider, Esq.
Weissman, Nowack, Curry & Wilco, P.C.
One Alliance Center, 4
th
Floor
3500 Lenox Road
Atlanta, GA 30326
Attorney for First American Title Insurance Company

William S. McFadden, Esq.
McFadden, Lyon & Rouse, LLC
718 Downtowner Blvd.
Mobile, AL 36609
Attorney for Federal National Mortgage Association

Ray L. Allison, Esq.
Denney, Pease & Allison
P.O. Box 2648
Columbus, GA 31902
Attorney for Jerome Rogers

Christopher Meacham, Esq.
Meacham, Early, Fowler, P.C.
P.O. Box 9031
Columbus, GA 31908
Attorney for Lachone Trice and Ike A. Nwaobi

Benjamin A. Land
Buchanan & Land, LLP
P.O. Box 2848
1425 Wynnton Road
Columbus, GA 31902
Attorney for TRC Global Solutions, Inc.

William L. Tucker
Page, Scrantom, Sprouse, Tucker & Ford, P.C.
1111 Bay Avenue
Third Floor, Symovus Centre
P.O. Box 1199
Columbus, GA 31902-1199
Attorneys for Columbus Bank & Trust Company,
A Division of Synovus Bank

O. Wayne Spence, Esq.
O. Wayne Spence, P.C.
2945 Gardenia Street
Columbus, GA 31906
Attorney for FBMC Mortgage Corporation d/b/a First Bankers Mortgage Corporation,
and William Rembert

This 23
nd
day of November, 2011.

s/Charles W. Byrd
CHARLES W. BYRD
ASSISTANT U.S. ATTORNEY
Exhibit "A"
Case 4:11-cv-00184-MSH Document 1-1 Filed 11/23/11 Page 1 of 101
IN THE SUPERIOR COURT OF MUSCOGEE COUNTY
STATE OF GEORGIA
COLUMBUS BANK AND TRUST
'"
COMPANY, A DIVISION OF SYNOVUS
'"
BANK,
'"
CIVIL ACTION FILE
'"
Petitioner, NO. ___
'"
v.
*
'"
SUI! {!y do/':5
'"
LAW OFFICE OF MICHAEL A. EDDINGS, '"
P.C., FIRSTAMERICAN TITLE INSURANCE'"
::t r.:;
COMPANY, FIRST AMERICAN TITLE '" UJ
c:
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---
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(.1'''};--- ,
COMPANY, JOHN DOE 1, JOHN DOE '"
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2, JOHN DOE 3, ET AL., '"
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Respondents.
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PETITION FOR INTERPLEADER
0
'"< f\1
Columbus Bank and Trust Company, a division of Synovus Bank ("CB&T");Ules
this Petition for Interpleader pursuant to the provisions of O.C.G. A. et. -seq.,
and in so doing, shows as follows:
1.
Law Office of Michael A. Eddings, has its principal place of business and
Registered Agent for Service in Muscogee County, Georgia. Said Respondent may be
served by serving its Registered Agent, Michael A. Eddings, 860 Brookstone Centre
Parkway, Suite B, Columbus, Georgia 31904.
2.
On information and belief, First American Title Insurance Company, is a
California corporation qualified to do business in the State of Georgia, with its principal
office at 5607 Glenridge Drive, N.E., Suite A200, Atlanta, Georgia 30342. It may be
served at said address by serving its Registered Agent for Service, C. Scott Logan.
3.
On infonnation and belief, First American Title Company, is a California
corporation qualified to do business in the State of Georgia, with its Registered Agent for
Service, Corporation Service Company, 40Teclmology Parkway, South, Suite 300,
Norcross, Georgia 30092.
4.
On infonnation and belief, John Doe 1, is believed to be a claimant of the funds
noted herein and to be a resident of Muscogee County, Georgia.
S.
6.
7.
On information and belief, there may be other claimants of the funds noted herein.
Said claimants to be identified by amendment and to be served accordingly.
8.
The Law Office of Michael A. Eddings, P.C. has been and currently is a customer
of Petitioner. Said Respondent has maintained a depository account with Petitioner
which is designated an IOLTA Trust Account, Account Number -----766, which account
is believed to contain funds belonging to one or more of the Respondents and possibly
other persons or entities yct identified.
9.
On October 28, 2011, Petitioner was advised that there is considerable uncertainty
as to the specific ownership of the funds on deposit in said account and that there is a risk
of the funds in question being delivered to persons other t h ~ those who have legitimate
claims for said money.
10.
On information and belief, given the potential claims to said funds and the
uncertainty as to the ownership thereof, Petitioner shows that it is doubtful or dangerous
for Petitioner to act in the disbursement thereof and that it is appropriate for Petitioner to
apply to equity to compel all claimants to interplead and to show cause to this Court as to
why said funds should be disbursed to them.
11.
The account and funds held are situated in Muscogee County, Georgia, and as
such venue and jurisdiction are proper herein.
12.
Given the conflicting information and claims relative to said funds, Petitioner
cannot safely pay the funds on deposit to anyone respondent or to anyone person, until
the respective rights of said persons or entities have been determined and otherwise
adjudicated by the Court.
13.
Petitioner makes no claim to the funds held in the aforesaid account or to the
funds hereby tendered into the Registry of the Court. As to the remaining funds on
deposit, Petitioner herewith seeks permission to deposit said funds along with any and all
future deposits into said accounts into the registry of the Court pending a detennination
by the Court of the appropriate disposition of the account and funds in question.
14.
Petitioner reserves the right to amend its Petition for the purpose of seeking
direction or to otherwise having adjudicated the rights of Respondents,
Wherefore, Petitioner prays as follows:
(a) That the usual proceedings be had as in all cases of a Bill of
Interpleader;
(b) That the Court issue an order directing the disposition of the funds
described herein;
(c) That an Order be issued discharging Petitioner from further
obligation with respect to said monies and account;
(d) That Petitioner be pennitted to recover its costs from the funds paid into
the registry of the Court, and
(e) For such other and further relief as may be just and proper, premises
considered.
, .
day of October, 2011.
P AGE, SCRANTOM, SPROUSE,
TUCKER & FORD, :']) ..-.-
. By: V.MA.-T:../
William L. Tucker
1111 Bay Avenue State Bar No.: 718050
Third Floor, Synovus Centre
Post Office Box 1199 Attorneys for Columbus Bank and
Columbus, Georgia 31902-1199 Trust Company, a Division of Synovus
(706) 324-0251 Bank
STATE OF GEORGIA
*
*
BANK,
*
CIVIL ACTION fILE ..
*
Petitioner,
*
No.S01l ~ V ' 3 8 ' 1 ~
*
v.
*
*
LAW OFFICE OF MICHAEL A EDDINGS, *
P.C., FIRSTAMERICAN TITLE INSURANCE*
COMPANY, FIRST AMERICAN TITLE *
COMPANY, JOHN DOE 1, JOHN DOE *
2, JOHN DOE 3, ET AL., *
*
Respondents.
*
VERIFICATION TO PETITION FOR INTERPLEADER
GEORGIA, MUSCOGEE COUNTY.
Comes now, TIM FARMER, having been duly sworn, and states that the facts and
information contained in the foregoing Petition for Interpleader are, to the best of his
knowledge and belief, true and correct and that neither ~ e nor Columbus Bank and Trust
Company, a Division of Synovus Bank, are in collusion with either or any party claiming
the property or funds specified in said Petition.
TIM FARMER, on behalf
of and as an employee of Columbus
Bank and Trust Company
Sworn to and subscribed to before
me thi day of October, 201 L
IN THE SUPEIUOR COURT OF MUSCOGEE COUNTY
STATE OF GEORGIA
*
*
BANK,
*
CIVIL ACTION FILE --
*
Petitioner, No.50 l\ C!.-U ~ g1 '::::>
*
*
v.
*
*
LAW OFFICE OF MICHAEL A. EDDINGS, *
P.C., FIRSTAMEIUCAN TITLE INSURANCE*
COMPANY, FIRST AMEIUCAN TITLE *
COMPANY, JOHN DOE 1, JOHN DOE *
2, JOHN DOE 3, ET AL., *
*
Respondents.
*
ORDER ON INTERPLEADER
The Court having considered Columbus Bank and Trust Company, a Division of
Synovus Bank (CB&T) Petition, Petitioner is hereby directed to interplead the funds held
in the account identified therein into the registry of this Court. Said funds to be held by
the Clerk of Superior Court until such time as the Court may adjudicate the rights and
appropriate disposition of said funds.
This ffiay of atM1u" 2011. e 5"!J p.II} .
~ -
Judge, Superior Court of Muscogee
County, Georgia
OFFICIAL CHECK
csc;:r
431020435
a division of SYNOVUS' BANK .
p.o. BOX 120 COLUME\US, GA 31902 Jl4::Q.
611
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Cl erk Df SUper1ot' COlirt
1'........ '
tJI9'.9d.I'l'I'E'l(, Columbus Ban.k& Trust
AUTHORIZED SIGNATURE ,.
PIYll
PAYABLE THROUGH SYNOVUS BANK COLUMBUS, GEORGIA
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STATE OF GEORGIA
COLUMBUS BANK AND TRUST CML ACTION FILE NO.
COMPANY, A DIVISION OF SYNOVUS SU-U-CV-3875
BAl'll(,
Petitioner
vs.
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LAW OFFICE OF MICHAEL A. e::> f'T1
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EDDINGS, P.C., FIRST AMERICAN
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TITLE INSURANCE COMPANY, FIRST ;OM
AMERlCAN TITLE COMPANY, JOHN
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Respondent ......... M
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ANSWER TO PLAINTIFF'S PETITION FOR INTERPLEADER
COMES NOW, Defendant, Ike A. Nwaobi, herein an unnamed but intended Respondent
in the above-styled civil action (hereinafter referred to as "Nwaobi") and submits this his Answer
to Plaintiff's Petition for Interpleader responding seriatim to the numbered paragraphs thereof,
and respectfully shows unto this Honorable Court as follows:
Answer
1.
Nwaobi admits Paragraph 1 of Plaintiff's Petition.
2.
Nwaobi admits Paragraph 2 ofPlaintifrs Petition.
3.
Nwaobi admits Paragraph 3 ofPlaintifrs Petition.
ME&I/GA/LitigationlGen'l CivillNwaobi, Ike
Answer to Plaintiff's Petition for Interpleader
4.
Nwaobi admits Paragraph 4 of Plaintiff s Petition. By way of further Answer, Nwaobi is
a claimant of funds noted in Plaintiff s Petition, is a resident of Muscogee County, Georgia, and
believes that he is the Respondent identified in Paragraph 4 of said Petition as John Doe 1.
Nwaobi acknowledges that there may be other claimants of the funds noted in Plaintiffs
Petition, and that ifhe is not John Doe I, he should be specifically named as one of the claimants
for such funds.
5.
Nwaobi admits Paragraph 5 of Plaintiffs Petition.
6.
7.
8.
9.
10.
Nwaobi admits Paragraph 10 of Plaintiff's Petition. By way of further Answer, Nwaobi
shows that on October 27, 2011, he wire-transferred the amount of Nine Thousand Eight
Hundred and nolI 00 ($9,800.00) United States Dollars to the Law Offices of Michael A.
Eddings, P.C., depository account 30050766, for a real estate closing to be held on or about
November 2,2011. A copy of Nwaobi's wire transfer request is attached hereto as Exhibit "10."
ME&1/GAlLiligationiGen'[ CivillNwaobi, Ike
Answer to Plaintiff's Petition for interpleader
11.
Nwaobi admits Paragraph 11 ofPlaintiff's Petition.
12.
13.
14.
15.
Responding to the unnumbered" WHEREFORE' paragraph of Plaintiff's Petition,
Nwaobi responds seriatim to the sublettered paragraphs as follows:
(a) This subparagraph requires no response.
(b) Nwaobi has no objection to this subparagraph.
(c) Nwaobi has no objection to this subparagraph.
(d) Nwaobi has no objection to this subparagraph.
( e) This subparagraph requires no response.
16.
Nwaobi demands strict proof of any and all allegations contained in Plaintiff's Petition
which are not expressly admitted or denied.
Having fully responded to Plaintiff's Petition for Interpleader, Nwaobi prays unto this
Honorable Court as follows:
(a) That this Answer be accepted and filed in accordance with law;
ME&J/GNLitigationlGen'\ CivilINwaobi, Ike
(b) That Nwaobi's funds in the amount ofNine Thousand Eight Hundred and nollOO
($9,800.00) Dollars paid by Petitioner into the Registry ofthis Court be disbursed
to Nwaobi as the Court may deem appropriate;
(c) That Nwaobi be pennitted to recover attorney fees and costs from the funds paid
into the Registry of this Court; and,
(d) For such other and further relief as this Honorable Court deems just and proper,
RESPECTFULLY SUBMITTED this '1111 day ofNovember, 2011.
MEACHAM, EARLEY & FOWLER, P.e.
B y ; ~ ~ ~ ~ ~ - = ____________
PO Box 9031
Christophe Meacham, Esquire
GA Bar #0500050
Phone: 706-576-4064
Attorneys for Defendant, Ike A. Nwaobi
Fax: 706-596-0621
ME&J/GAlLitigationlGen'l CivillNwaobi,Ike
EXHIBIT "10"
ME&J/GAlLitigationlGen'J CivillNwao bi, Ike
Answer to Plaintiffs Petition for Interpleader
Wire Transfer Services
Outgoing Wire Transfer Request
A customer or team member, with thHustomor thi< form whon requesting to send a wire. Outgoing wire, can only be sent for WeDs Fargo
(U,lDmers. Retain the original copy in the bank and provide a copy to the, customer ensuring you give the customer the Agreement for OutgoIng Wire Troosfer
Request (pagel when loom Is accessed & preprinted on the back of printed Requ[red information i. noted w[th.n asteri.k. Not.:WeU. Fargo
Wire Transfer Services wUl route wires based on COf11lSpondent banking relationships. See back (page 2) for explanations of the Mexican (LABE 'Olll\t, tho SWIFT
81(. the International Routing Code (IRQ and tho International Bank Account Number (lBAN).
"Today's Date Send Date r.mo.ysubmtt wi...ft.,4:l0 C1.'lo,.must,",1d If,ther than tod.ll.rn", n., !bIfJ
L
I
1.0riginators InformatIon
Custor'ner's Name Phone Number
I \''(."0:; A !, I!" lAoS;1
BeneftclllrylReclpient Name
II 6\....1 cr\.- .(tl'chC>t'1 B r
"Beneficiary Acccunt Number, Mexican CLABE f or tho Intemat!oMI Bank Account NUmbel IBAN) where applicable;
i 30(1<::;;07?1,..,
Benefici.ry Address.Gty, Stat .. z;p Code (A physical address is required forfortlgn wire .)
I
Information fur the BenefKiary (Invokrou.,Puld>.", ord,r numb<r,.uJ BeneHdary Phone Number
L-______ ______________ __ _________________________ _____________
3. Benefidary Bank information 1n.;,I"b. __
Benef.ciary aank Name
I '..

Jnformadon for BoenefK:iary Sank (wires to Muican b4lllb Jequn the ruBE account number in tbt Bentfidil)' rutM1ions to correct pl)lnmtj
L-__________ __----------------------------
4. Jntennedlary Bank Information {ll!Is1s.ft1Iaodol_IMIIr".II<mlIStJlltb".ghb......-h1glh.t!naIbmoftdllyballk,) ThI"KtI ..oIom!......._"".I.....
. ___....u..,NY....nvu .... """" ..WolkF.'1.Bonlls..............
.', Optlon.l: "Intermediary Beneficiary Bank RTN or SWiFTBIC intemational Routlng Code :IRQ

Bank Name 'Interme"",ry Bank Account No.
o I
Intermediary Bank Address, Clty, State. Zip, Country (oplilNi illf<lmlation)
I
Information for Intermediary Bank.
I
Wire Fee Amount (the Transfer From accouj,lt wID be charged Ihe lea) The region that houses lhe account
being debited determines the fee amounL Use the fee information ......ble through Teamworks and/or b
the Banker's Guide. Do not use SVT/SVPlorreewhen aC(Qunt is Dotln your region. Additional fee, m.oy 2,'S.!!--.
apply (see page 2 of this form).
My Signature hen! Indi",t.. agreement to all of the information on this Outgoing Wire Transfer Request and lothe terms and conditions on the second page ofthl,
request. Fargo Bark if authorized to rely on the Information on this Request in making the requested funds transfer. Oate
I Jr) /1'11 JI
6. Bank Only - Bank Approval- Following MUST be <Dmpleted for ALL outgoing wlr....
"When Customer', account is not debited, the WIP Acc<>unt is funded by:
I 0 paid by Check Q paid Cash D Paid throu"h l!CCQ\![lt oInertban checl<inQ.savings,MRA, TRS or Hogan.. Reference Acct #;
Tax 10 'fl'pt'-Type 1\ No.are required when custorner's account Is not debited. Tax ID No. Iff nCBdtU<1I providt Aim ID I. *&(000''1)
I D Soc"'l SecurilY D rTIN 0 Non-U.S, Citl,en without TIN D Employer 1.0 . I
e.Customer Not Present
VerlfIc:atlon of OtIglnator 11.lIp..... fU. ..__1
Reason CAlier cannot come into the Bank caHers location Caller's lmmediate phone number
..._______ [dCgmp@nyDHomeDOther. I
Confll'J1la.tion of Request otbrrthan thl initiataJ calkcurtamerwmn.mnallon)
Ph<lne t to c.1I to verify request Time of caft to cuSlomer SoUla! used Token verified?
L-. I I Dll<!nkRecords OTelephoneDirectory POther: I DYes [dNo
Nam. of person placing call Customer Contact Na"", Customer
I I ! Q ApprQved the the transfer
T..1epnon., F"", orWritien Request(App"'''''.bn!'..tbyPnwour_I\gMII'.,Bllsln... e.nIio9l!gr,.... .. lMlof.uthori\yabo.. S...-I'''''''''
Approve"" Prlnted N.m. Approve'" Signature Dille
I Ix I
Agreement For Outgoing Wire Transfer Requests
Responsibility of the Bank. The Bank is only responsible for m.klng 0 good faith effort to exe<;ute the payment order described in the Outgoing Wore Transfer Request
(the'Order'). The Order may be sent by wire. telegroph,telepllono. cable, Or whatever other transmission method thellank considers to be ",asonable. The Orderm.y
be transmitted directly to the Benefici.ry Bank. or indirectly to the BenefICiary Sank through another bank,govemment agen<:y,or otMr third partythot the Bank
considers to be reasonable.
Agent. Bank m.y u!eagenl< ollis choke to perform .ny of Its obligations.
l.Jmi(ation of !.lability. The Bank win not be liable for any 1055 or d."'"9" due to the failure, delay,or error of:(1) the method of transmission selected by the Bank.
(2) athird party selected by the Sank to receiyethe omer,or (3) the Beneficiary Bank. IN NO EVENT WILL THE SANK Be LIABLE FOR DAMAGES AAlSlNG DIRECl1.Y OR
INDlRECl1.Y IF THo ORDER 15 EXECllTED BY THE BANK IN GOOD FAfTH AND IN ACCORDANCE WfTH tHETERMS OF THIS AGREEMENT. REGARD:.BS OFTHE FORM OR
NATURE OF A:'Y CLAIM OR ACTION, IN NO EVENT WILL THE BANI< BE LlABLE FOR I'UNITNE,INCIDENTAL OR CONSEQUENTIAL DAMAGES. WHETHER OR NOTTHE BANK
SHAll HAVE BEEN ADVISED OF THE POSSIIllUTY OF SUCH DAMAGES.
Reliance on information Provided. Bank may rely solely (I) on the .ccount number of the person ("Beneflciary1 who is to receiye the wir. transfer rather than the
Senefidary's name, and liii if provided by you.on the identification number of any other finand>1 through arto which the funds are to be tnlnsferred, rathe<
than the name of the financial institution.
InternationalWtreTraM..... A Payment omer ""pressed in U.s. Dollars will be sent in U.s. Dollars. Company may request that prior to executing. Payment omer,
Bank convert the .mount to be transferred from US. Dollars to the currern:y of a designated foreign government ",r Intergoyernmental orgaowlt.,n ("Foreign
Curren<:y1at Bank's sen ratefor e.change jn effect on the date Bank executes the Payment Order. If the financial in>titution df!'lgnated to receive the funds does
not pay the beneHclary specified in a Payment Order payable in foreign Currency and the fund. are retumed to Bank. Bank will not be liable fo<o ,um in exces, of
the yalue of the funds after they have been converted kom Foreign Currency to u.s.DoUars at buy rate for exchange ., the time the cancellation of the
Payment Order Is confirmed by Bank. Sank will not be liable for any failure or delay by any financial insthution or othe< third party in the designated foreign count!)'
in executing or faiRng to eX"",ute .ny Payment Order !lank transmits to a foreign country.
Refund. If the Beneficiary Bank does not pay the aeneficiary speCified on the Order, a refund will be made only after the Bank has received confirmation ofthe
effective cancellatlon of the Order and the Sank Is in free possession of the funds debited or e.rmarked in connection with the Order. If the order i. payable in Foreign
Currency, the Bank wUI not be li.blefor a sum In excess of the value of the Order .fter It ha, been converted from foreign Currency to U.S-Dolla" at the buying
rate for exchange at such orne as the cancell.tion of the Order is confirmed by the Bank.
F.llu.... to Transfer Proper Amount. If the Bank is notif...:! th.t it did not transfer the full amount stated In the Request. toe Bank's sole liability will b. to promptly
execute. second payment Order in the amount "fthe stated defidency. If the Bank executes an Instruction in exce.s of the amount stared in the Request.. to the ext.nt
that the orig!nator does not let.elve the benefit of the Order, the Sank will only be liable for any loss of the principal amount in exce55 of the amOU!ll stated In
the Request instructions. AdditiooaEy, the Bank w/U be liable for the amount of/nlVest the originator has lost due to the tran"'.r of the excess amount.computed at the
then current Federal Funds rate. However. the Bank's liability for 10>, of interest shel( be rlmitedto twenty (201 calendar dey" Interon. This section sets forth the
complete U.bifttyfor the order issued undetthis agnoemenL
Anality of orders. The o,der will be fin.land will not besubjec:t to stop payment or mall,except that the Bank may. ot Ihe origln.tor', request make .n effort to
offect: such <top payment or recall In such case, the Bankwi!llncur no Nability for It. failure or inability 10 do '0.
Fees, In addition to the outgoing wire transfer feo. additional fees may apply. Additional fees an indude, but are not limited to: an additional fee for bank initiated
tr.nSOtlions.amendment fees,statement fee.. fees .,sessed by beneficiary and intermediary banks, etc. On 'nternationol outgoing wires, If a SWIFT 81C.IRC, IBAN, or
ClABE number is not provided the (oreign baoks may retum thewire or '.5<:51. surchorge. Wells Fargo Sank Wire Transfer Fees are disclosed In your most recent Fee
on<! information Schedule aod related amendments.
Acts of G"d. The Bank is _used for delays or f.'ut" to execute theOrder to the extent th.lthe delay orfailur. results from" cause beyond the rearonable control af
thea.ok.
Wire Transfer Information
Gonlfallnrormatlon:You un NOT t.ave. bank o. the fino! benelldary,un!ess thewl.e Is. paymentto the bonk (i,,,-,mortgage,auto loan, etc.). We.rt! required to know who
the money IS90ing to, to enSlJl'e the fund..", not being used to support terrorist or drug activi1y. We need an account numherfo, the benelidary OR. completo physicoI
addr.", No PO e""es mOl' be used whon no .ccount number I, provided for the S."eflciary.
Inter'MtIonal Wiru: Wim going to foreign covntries require <Hfferent numbers depending on the receiving foreign country. wire transfer paym!nb for Europe
include tI'lC"SWlFT 9f.ok lde:"tifier Code {SWIFT BIC'i.lnttm'lational Rgl,.lting Code {tRq liS 3nd for participating COl,Jnlries the benefidary's International8.lnk
Accounl Number (IBAN). Mexian bonks require. ClASE number In .ddition to the SWIFT SIC
1. SWiFT Bank Identlf'oer Code (SWIFT 810. Th. 8 ... 11 ch''''mr SWIFT SIC Is uniqve seri.. 0; .Iph.> numeric ch''''cters that help to identify specific The
SWIFT BiCshould be obtained from tho bero<ficl.ry. To ensu timely delivery plea", be sure that iotern.tlonal outgoing wire' Indude the SWIFT SIC where opplicable.
2. international Routing Code (lRCI' Some countries throughout the international banking community hayo ""'>ted routing t:<>dei. which are USEd in combination
with thot SWIFT BIC to aid In routing the payment through. main office to. branch. Each country nas. specific name for thelrloutlng code (Le,Sort Code In the United King<lom,
Canadian Payments AloSod!tion Routing Numbers in Canada). Yoor benefiCiary mtJst provide the routing code to flldJitate receipt of an intti'f"latioNI paycnent.
Sending a wire wlthouttM IRC number can deiaythewire.,orthe receMn.g bllmkmayreturnthewire:when this number is notincluded in the paymentlnstnJcnons.aoo additional
fees may be Illliiened.
3. International Bank Aa:ount Number !lBANI: The IBAN varies by rountryl1n.1!itution, Warning! Only the bank Servicing an oount an praYlce the correct IBAN of tMt .ccount
and must beobtolned from the beneficiary of the wir.. s.ndlng. wire to participJJtlng countTy without the lEAN can delay the wit.. orth. "".ivlng Mnk mOl' retum th.wir.
when the i8AN is not Induded in the payment Instructions.and additional fees may be assessed.
Countries that require an IBAN:
I Andorra Guadeloupe Poland
I
Austria Portugal

Iceland Reunion Istand
I
Herzegovina _nd(Republicofj "Romania
Bulgaria
-
Isle atM.n San Marion

.
Italy Saudi Ar.bi
Cyprus Latvia Seri;)ia and Montene9!0
Caeh Republic liech""'steln Slovakia Repubiic
Denmark Lithuania Sloven..
Eslonl. luxembourg Spain
Moland I MacedOni. Sweden I
France Malta SWItt.rland

Polynesia
Mortinlque
Monaco
Tunisia
r\mcey
Germany Netherland. United 1G-"9'I.om
Gibraltar NeW Caledonf<l I
Greece Norway
4, Mexico etAS!: Account Number: Mexican banks now require in 18digit CLABE account be added to the Beneficiary iMtructions to ensure payment The (LASE
numb<! is required on .n "","",can Peso (MXN) .nd USD payments Sl!nt to Mexico. The ClABE lICCount number must be obliined from tile benefJdary. g the benefidary do",
n h ..... the (!ABE ac<OU'rt p"'.se have the beneficiary contact their bank. WeU. fargo does not provide Or calculate the (lABE. Sending a wire without a Cl.ABE
acrount number can delay the wire. or the receMng bank may return the wire If the ClABE Is not Induded In the Plyment Inwuctions. and fees may be .sse>sed.
S. Wells Fargo that if you do not have SWIFT BIC.IBAN,IRC.or Me_n ClABE number, that yau con1nd the benefidary of the wile. If the oo,eAciary does not
have the needed Informatiof\, prse have tile be ""lidary contact'lhelr bonk to obJain the .ppropri.te inl!:xmatlon. 5endlng International wires without the required
Inn,rmatlon Cln _the wile to be delayed,rerurned,orassessed .ddnional f....
for International outgoing wirvs only: When sending in cU'fTency. please ensure the ac:count accepts the designated foreIgn currency.
fOf>1lgn curenC)l wires IT" genemlly loss penslve to ,end IS compared with Intemational usn wire. (the Well, Forgo wire fee I, always les' when the win> is sent In for.ign
cUrTer'lCY and Wells Fargo does not charge a converting fee;we also offer competitive i!XChange ril'tes.) For Intl!'miltional wires in currency tlll!.re equal to or over
SlS,QO() US.oquiv>lent,pl."'" coli )'Our locil foreign >chango Specialist at 800-7865593, to obtain. CQntnlct number.
h"
VERIFICATION
STATE OF GEORGIA
COUNTY OF MUSCOGEE
Personally appeared before me, the undersigned, IKE A. NWAOBI, after first being duly
sworn, deposes and says that he is the Plaintiff in the foregoing captioned cause, and that the
facts contained herein are true and correct.

Sworn to and subscribed before me this

::) day of ,2011.
. 1\ rv
Notary Public
My Commission Expires: \ (11.0,
STATE OF GEORGIA
COLUMBUS BANK AND TRUST CIVIL ACTION FILE NO.
COMPANY, A DIVISION OF SYNOVUS SU-U-CV-3875
BANK,
Petitioner
vs.
LAW OFFICE OF MICHAEL A.
EDDINGS, P.C., FIRST AMERlCAN
TITLE INSURANCE COMPANY, FIRST
AMERlCAN TillE COMPANY, JOHN
DOE 1, JOHN DOE 2, JOHN DOE 3, et aI.,
Respondent
I do certifY that I have on this day served a copy of the above and foregoing document
upon the person named below by mailing a copy of the same through the United States Mail with
adequate postage attached thereto to insure proper delivery, addressed as follows:
William L. Tucker, Esquire
Page, Scrantom, Sprouse, Tucker & Ford, P.e.
1111 Bay Avenue, Third Floor, Synovus Centre
POBox 1199
Phone: 706-324-0251
Attorneys Jar Columbus Bank & Trust Company, a Division ofSynovus Bank
RESPECTFULLYSUBMITTED this 1111 day ofNovember, 2011.
MEACHAM, EARLEY & FOWLER, P.e.
PO Box 9031
Phone: 706-576-4064
Fax: 706-596-0621
ME&J/GAJLitigationiGen'l CivillNwaobi, Ike
Answer to Plaintiff's Petition for Inte!pleader
By: __..--->'"<::-__________
Christopher eacham, Esquire
GA Bar #0500050
Attorneys for Defendant, Ike A. Nwaobi
STATE OF GEORGIA
COLUMBUS BANK AND TRUST COMPANY,
*
A DIVISION OF SYNOVUS BANK,
*
Civil Action File No.:
SU-11-CV-3875
*
Petitioner,
*
*
Vs.
*
r-...:.
:r C;::;)
* VIC':::,..
.......
LAWOFFICE OF MICHAEL A. EDDINGS, P .C., *
c:c,,:-"
--00_ :;z:
FIRSTAMERICAN TITLE INSURANCE *
!;!c)- D
J ~ f 1
....;:
""""""")
0
COMPANY, FIRST AMERICAN TITLE * QI'::,lU I
...-. ..
;:J(]/"""j :to. co
..c..
COMPANY, JOHN DOE 1, JOHN DOE 2, *
0(');'
0
JOHN DOE 3, ET AL. * 0 0 ;:::'
v
--.,
*
-'1 c: c: ="J
:'i!
;r.rZO
w
t'J
-1-:"1
Respondents.
r;-,
*
-<
\.0
JEROME ROGERS' ANSWER, COUNTERCLAIM AND CROSS CLAIM TO
PETITIONER'S INTERPLEADER PETITION
COMES NOW, Jerome Rogers (identified as "John Doe" in the above styled action), and
makes this his claim to his money in the above-styled action by filing this Answer, Cross Claim,
and Counterclaim to Petitioner's Interpleader Petition and shows unto this Honorable Court as
follows:
FIRST DEFENSE
Jerome Rogers ("ROGERS") responds to the separately numbered paragraphs comprising
PETITIOl'..'ER'S Petition for Interpleader as follows:
L
ROGERS admits the allegations contained in Paragraph One (1) of PETITIONER's
interpleader action.
2.
ROGERS is without knowledge or information sufficient to form a belief as to the truth of
the allegations contained in Paragraph Two (2) of PETITIONER'S interpleader action.
3.
the allegations contained in Paragraph Three (3) of PETITIONER's interpleader action.
4.
the allegations contained in Paragraph Four (4) of PETITIONER'S interpleader action.
5.
the allegations contained in Paragraph Five (5) of PETITIONER'S interpleader action.
6.
the allegations contained in Paragraph Six (6) of PETITIONER'S interpleader action.
7.
ROGERS is without ~ o w l e d g e or information sufficient to form a belief as to the truth of
the allegations contained in Paragraph Seven (7) of PETITIONER's interpleader action.
8.
ROGERS admits the allegations contained ill Paragraph Eight (8) of PETITIONER's
interpleader action. By way of further answer thereto, ROGERS shows that he wired the sum of
$89,498.90 to the trust account of the Law Office of Michael A. Eddings, P.C., pursuant to the
wiring instructions received from the Law Offices of Michael A. Eddings, P .C. A copy of the
wiring instructions are attached hereto as Exhibit "1" and made a part hereof by reference. A
copy of the wire transfer is attached hereto as Exhibit "2" and made a part hereof by reference.
ROGERS wired said funds to said trust account of Michael A. EDDINGS, P.C. ("Eddings"), for
purposes of purchasing real estate, with a closing scheduled for 10:00 a.m., on Friday, October
28,2011. The scheduled closing did not occur due to the actions of either the Defendants and/or
the PETITIONER. ROGERS' funds are still in the trust account of EDDINGS, and comprise part of
the funds paid into the Registry of the Court.
9.
the allegations contained in Paragraph Nine (9) of PETITIONER'S interpleader action.
10.
the allegations contained in Paragraph Ten (10) of PETITIONER's interpleader action.
11.
ROGERS admits the allegations contained in Paragraph Eleven (11) contained in
PETITIONER's interpleader action.
12.
the allegations contained in Paragraph twelve (12) of PETITIONER's interpleader action.
However, by way of further answer, ROGERS shows that he is entitled to have his money in the
trust account of EDDINGS returned to him so that he can complete the purchase of the property
that had been scheduled to close at 10:00 a.m., on Friday, October 28
th
, 2011.
13.
ROGERS shows that Paragraph Thirteen (13) of PETITIONER's interpleader action
constitutes a legal conclusion requiring no answer, and therefore, ROGERS neither admits nor
denies the allegations contained therein.
14.
ROGERS denies the allegations in Paragraph Fourteen (14) OfPETlTIONER'S interpleader,
including the prayers for relief contained therein, having any application to him.
COUNTERCLAIM AGAINST COLUMBUS BANK AND TRUST COMPANY,
A DIVISION OF SYNOVUS BANK, PETITIONER
For his counterclaim against PETITIONER, Cohunbus Bank and Trust Company, a division
of Synovus Bank, ROGERS shows to the Court the following:
1.
Columbus Bank: and Trust Company, a division of Synovus Bank ("CB&T") is subject to
the jurisdiction of this Court and this counterclaim is properly pleaded in this interpleader action.
2.
ROGERS shows that by virtue of his wire transfer of the sum of $89,498.90 to the trust
account of the EDDINGS, it now constitutes a portion of the funds paid into the Registry of the
Court by PETITIONER. Exhibit "2" attached hereto gave PETIT10NER information and knowledge
as to ROGERS' fimds being transferred into the trust account of Defendant, EDDINGS.
3.
ROGERS further shows that his money wired into EDDINGS trust account has not been
returned to him nor has it been paid to anyone else for ROGERS benefit. Thus, ROGERS'
$89,498.90 remained in EDDINGS trust account at the time PETITIONER paid said trust account
into the Registry ofthe Court.
4.
ROGERS' closing was scheduled for 10:00 am., on Friday, October 28, 2011, when his
real estate agent was informed by telephone call shortly before the scheduled closing that it
would not occur.
5.
The closing of ROGERS' purchase of the property he had agreed to purchase did not take
place.
6.
ROGERS' purchase of the property scheduled to close on October 28, 2011, was a short
sale, which has to be closed in sufficient time so that certified funds can be received by Chase
Bank on or before December 6
th
, 2011.
7.
A copy of the purchase and sale agreement is attached hereto as Exhibit "3" and is made
a part hereof by reference. The closing date of October 28, 2011, is shown on the document
entitled "Amendment to Change Closing/Possession Date Amendment Number One" dated
September 30, 2011. Likewise, a copy of the letter from Chase Bank approving the short sale
comprises part of the contract and the approval letter from Chase Bank as to approval of the
short sale shows the requirement of certified funds being received on or before December 6
th
,
2011.
8.
Rogers made a good faith wire transfer of his $89,498.90 into EDDINGS trust account for
the specific purpose of buying real estate. The specific purpose has now been thwarted, due to
the actions of PETITIONER.
9.
ROGERS is entitled to a prompt return of his $89,498.90 inasmuch as there is no
uncertainty or doubt as to his funds comprising part of the EDDINGS trust account paid into the
Registry of the Court.
10.
If ROGERS does not receive his funds back from the account now in the Registry of the
Court, he will be unable to timely close the purchase of said real estate he agreed to buy and will
thereby suffer damages. Due to the present circumstances, Rogers cannot determine the amount
of damages at this time, but will supply the same by amendment at the time such damages are
known.
11.
Wherefore, ROGERS prays that this Court enter an order directing that he be paid the sum
of $89,498.90 so that he can proceed with the timely closing of the purchase of the property
which should have been closed October 28, 2011, and in the alternative, for a judgment against
PETITIONER for not less than $89,498.90 together with any additional damages ROGERS may have
sustained due to PETlTIONER'S actions.
CROSS CLAIM AGAINST LAW OFFICE OF MICHAEL A. EDDINGS, P.e. ("EDDINGS"),
ONE OF THE NAMED DEFENDANTS
For his Cross Claim against Defendant, Law Office of Michael A. Eddings, P.C.
("EDDINGS"), ROGERS shows to the Court the following:
1.
Defendant EDDINGS is subject to the jurisdiction of this Court and this Cross Claim is
properly pleaded in this interpleader action and response thereto.
2.
ROGERS shows that he made a wire transfer in the amount of $89,498.90 to the trust
account of EDDINGS which monies now constitute a portion of the funds paid into the Registry of
the Court by the PETITIONER. Exhibit "2" attached hereto is a copy of such wire transfer
3.
ROGERS made the wire transfer into the trust account of Defendant EDDINGS as per
instructions received from Defendant EDDINGS office. Exhibit "1" attached hereto is a copy of
such wiring instructions.
4.
ROGERS wired the money into Defendant EDDINGS trust account for the purchase price of
the property he had agreed to buy. EDDrNGS was to use the wired amount on his behalf to pay
the purchase price to the Seller of the property ROGERS had contracted to purchase.
5.
ROGERS made a good faith wire transfer to EDDINGS trust account. At the time of doing
so, ROGERS had no information, notice, or knowledge of the impaired condition of EDDINGS trust
account and the likelihood of him not being able to access his own monies.
6.
ROGERS' closing was scheduled for 10:00 a.m., on Friday, October 28, 2011, when his
real estate agent informed him that such scheduled closing would not occur at the previously
scheduled time.
7.
Defendant EDDINGS closing of ROGERS' purchase of the property he had agreed to buy
did not take place on October 28
th
, 2011, and has not yet taken place because of ROGERS' funds
being in the Registry of the Court.
8.
ROGERS is unable at this time to access his $89,498.90, which was in EDDINGS trust
account at the time PETITIONER paid it into the Registry ofthe Court.
9.
ROGERS' purchase of the property is a short sale which has to be closed in sufficient time
so that certified funds can be received by Chase Bank on or before December 6, 2011.
10.
A copy of the purchase and sale agreement is attached hereto as Exhibit "3" and made a
part hereof by reference. The scheduled closing date of October 28, 2011, is shovvn on the
document entitled "Amendment to Change Closing/Possession Date Amendment Number One"
dated September 30, 2011, which is part of Exhibit "3". Likewise, a copy of the letter from
Chase Bank approving the short sale and imposing the requirement of certified funds being
received on or before December 6, 2011, is part of Exhibit "3",
11.
If ROGERS does not receive his funds from Defendant EDDINGS trust account now in the
Registry of the Court, he will be unable to timely close the purchase of the real estate he agreed
to buy, and will thereby suffer damages in an amount that cannot be determined at this time.
12.
ROGERS is entitled to a prompt return of his $89,498.90 inasmuch as there is no
uncertainty or doubt as to his funds comprising part of the trust account of Defendant EDDINGS
now paid into the Registry of the Court.
13.
EDDINGS either knew or should have known that his trust account was not maintained in
the manner required by the State Bar of Georgia. Further, EDDINGS either knew or should have
known that his negligence in misusing/mishandling his trust account funds would endanger any
additional funds wired into it by his clients, such as ROGERS. Lastly, EDDINGS either knew or
should have known that there was a substantial, imminent risk of his trust account being seized,
paid into the Registry of the Court, or his office being closed.
14.
EDDINGS failed to use reasonable care in safeguarding ROGERS' funds wired into his trust
account thereby causing substantial damage to ROGERS. EDDINGS received such money from
ROGERS in his trust account and neglected and failed to use it for its intended purpose.
15.
EDDINGS further failed or neglected to advise ROGERS that EDDINGS trust account was
impaired to the point that ROGERS' monies he wired into it may be lost or not accessible to
ROGERS for an extended period of time, if at all.
16.
EDDINGS actions or inactions violated his fiduciary obligations to ROGERS, as his client.
17.
ROGERS reserves the right to file an amendment or amendments setting forth the
additional grounds for ROGERS'S recovery of his funds and damages, when any additional facts
are developed by virtue of further pleadings filed in this action, by independent investigation, or
by legal discovery means.
18.
Wherefore, having fully shown that he is entitled to promptly have his $89,498.90
returned to him, ROGERS prays that this Court enter a Judgment against EDDINGS for not less than
the sum of $89,498.90, together with any additional damages ROGERS may have suffered due to
the actions or inactions of EDDINGS. ROGERS further prays that this Court enter an Order
directing the payment of $89,498.90 to him without any deductions for costs, attorney's fees, or
otherwise.
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This _0_ day of November, 2011.
Denney, Pease, Allison & Kirk
Post Office Box 2648
Columbus, Georgia 31902-2648
(706) 324-3711
VERIFICATION
MUSCOGEE COUNTY, GEORGIA.
Personally appeared before the undersigned officer, duly authorized by law to administer
oaths in and for said State and County, Jerome Rogers, who after first being duly sworn,
deposes and says, on oath, that the information contained in his Answer, Cross Claim and
Counterclaim to Petitioner's Interpleader Petition is true and correct to the best of his
information, knowledge and belief.
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Exhibit "1"
'lHB LAw OFFICES OF
MICHAEL A. EDDINGS, p.e.
706.653.7227 0/706.653.7832 F
.www..eddiogspc.com. '
:Miebld A. fiddin&s Mkbacl E.Joyner. OfCOunseI .
- Admiaed14.AI.. GA. &:oc Admitted in G,A ,
ruejO}!ne:@e&dlagspc.CO!U
WIRlNG INSTRUCTIONS
Wiring Instructions to: CB&T for The Law Office ofMicl1ael A. Edc:l.ingB, P.c.
Routing Number: ' 061100606 .
Bailk Name: . ColmnbtlS Bank a.WI Trust Company
Accol;Dlt Name: The Law Office ofMicltaelA. Eddings, P.e.
Aeeount
Aeeount Num.bet:
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S60 Ceat.iI: Pukway. Suite B " 345' Peaclttree :Boad. NB, 5"th Floor
-'.. ..6.tIa.o.<lt, Georgia 30326 . Coh""bus, G:orgi131904
Exhibit "2"
Beneficiary Transfer Page 1 of!
Beneficiary Transfer
Reference Number 20.111027-00003476 is Pending Approval.
Branch 2107505 SIMONS PlAZA BRANCH
Paymeot Amount 89,498.90 USD Rate Contract Number
Debit Amount 89,498.90 USD Charge Party None
Send Date 270CT2011 Value Date 27OCT2011
Debit Party
0/1000137874110
JEROME ROGERS POD
305 E PLATT ST
LONG BEACH CA 90805-6421
Beneficiary
Is Benefidary a Bank? No
$ 766
THE LAW OFFIce OF MICHAEL A EDDINGS
860 BROOKSTONE CENTRE PARKWAY STE B
COLUMBUS, GA 31904
BeneficiarY's Bank.
N061100606
SYNOWSBANK
.,. ..... COLUMBUS, GA
Bank to Bank Originator to Beneficiary
Information Information
http://frontofficewire.sunfrust.com/fwilentConfirmation.do lOfl7f2011
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Exhibit "3"
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PURCHASE AND SALE AGREEMENT

2011 Printing
1. PUr#!!!!! and Sale. Tha undens9ited buyer ("Buya().agrees to buy and the undemigned sa/klr ("Sellof') agrees to S&IJ ffla
Property with I!lII kllloWing . 3868 Nil RJdgt Yl!$!
CIIy EJlMlW9 . County Cfayton . Georgia. ZIp Code 30291 '
TAXlOJPIN, tDgelherwllh aJl1ixtLlrGs, landscaping. Improvements, and eppt..Q'tQnan<;ea (excapt
ihoee ldenUfied In any &lJe('a Prcper1 Disclosure StaIement attacIlOd IwetO as not remalnln!j1 with the Property) and as more
pal1lcularly described In the L&gaI DeseriptIon PalWdraph below (all ofwIllcfl [s herefn.r referred to as Prcpertf).
3. PW"Cha" PriT! and M!1h()d of Payment. At cfoaing, Buyer agrees to pay Seller lie pt.HClurss price of the PI'QI)8rty of
$. . ,8.oo0..0p . .' NJD!!!(l1toutIInd U,S,
ca$h, wile tlansfer of immedlateJy available furds, or .. c:ash1G1'$ cIl9Ck II$t.Ied fur 1he dosing by III filderally InIIUI\')(f bani:, savings
bank, savingls and ioan association or credit union wheIa tb6Ifuncls arV- fmInecIIafDly IivaIIIbIa. The abow'fo!ms of shall be
deemed tD ba the equlvakint of BuyerpayinQ l1li c&!m at dOeing which shall be- U'IG method of payment.
4. Amount and of Eatne!1 yonw. Buyer haS paid, h) CoIda" BJobr Kennon. Ptutw" j)w"tqQ & Key ("Holde!")
eamnt money of $. 2.QOfl,oo chGdc. OR IS Or!! cash, wtlicl1 ha$ been mQllved by Holder. 'F'ha 8amItSt
ITIOIlGyshaU be depo$ftec;f In HoIder"sescrcwlln.lst,account(WlIb HoIdarrs!s1n1n9 the accoootl$
ftw (S) banlClng days fi'om 1I1e BlOOlng AQJeement Data. If Buyer WIilBs a c::bedc for earnest l'I1Oney and the $Bme Ie daposifed /No
. HoklOr'" Hokfa-r lhaK not be !8(fuimd to Mum the earnest money U!lIiI the cheCk bas deatlilCUh& &c:<:OUnt on
which !fie check was wrItfun. In the ownt any'eJmm'money dl9Ck Is dishonored by the' bank upon It wdmwn. He,1de/' shill
Pl'OOIptIy gMilnolica of the same to Buyer and Seller. Buyer Ihalf hI:IW Itueo (3) bar'IIdrQ days af!er reoeMng lIU:h nolfoo to deliVer
good foods to HoIdur. In too event Bu)'er UOes not timety tIeBver good fund&, Sellar shaD have the ri9ht to tsnniI* thls AgraemE1nt
upon notIc:e to
S. goslnq CQI!! mel Ofh!r StttJamont Expanj""
A. (tsmB.paJd By Bay&, at CIotIn{I. At closing, Buyer8ha1 pay !he
1. Georgia ptaper(y fa;(;
2.- All CD!It8. fee5 and charges \I) haw tI'I8 cfosIng attom&y search tIUe and prepare; (8) tha WM1II1f deGd: (I) affid'1llIIt;
(c) Buyer's powert ofdom&y, and (d) eI promlsiory notes. deed!; to -.:tIllI debt and othor roan. documents mqulmd by any
lender proviIflllllllrnu)dng In the flaJ'I8action: '
3. AU dOaU1g co:sts. tax -mce 1;baIga$. taCOrdill9 costa, courier ." OVBmight daIvery fees. doa.ImOnt preparation fees,
undf5!W!f1in9 c:IeliVBry. copying and handKng charge, ancf aB other cost$, fees, charges and amounts to dose Ihls
transaction otherwfse. 8XC8pt as they RIlaie to the clearance oftilla encumbrances tntJIor dereds kif, Sei!erto be
aDJ. ro ooriwy good and maablbls 00e to1ha Propalty.
s. hams fWd By sellor at cro.1ng. JU cb5Ing, SalIarllhal pay !he1cIIowl/V!
. 1. The.um of $. . O.!JO to be UHd by Strfet as '. oontribution.for 111" ibmls in fl19 palil,llraph aboYe. In
addlfion. Buyer may usa the SeIlets conbibU1Ion \I) pay for, /nciudlng but not II.tnJtsd to, I!tIIVBy costs, app!tIisaIs. Insurance
(including -flood II' applicable). Jnapealons. Iemlil& 1raafment and/or repair guaran1e& and. If lkIyer is obtaInIllIi
Iina1Idng, escrow loan dlsoount points, costs to buy down a Joan, and cdher almllar CO$lS
{unlesunyof1h&same are pro,h/bif&dbyBuyetsmCl19age lanciel? Unspmt sums,hny, shall r&maIn wifhtbe Saller.
2. Excapt as providecl aboVe. alaums. oosIs. charges and fae$ to eleill' title enoumbran<:e$ and/or d$fec{s to aUow'
sallerto be able to OOIJ\I9y gooc:fand maikefable tItIG to the Ptopedv. .
3. Anyectm cosIB, fees and charges rEl$UIfjng tom Seller not being able to attend lh& closing In penon .
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F. nme of Euonce: TI[Jl$ 1$ ofth8 eslIllOO8 ofUliaAgreement, . ,
G. Tvnnlnologv:' As ttw confBxf: may 16qu!mln this AgrGeMlint (1) b singUlar wn moan the plural and Yrce versa; end (2) aD
pronouns shall mean and ixlude !be person, enlfty. fiml. or corporation to wf\ich Uiey i'$1ata.. .
H. Blndlng A;JHmem DslO: The A(InHIment Date In iflIs shall be the dafIt wheo the pasty maldng thQ 1asI
offer, or the Broker (except In a designsled agency1ransactlon)or amIiated of Broker rapresentfng ItIatparty all a client.
/UceIws I'lOt!oa that tbEt oll'ar has been ar:cepted. This party (or Uie Broker or afliJiatlid /le$nsee repnlS$nUng UlI!J party a$ a
ClientJ .baII fiR in file B/nc1lng Agreement Date'beIow and J)I'Ol'nptIy give notice of ltlls date 10 the .ofher party. FJirQ In the BindIng
Agl6ament Dale shall not be'deeniBd to b$ a oounterolfer, ' .
1. RMponslblllty to Cooparatr. All pazties to taka all actions and dD aU thklg$ f9aS1)naIiIy to fUlli1ll1le1erms and
CXX1dltiot1$ of !his In good faith and in a timely manner.l3uyerand Seller shill and delIversuch certilications.
allldavb, and IRaIIIIlIGuts as are 19qulred dany tender($) and offederatand IIfatelaw.
J. GAR Fonna; The Geoc9Ia.Association of REALTORS" Inc. ("GAR") makas oerfaln standard mal estafs famII ava1labl& to its
1'I'II'InlbGnI. These GAR loons ant frequenUy to th& parties In MI estafB,tnilnsadions by the RE'ALTORS with whom
they are WOI'king. NO party Is raqrJred to US$ any eAR fOnn. Since ,the:M iOn'n8 are generic and wr!Ifan Interests of
mUltIple parf/es In mind. they I'IiS<I fr> be modified to meet fie apedfic MElds ofille partl8$ using them. Ifany party has any
questions about his or her rights and obIigaD0r6 under any GAR fbnn hII or She $holIId consUt an a1IOmey. The p&lties hereto
agree that tfle. GAR foons may oNy be used in acconfance wItl'Ilhe IlcensfIl9 agnl&fl1!mt of GAR. WhIte GAR rorm$ may b$
modi1ied by tm parlfes.,' no GAR form may be ceprodU(:ed with &eQlklns remOlled. altered or modlfied unless 100 changes are
vlslbJe onlbe tom! belfor In a stipuIaIfon, addendum,. exhibit oramendment fher8to.
f9.lbIcelpt By Br.Iyerof COl1SUrMr ProtacfIon 1m OR0 has not rocelved a ctIPY of !he
GAR brochure entitled "Protect Yourself \lllhGn BuyIng a Home" (Form F13),
20. gxbibltl ,ad Adfpnda. All exhI>Its and/or addwtda attached hereto. Iisfad below, 01' rufwrenced hemin are made a part of this
Agmement If Mrf exhibit. or addendum conflicts wllh any preteding par.asraph {/ncIudi1ll any cbanges thel'8b made by tt\e
parUas). Slid exhibit 01' addendt.rn shall oonltol:
o !.agaI Oesc::ription ofthEt Property ti$ ElchIblt ___
o FJRandng Conffngency 8$ Exhibit " ___
o The OFHAL.oanExhlbll OR OVALoanExlllblt OR DConlfBlltlonalFrnancirIG Exhlbltas Exflibit___
o ASuvey of Propertyas ExfilbIt c___
o as E:xfIH ___
o SeWs Property Dbc:Io!ItJr& statBment at ExhIbit ___
l8I J...ead..Based Paint,Exhibit as ExhIbit" It.
o Soun::e of Buyer's Funds as exhibit __.......:..
o Sale or Lease of Buyel's 9$ Extiibit___
o exhibit "___
o community Assotfalfon DiSclosure as Exhibit " ___
_____________ ________________________
o 0Ib&r _______ _____________
OOCh&r_______________ ______

___________________
SPECW. STIPUlATIONS The Spadal Stipulalions. if conliidingwith any e:xflI)Jt. addendum, 'or parag.raph
(lncfudlng any thenIIn made by fIB palilss}, .haI corttJm: '
1. Offvr 1& COIItingent on Buyw CIOIifng on cummt maJdollC8 onSeJ'ltember 28, 281t.
2. a._to enaura all Ale unit .... wol1dnp
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., Qual-1t:V'- Inn Waycross GA.
" : 09/,23/201114: 54 FAX"
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exHIBIT HA- . If
2011 PrtnffltJ
ThIs saw. Dltdollln Statam4tlt II .,. IN\fIN fD u.. amf $IIi Aa/lMlmOllt wlth *'" O&r DIIie of
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. A. INSTI(UCTIOHS T08m.uR IN COMPLl!11NG l1li,
aaraeato:. .
m1MWit"quNtlont In rafet'tnoe to !he PI'O!*tt tVtitloh. unJi:III atheMflla atIaII lmprowmenla thenson);.
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fa) 11/ UIy Ind bIIAd upcn #It b." and bcIW till SeilII'f1n 1M Pun::hMt w ...
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. Clfhqueatlon forMlidl 1M addIIIoIW .. bIIIrI IItId
(f) prTJI!IptIrlll'riM 1he and fIVI EliMrlrwolved ItJXIoriQ
dOWliJ lfI8fIart I"mefatiaII d*IQfi In the IJIIWIInttl ant CIt the QUUIfOtIs.
a. HDWlH/881'ATENENl' 8lf01JU) a utiaD fJ'IDUY!R.TheIII'II!I'oIIIIVQt6tlltrt.vtlo*a/'bWIfIOCbIa wb$IIMa I:Ir
a /ndapIhd1Mlt CWiIIiMIIan d ..PropMr. CIWIIt .....cr bw- "tho IIW In 0accgIe. .B4I)W hi 10 UIf
cera 10 fdentIf1 ctWadIln N P.IOI*1Y -1itIItf; II8lMIf ex' lilt !hi Ie 4UftabIIf for auy.n .,..and
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buyer tiWallgale t\.1ttNr. 6u)IIIr may not haVe Boyet tdr JI) /ItYoItIJIaII AItttm. .
C. DIICLOIURII..
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... AMENDMENT TO CHANGE CLOSING/POSSESSION DATE

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AMENDMENT .,. 1
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2011 PrltdIng
WhI!mae. thll underS/gi1ed pattI8I have Mt8red Into, Wlth a BInding A9n:ten'1e11t o8te ",_______
____=-__fOr the tall! of reel ptCperty toca1ed at: 389 TwIn Rf.Qa. Wn.
, Georgi!! 302H. j and .
the undersigned pariiM desIte to ametId tno 91bre1Mntloned It being 10 tNt mutuaf bendt t>f aD pattiM Ig do 80:
NoWtIWaI'or8. for end Itt corItlderaUon of the tum ofTet'f "otIs... (S1D) end oUtwvsbtbla palcf by eech to tn& oIh6lj thO
tlICc!ipt and atfIRcIency d whfch are 1'ter8!l1 tho pertIe$ hereto Il{IFee to.modIfy end amend the
Agraement ... tolowa:
DIN: The 0I04ln" dQte In the ".httvby al'n4!ll'ldtld as follciw&:
ThIA tlWlBlSctkm ,haIl'be dosed on1he cIat& " 10:U:::11 or on tudt otfw as may be
to by thtt PQI1Iea In wri'tfng.
fxt!B!IoQ: n.rlghtlO unlatsmllytld&tldfaedosklQ_fi;lr't (a9ven)@)'lJ" rot'ln the Date r:i C/oeIng and Tmnefer of
oftbt OR Oshal remaln In Ml fOI'()6 anQ
efi'8ct.
By: I.
Broker Of BroltetaA1II1iated lJo9naeG
Mamberot: ___Co __o1 REALl"ORS. Member of: Of'REAlTORSe
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Chase
PO BOX 469030
CHASE 0
Glendale, CO 80246-9030
October-20,2011
Daryl Jackson
3868 Twin Ridge Lane
Ellenwood., GA 30294
Approval ofshort sale
Account: 0019297100
Property Addre.c;s: 3868 Twin Ridge Lane .
Ellenwood, GA 30294-0000
Dear Daryl Jackson:
We have reviewed your recent request for a short sale on the account above. We have accepted the offer
under the Home Affordable Foreclosure Alternatives (HAFA) Program.
We agree to accept all net proceed:;; from the settlement, but not less than a minimum of $79,738.38. as full
and final satisfaction of your loan. After we receive the settlement amount, we will settle your account and
release the lien on the property.
We must receive payment in certified fonds on or before 12/002011. or this offer becomes nuD and
void.
This approval is subject to the following:
A. Terms-The sa1e and closing comply with all teIlIlS and conditions of the Short Sale
Agreement (the "Agreement").
B. Changes--Ariy change to the teons and representations In the Agreement must be approved
by us in writing. We are under no obligation to approye s ~ h changes.
C. Subordinate LieDS--Prior to releasing any funds to holders of subordinate liens/mortgages,
the closing agent must obtain a written commitment from the subordinate lien holders that
they will release the borrower from all claims and liability relating to the subordinate liens
in exchange for receiving the agreed upon payoff amount.
Before the transaction can close. all subordinate lien holders must provide a written
commitment that:
.. They will release their liens and the borrower from personal liability in exchange
for a combined payment equivalent of $6,000 to all subordinate lien holders.
Payment for release of any subordinate liens is dependent upon the agreement of
al1 subordinate lien holders to release their liens and the borrower from persona!
liability.
D. Proceeds from Sale-Except as previously agreed to in writing by Chase, andlor as set forth
herein. the seller will not receive any proceeds from the sale of the property. The parties
aclmowledge that the seller- will receive an incentive payment of$3.000, provided for in the
HAFA program. Please note that Chase requires a copy of the $3,000 relocation
incentive check or wire transfer. This should befaxed to (866) 220-4130.
Any incentive payments will be paid at closing and will be reflected on the HUD-I
Settlement Statement. .
E. HUD-I-A Preliminary Settlement Statement must be provided to us at least
48 hours before the closing date. We must also receive the signed Final HUD1 Settlement
Statement within 24 hours after closing. Please use the fax number listed below.
Fax: (866) 220-4130
F. Real Estate ColllIJlissiollS-Real estate commissions that are paid from sale proceeds to the
listing and selling brokers involved in the transaction cannot exceed 6% of the contract
sales price. Neither the buyer nor the seller may receive a commission.
G. Bankruptcy--Ifyou are currently in bankruptcy or you ttle bankruptcy prior to closing. you
must obtain any required consent or approval from the Bankruptcy Court.
H. Tax Consequences-We report forgiveness of debt to the IntemaI Revenue Service.
Proceeding with this transaction may have implications on your state or federal tax liability;
please consult a tax advisor for additional information.
I. Conswner Reporting-Please note that our acceptance of this short sale is reported to
various consumer reporting agencies and may have an adverse effect on your credit rating.
The impact of a short sale depends on the homeowner's entire credit profile. To learn more
about the potential impact of a short sale on your credit. visit the Federal Trade Commission
website at www.ftc.govlbcpJedu/pubsiconsumer/credit/cre24.shtm.
J. Payment InstructiollS-We must receive payoft' funds within 24 hours after closing.
Please use the following wiring instructions or overnight mailing address, and include your
account number on your payment. .
In order to ensure timely acceptance of payments, please do not submit payments at a bank
branch.
Wire: JPMorgan Chase Bank, N.A.
ABA # 021000021
Account # 765912993
Account Name: Chase Default Payoff Account Client #156
Customer Loan Number: ******7100
Overnight Mail: Chase
Attention Short Sale Department
Mail Code OR4-7133
3415 Vision Drive
Columbus, OR 43219-6009
K. Closing InstructiDns-At closing, forward the signed Affidavit DC Ann's Length
Transaction (enclosed) to the following address or fax:
OvernightIRegulat Mail: Chase Fulfillment Center
710 South Ash Street, Suite 200
Glendale, CO 80246-19&9
Fax: (866) 220-4130
P1ease can us at the telephone nnmber below on the day of closing to provide us with
the details regarding the delivery of funds. After we the certified funds. we will
'" .
the !ien:Anyexcess funds, at closing must be refunded to US.','
This acceptance is only for the contract sale price of $90,000.00 between Jerome Rogers (tbe "Buyer"), and
the Seller.
If your current mailing address or phone number has changed, please fill out the attached fonn, sign it and
fax: it back to us at the number provided. Ifyou have questions. please call us at the telephone number listed
below. We appreciate your prompt attention to our request.
Sincerely

Terry L. Roberts Jr.
Chase
888-332-7856-x5178 Ext. 214-626-4341
(866) 220-4130 Fax
(800) 582-0542 IDD I Text Telephone
www.cbase.com
Enclosures
- Borrower Contact Infoonation Update FOffil
- Affidavit of Arm's Length Transaction
We are a debt collector.
If you are represented by an attorney, please refer this letter to your attorney and provide us with the
attorney's name, address, and telephone number.
To the extent your original obligation was discharged, or is subject to an automatic stay of
bankruptcy under Title 11 of the United States Code, this notice is for eompliance and/or
informational pnrposes only and does not constitute an attempt to collect a debt or to impose
personal liability for such obligation.
OP411
BORROWER CONTACTINFORMAnON UPDA1E FORM
Account: 0019297100
Borrower(5): Daryl Jackson
Property Address: 3868 Twin Ridge Lane
Ellenwood, GA 30294-0000
Name of Borrower(s) Requesting Update
Borrower's New Address
Borrower's New Home Phone Number
Borrower's New Work/Alternate Phone Number
BY SIGNING BELOW.
The borrower(s) agrees to inf(;mn IPMorgan Chase Bank, N.A. of any changes in the borrower's current
mailing address imd phone number.
Borrower 1 Date
Signature
Borrower 2 Date
Signature
As a reminder, please return this completed form by fax to (866) 2204130.
OP4J1
AFFIDAVIT OF "ARM'S LENGTH TRANSACTION''':
Pursuant to a residential purchase agreement (the "Agreement"), the parties identified below as the "Seller"
and the "Buyer." respectively. are involved in a real estate transaction whereby the real property commonly
known as 3868 TWlN RIDGE LN. ELLENWOOD. GA, 30294-0000 (the "Property") will be sold by the
Seller to the Buyer.
JPMorgan Chase Bank. N.A. (the "Lender") holds a deed of trust or mortgage against the Property. In order
to complete the sale of the Property. the Seller and the Buyer have jointly asked the Lender to discount the
total amount owed On the Loan secured by the deed of trust or mortgage. The Lender, in consideration of
the representations made below by the Seller, the Buyer, and their respective agents. agrees to accept the
amount to resolve its Loan (pursuant to a separate Agreement between the Lender and the
SeUer) on the express condition that the Seller, the Buyer. and their respective agents (including, without
limitation, real estate agents, escrow agents, and title agents) each truthfully represents, affirms, and states .
as follows:
1. The purchase and sale transaction reflected in the Agreement is an "Arm's Length Transaction,"
meaning that the transaction has been negotiated by independent, unrelated parties, each of whom is
acting in his or her own self-interest. and that the sale price is based on fair market value of the
Property. With respect to those persons signing this Affidavit as an agent for either the Selier, the
Buyer. or both, those agents are acting in the best interests of their respective principal(s).
2. No Buyer or agent of the Buyer is a family member or business associate of the Seller or the
Lender.
3. No Buyer or agent of the Buyer shares a business interest with the SeJIer or the Lender.
4. There are no hidden terms or hidden agreements or special understandings between the Seller and
the Buyer or among their respective agents that are not reflected in the Agreement or the escrow
instructions associated with this transaction.
5. There is no agreement, whether oral, written, or implied, between the Seller and the Buyer and/or
their respective agents that would allow the Seller to remain in the Property as tenant or to regain
ownership of the Property at any time after the consummation of this sale transaction.
6. Except as previously agreed to in writing by the Lender. andlor as set forth herein, the Seller will
not receive any proceeds from the sale of the Property. The parties acknowledge that the Seller will
receive an incentive payment of $3,000, provided for in the HAFA program. Please note that the
Lender requires a copy of the $3,000 relocation incentive check or \rire transfer. This should
be faxed to (866) 2204130.
Any incentive payments wilJ be paid at closing and win be reflected on the HUD-l Settlement
Statement.
7. No agent ofeither the Seller or the Buyer shall receive any proceeds from this transaction except as
is reflected in the final estimated closing statement, which shall be provided to the Lender for
approval prior to the close of escrow.
8..The Buyer acknowledges that he/she is not an employee ofJPMorgan Chase Bank, N.A. and its
affiliates, including those associates on assignment through a provider of temporary employment
and any re!atives of such employees or associates (collectively. an "Employee").
9. Each signatory to this Affidavit expressly acknowledges that the Lender is relying upon,the
representations made herein as consideration for discounting the payoff on the Loan, which is
secured by a deed oftrust or mortgage encumbering the Property.
lQ.Each signatory to this Affidavit agrees to indemnify the Lender and any investor on the Loan for
any and all losses resulting from any negligent or intentional misrepresentation made in this
Affidavit including, but not limited to. repayment ofthe amount of the discounted payoff on the
Loan.
I L Each signatory to this Affidavit expressly acknowledges that any misrepresentation made by him or
her may subject him or her to civil liability.
,12. This Affidavit will survive the consummation of the sale f:!anSaction.
JJWe declare under penalty of perjury under the laws of the State of Georgia that all statements made in this
Affidavit are true andcorrect.
AdditionaUy. I/we fully understand that it is a federal crime punishable by fine or imprisonment, or both, to
knowingly and willfully make any false statements concerning any of the above facts as applicable under
the provisions of Title 18, United States Code, Section 1001, et seq.
Buyer!
(Print Name)
(Signature)
(Date)
Boyer 3
(Print Name)
(Signature)
(Date)
Seller 1
(print Name)
(Signature)
(Date)
Sel1er3
(Print Name)
(Signature)
Buyer 2
(Print Name)
(Signature)
(Date)
Boyer 4
(Print Name)
(Signature)
(Date)
Seller 2
(Print Name)
(Signature)
(Date)
Se1ler4,
(Print Name)
(Signature)
(Date) (Date)
Buyer's Agent Seller's Agent
- ~ .....-------------
(print Name) (print Name)
(Print Company) (Print Company)
(Signature and Date) (Signature and Date)
As a reminder. the signed Affidavit of Arm's Length Transaction must be sent at closing tD the address or
fax number provided below.
OvemightIRegular Mai}; Chase Fulfillment Center
710 South Ash Street. Suite 200
Glendale, CO 80246-1989
Fax; (866) 220-4130
OP411
'... ".' lv.l5'oN IIOl 'Sl'PO
It.This willl'urvive the consumm:ati0A ofdie saie
;
, IIWv ......-.1... , Of ......n!Jry under tho laws of th' State of uU madll in this
. J"--,J
Affida-yit artt,."'Ue Ilnd .
Addldonally,lIwc futt)' Cmierstand,that It ts p (),fhne'ptmillAable by fine or' impri:iQllment. or both. to
<-.
. Ialowil'lgly and witlfuUy make My false sta:tomonta .an)' of the above facts' as applicable u{lder
'"'t....
'"
provisions of title 18. United States Code., Se:stinn 1001. 5bq. .
"t. I
1 P_,..'
0f:) E'r: 5'

(S
)
to- 5-= d.'i'.{ (
(Prlnt Name)
" '
Buyer 2
_,_,_'''________
(PtmtName)

(Da.te)
BUJ4
(PritltName)
(PrJnt Name)
I ,
'I I
'\

SeIIert
., . . ij" :
(Print .
!
(SignlllUR)
'

Seller 3
(Print Name)

I do hereby certify that I have served a copy of the foregoing Answer, Counterclaim and
Cross Claim to Petitioner's Interpleader Petition upon the below listed interested party(ies) by
depositing the same in the United States mail properly addressed and with sufficient postage
thereon to insure delivery to the following:
Columbus Bank & Trust Company
clo Page, Scrantom, Sprouse,
Tucker & Ford. P .C.
William L. Tucker
P.o. Box 1199
Columbus, GA 31902
clo Michael A. Eddings, as Registered Agent
860 Brookstone Centre Parway, Suite B
Colunlbus, GA 31904
FirstAmerican Title Insurance Company
clo C. Scott Logan, as Registered Agent
5607 Glenridge Drive, N.E., Suite A200
Atlanta, GA 30342
First American Title Company
clo Corporation Service Company, as Registered Agent
40 Technology Parkway South, Suite 300
Norcross, GA 30092
~ ~
This ~ day ofNovember, 2011.
erome Rogers
STATE OF GEORGIA
COMPANY, A DIVISION OF SYNOVUS SU-ll-CV-3875
BANK,
Petitioner
vs.
EDDINGS, P.c., FIRST AMERICAN
AMERICAN TITLE COMPANY, JOHN
DOE 1, JOHN DOE 2, JOHN DOE 3, et ai.,
Respondent
COMES NOW, Defendant, Lachone Trice, herein an unnamed but intended Respondent
in the above-styled civil action (hereinafter referred to as "Trice") and submits this her Answer
to Plaintiffs Petition for Interpleader responding seriatim to the numbered paragraphs thereof,
and respectfully shows unto this Honorable Court as follows:
ANSWER
1.
Trice admits Paragraph 1 of Plaintiffs Petition.
2.
Trice admits Paragraph 2 ofPlaintiifs Petition.
3.
ME&J/GNLitigationlGen'l Civilrrrice, Lachone
4.
Trice admits Paragraph 4 of Plaintiffs Petition. By way of further Answer, Trice is a
claimant of funds noted in Plaintiffs Petition; is a resident ofMusco gee County, Georgia; and
believes that she is the Respondent identified in Paragraph 4 of said Petition as John Doe 2.
Trice acknowledges that there may be other claimants of the funds noted in Plaintiffs Petition,
and that if she is not John Doe 1, she should be specifically named as one of the claimants for
such funds.
5.
6.
7.
8.
9.
Trice admits Paragraph 9 ofPlaintiffs Petition.
10.
Trice admits Paragraph 10 ofPlaintiff's Petition. By way of further Answer, Trice shows
that on October 25, 2011, she was the Seller of property located at 509 15th Avenue, Columbus,
Muscogee County, Georgia. Said property sold for the sum of Fifty-seven Thousand and no/100
($57,000.00) Dollars. As the Seller, Ms. Trice received a check (numbered 32844, drawn on
funds payable from Columbus Bank & Trust Company) in the amount of Fifty Thousand Seven
ME&J/GAlLitigationiGen'! CivillTrice, Lachone
Hundred Seventy-four and 511100 ($50,774.51) Dollars. These funds were to be drawn from the
depository account of Michael A. Eddings, P.C., depository account 30050766, for said real
estate closing held on October 25, 2011. As of the date of this Answer to Plaintiff s Petition for
Interpleader, this check has been returned "Dishonored" and Trice has been unable to collect on
the funds due and owing her.
11.
12.
13.
14.
15.
Responding to the unnumbered "WHEREFORE' paragraph of Plaintiffs Petition, Trice
responds seriatim to the sublettered paragraphs as follows:
(b) Trice has no objection to this subparagraph.
(c) Trice has no objection to this subparagraph.
(d) Trice has no objection to this subparagraph.
(e) This subparagraph requires no response.
ME&J/GNLitigation/Gen'l Civilffrice, Lachone
16.
Trice demands strict proof of any and all allegations contained in Plaintiff's Petition
Having fully responded to Plaintiff s Petition for Interpleader, Trice prays unto this
RESPECTFULLY SUBMITTED this J3- day ofNovember, 201 L
(b) That Trice's funds in the amount of Fifty Thousand Seven Hundred Seventy-four
and 511100 ($50,77451) Dollars paid by Petitioner into the Registry of this Court
be disbursed to Trice as the Court may deem appropriate;
(c) That Trice be permitted to recover attorney fees and costs from the funds paid into
the Registry of this Court; and,
(d) For such other and further relief
---.
as this Honorable Court deems just and proper.
MEACHAM, EARLEY & FOWLER, P.C.
PO Box 9031
Phone: 706-576-4064
Attorneys for Defendant, Lachone Trice
Fax: 706-596-0621
ME&J/GAJLitigation/Gen'] Civilrrrice, Lachone
VERIFICATION
STATE OF GEORGIA
COUNTY OF MUSCOGEE
Personally appeared before me, the undersigned, LACHONE TRICE, after first being
duly sworn, deposes and says that she is the Defendant in the foregoing captioned cause, and that
the facts contained herein are true and correct.
Swom to and subscribed before me this
l day of UO\rt:roCtIY ,2011.
M . 1 ~
ME&JJGAlLitigationfGen'l Civilffrice, Lachone
General Civil Case Filing Information Form (:\on-Domestic)
(
, '1 L ,"," C 'V/ /;J ,,"7
Court
County Yl/ .t/ j LVI r::..z...
Date Filed II - \ S - I
. v
.z(Superior MMDD-YYYY
o State
Docket r:SU J I CV. 3151 S
Plaintiff(s)
l2.';t
(JC/
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last
FiI'S! I. Suffi:\: Prefix
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Fir:;t Mid,lle 1. S,lillx Pretlx
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Fi;:;1.
Finit
.-------------------
Micdle l. Suffix PrefIx M,iden
I..,u First !'.Iidd!" I. Prcii;.; lo.-taili,"n
No. of Phlintiffs __"_
PlaintiffiPetitiQner'g Attol'Dey 0 Pro Se
__
1.3..S1 Fil"$l MiJdle t. sum"
Bar# 11<6050
No. of Defendants Lt VLrLLt.flL- boo v<?d .
Cllt'ck Primnry Type (Check only ONE)
o Wills/Estate
o Real Property
I 0 Dispossessory/Distress
o PersoIlal Property
o Equity
o Habeas Corpus
o Appeals, Reviews
o Post J Ildgment Garnishment, AUachment, or
Other
o Nou-DC\mestic Conrempt
o Tort ({ftort, fill in right column) II
;6 Othcr
1\ ,
! . -'JvtXeV 0lCCcLQ v2...
"
If Tort is Case Type;
(Check no more than T\VO)
o Auto Accident
o PNmises JJlIbililY
o Medkal Malpractice
.-ErOther Prof<;sslonal Negligence
o Product Li<lbllity
o Other
Are Punitive Damages Pleaded? )2'"Yes 0 No
IN THE SUPERIOR COURT OF MUSCOGEE COUNTX: I L r, 'I U C. -::::' .', i:'
it ..... U ,'", Ii, ... {_
STATE OF GEORGIA
lull NOV 14 AN !O: 58
COLUMBUS BANK AND TRUST COMPANY,
*
A DIVISION OF SYNOVUS BANK,
*
*
Petitioner,
*
*
Vs.
*
'"
LAW OFFICE OF MICHAEL A. EDDINGS, P.C., *
FIRSTAMERICAN TITLE INSURANCE *
COMPANY, JOHN DOE 1, JOHN DOE 2, *
JOHN DOE 3, ET AL. *
*
Respondents.
*
NOTICE OF HEARING
Please be advised that the MOTION FOR PAYMENT OF FUNDS FROM THE REGISTRY OF THE
COURT filed in the above referenced matter has been scheduled and will now come on before this
Court for hearing, before the Honorable Bemon G. McBride, III, Judge, on Monday, November
28, 2011, at 10:00 a.m., on the 11th floor of the Columbus Consolidated Government Center,
Columbus, Muscogee County, Georgia.
This of November, 2011.
DENNEY, PEASE, ALLISON & KIRK

Ga. Bar No.: 013000
Columbus, Georgia 31902-2648
(706) 324-3711
I do hereby certify that I have served a copy ofthe NOTICE OF HEARING by depositing
the same in the United States mail properly addressed and with sufficient postage thereon to
insure delivery to the following:
Columbus Bank & Trust Company
clo Page, Scrantom, Sprouse,
Tucker & Ford, P.C.
William L. Tucker
P.O. Box 1199
Columbus, GA 31902
clo Michael A. Eddings, as Registered Agent
860 Brookstone Centre Parway, Suite B
Columbus, GA 31904
FirstAmerican Title Insurance Company
clo C. Scott Logan, as Registered Agent
5607 Glenridge Drive, N.E., Suite A200
Atlanta, GA 30342
First American Title Company
clo Corporation Service Company, as Registered Agent
40 Technology Parkway South, Suite 300
Norcross, GA 30092
Meacham, Earley & Fowler, P.C.
Attn: Christopher L. Meacham
P.O. Box 9031
Columbus, GA 31908
~
This Jl. day of November. 2011.
Of Counsel for Jerome Rogers
STATE OF GEORGIA
*
*
BANK,
*
* CIVIL ACTION FILE
Petitioner, * NO. SUI I CV-3875
*
v.
*
*
LAW OFFICE OF MICHAEL A. EDDINGS, 11<
P.C., FIRSTAMERICAN TITLE INSURANCE *
COMPANY, JEROME ROGERS, LACHONE *
TRICE, IKE A. NWAOBI, UNITED STATES ...
OF AMERICA, FOR US CORPS OF *
ENGINEERS, FEDERAL NATIONAL *
MORTGAGE ASSOCIATION, TRC *
GLOBAL SOLUTIONS, INC.; ELIZABETH *
WALLER, ET. At., ...
*
Respondents.
*
FIRST AMENDMENT TO PETITION FOR INTERPLEADER
In filing this First Amendment, Petitioner shows as follows:
1.
Respondent John Doe 1 has now been identified as Jerome Rogers. Mr. Rogers
has filed responsive pleadings and in so doing has made a claim for $89,498.90.
Respondent requested that the latter be paid to him from the monies interplead by
Petitioner.
2.
Respondent John Doe 2 has now been identified as Lachone Trice. Ms. Trice has
filed responsive pleadings and in so doing has made a claim for $50,774.51. Respondent
requested that the latter be paid to her from the funds interpled by Petitioner.
3.
Respondent John Doe 3 has now been identified as Ike A. Nwaobi. Mr. Nwaobi
has filed responsive pleadings and in so doing has made a claim for $9,800.00.
Respondent requested that the latter be paid to him from the funds interpled by Petitioner.
4.
Respondent John Doe 4 has now been identified as the United States of America
and through it, The Corps of Engineers. United States has not filed responsive pleadings,
but has notified Petitioner that it intends to do so and that it will make a claim of
$87,421.04,
5.
Respondent John Doe 5 has now been identified as Federal National Mortgage
Association ("Fannie Mae"). Fannie Mae has not filed responsive pleadings but has
advised Petitioner that it will make a claim of $174,825.20. According to information
received, said claim pertains to a closing involving Crescent Mortgage and a wire transfer
into the account in question of $194,137.49.
6.
Respondents John Doe 6 and 7 have now been identified as TRC Global
Solutions, Inc., ("TRC") and, on information and belief, Elizabeth Waller. TRC and
Elizabeth Waller have not filed responsive pleadings but TRC has advised Petitioner that
a claim of$145,621.82 will be made for Respondents.
Wherefore, Petitioner prays that this Amendment be permitted and:
(a) That the usual proceedings be had as in all cases of a Bill of
Interpleader;
(b) That the Court issue an order directing the disposition of the funds
described herein;
(c) That an Order be issued discharging Petitioner from further
obligation with respect to said monies and account;
(d) That Petitioner be permitted to recover its costs from the funds paid into
the registry of the Court, and
(e) For such other and further relief as may be just and proper, premises
considered.
This;2l S''day of November, 2011.
PAGE, SCRANTOM, SPROUSE,
TUCKER & FORD, P .C. ,-
By: 'lJdA ~ k -
William L. Tucker
1111 Bay Avenue State BarNo.: 718050
Post Office Box 1199 Attorneys for Columbus Bank and
Columbus, Georgia 3 1902-1199 Trust Company, a Division ofSynovus
(706) 324-0251 Bank
STATE OF GEORGIA
*
*
BANK,
'"
'" CIVIL ACTION FILE
Petitioner, '" NO. SUll CV-3875
*
v.
'"
*
LA W OFFICE OF MICHAEL A. EDDINGS, *
P.C., FIRSTAMERlCAN TITLE INSURANCE '"
COMPANY, FIRST AMERICAN TITLE '"
COMPANY, JEROME ROGERS, LACHONE *
TRICE, IKE A. NWAOBI, UNITED STATES '"
OF AMERICA, FOR US CORPS OF *
ENGINEERS, FEDERAL NATIONAL *
MORTGAGE ASSOCIATION, TRC '"
GLOBAL SOLUTIONS, INC.; ELIZABETH *
WALLER, ET. AL., *
*
Respondents.
'"
I do hereby certify that I am counsel for Petitioner in the above-styled action and
that I have this day served a copy of the above and foregoing Amendment to Petition for
Interpleader by emailing and mailing a copy of same, postage prepaid to the following:
860 Brookstone Center Parkway
Suite B
Columbus, Georgia 31904
Weissman, Nowack, Curry
& Wilco, P.C.
One Alliance Center
4th Floor
3500 Lenox Road
Atlanta, Georgia 30326
Attorney for First American Title Insurance Company
Mobile, Alabama 36609
P. O. Box 2648
P. O. Box 9031
Attorney for Lachone Trice
P. O. Box 9031
Attorney for Ike A. Nwaobi
Benjamin A. Land
Buchanan & Land, LLP
P.O. Box 2848
1425 Wynnton Road
Attorney for TRC Global Solutions, Inc.
Michael Moore, Esq.
United States Attorney
Attention: Ms. Veronica Jones
Civil Process Clerk
P.O. Box 1702
Macon, Georgia 31202
Attorney for United States of America
This 2...r..l-day of November, 2011.
1111 Bay Avenue
Co lumbus, Georgia 31902-1199
(706) 324-0251
PAGE, SCRANTOM, SPROUSE,
TUCKER & FORD, P.c.
By:LJA-'~
William L. Tucker
State Bar No.: 718050
Attorneys for Columbus Bank and
Trust Company, a Division ofSynovus
Bank
STATE OF GEORGIA
COMPA."N, A DIVISION OF SYNOVUS SU-II-CV-3875
.....,.
c:::>
BANK,
:r;
....,

'04

-
Petitioner ::z::
,- .
-Onr" 0
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fTlo-' -<:

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TITLE rNSURANCE COMPANY, FIRST
-4-
41
'"
-<
W
DOE I, JOHN DOE 2, JOHN DOE 3, et aI.,
Respondent
COMES NOW, Defendant, FBMC Corporation d/b/a First Banker's Mortgage
Corporation. herein an unnamed but intended Respondent in the above-styled civil action
(hereinafter referred to as "FBMC") and submits this his Answer to Plaintiffs Petition for
Interpleader responding seriatim to the numbered paragraphs thereof, and respectfully shows
unto this Honorable Court as follows:
1.
F BMC admits Paragraph 1 of Plaintiff's PClition.
2.
FBMC admits Paragraph 2 ofPlaintifi's Petition.
3.
FRMC admits Paragraph 3 of Plaintiffs Petition.
4.
FBMC admits Paragraph 4 of Plaintiff Petition. By way of further Answer, FBMC is a
claimant of funds notcd in Plaintiffs Petition, is a Georgia Corporation doing business in
Muscogee County, Georgia, and believes that it is the Respondent identified in Paragraph 4 of
said Petition as John Doe 1. FBMC acknowledges that there may be other claimants of the funds
noted in Plaintiff's Petition, and that if it is not John Doe 1, it should be specifically named as
one of the claimants for such funds.
5.
FBMe admits Paragraph 5 of Plaintiff's Petition.
6.
FBMC admits Paragraph 6 of Plaintiffs Petition.
7.
8.
9.
10.
FBMe admits Paragraph 10 of Plaintiffs Petition. By way of further Answer, FBMC
shows that on or about October 27,2011, FBMC, (a Mortgage Broker) brokered a property sale
and a loan transaction which was closed by the Law Office of Michael A. Eddings. P.c. The
purchase and sale was completed and the lender which FBMC procured, wired $194,137.49 to
Attorney Michael A. Eddings by and through Petitioner. Although the sale/loan transaction was
completed by Attorney Michael A. Eddings and Mr. Eddings' office had agreed to deliver to
FBMC the sum of $7,161.61 along with certain loan closing documents, that FBMC is required
by the State of Georgia Banking Commission to keep in file. FBMC never received said funds
or the required documents (see attached HUD-l Settlement Statement as proof of closing).
11.
FBMC admits Paragraph Il of Plaintiff s Petition.
12.
FBMC admits Paragraph l2 of Plaintiffs Petition.
13.
FBMe admits Paragraph 13 of Plaintiff's Petition.
14.
15.
Responding to the unnumbered "WHEREFORE" paragraph of Plaintiffs Petition,
FBMC responds seriatim to the sublettered paragraphs as follows:
(b) FBMC has no objection to this subparagraph.
(c) FBMC has no objection to this subparagraph.
(d) FBMC has no objection to this subparagraph.
(e) This subparagraph requires no response.
16.
FBMC demands strict proof of any and all allegations contained in Plaintiff's Petition
Having fully responded to P1aintiff's Petition for lnterpleader, FBMC prays unto this
(a) That this Answer be accepted and filed in accordance with law:
(b) The FBMe's funds in the amount of Seven Thousand One Hundred Sixty-One
and 61/100's ($7,161.61) Dollars paid by Petitioner into the Registry of this
Court be disbursed to FBMC as the Court may deem appropriate;
(c) That FBMC be permitted to recover attorney fees and costs from the funds paid
into the Registry of this Court;
(d) That a hearing on said matter be set down for determination as soon as possible;
and
(e) For such other and further relief as this Honorable Court deems just and proper.
RESPECTFULLY SUBMITTED this --.-Lbt"""day of November. 2011.
Columbu..c;, GA 31906
Phone: 706-324-7600
Fax: 706-324-0856
IN THE SUPERJOR COURT OF MUSCOGEE COUNTY
STATE OF GEORGIA
COMPANl', A DIVISION OF SYNOVUS SU-II-CV-3875
B ~ ~
Petitioner

VS.

EDDINGS, P .C., FIRST AMERICAN
DOE 1, JOHN DOE 2, JOHN DOE 3, et al.,
Respondent
This is to certify the undersigned has served Plaintiff with a copy of Answer to Plaintiffs
Petition for Interpleader by mailing via first class mail, postage prepaid, a copy of the same to
Plaintiffs attorney of record:
William L Tucker
Page, Scrantom, Sprouse, Tucker and Ford
PO Box 1199
Columbus, GA 31902
~ " ' "
This / ~ _ day of November, 2011.
O. WAYNE SPENCE, P.C.
Columbus, GA 31906
Phone: 706-324-7600
Fax: 706-324-0856
IN THE SUPERIOR COURT OF MUSCOGEE COUNIT
STATE OF GEORG1A
COLUMBUS BANK AND TRUST CIVJL ACTION FILE NO.
COMPANY. A DIVIS rON OF SYNOVUS SU-1I-CV-3875
BANK,
Petitioner
vs.

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LA W OFFICE OF MICHAEL A.
EDDINGS, P.c., FIRST AMERICAN
TITLE INSUR.Al'1CE COMPANY, FIRST

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AMERICAN TITLE COMPANY, JOHN -<
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DOE 1, JOHN DOE 2. JOHN DOE 3, et aI.,
Respondent
ANSWER TO PLAINTIF,F'S PETITION .FOR INTERPLEADER
COMES NOW, Defendant, William Rembert, herein an unnamed but intended
Respondent in the above-styled civil action (hereinafter referred to as "Rembert") and submits
this his Answer to Plaintiffs Petition for Interpleader responding sen'atim to the numbered
paragraphs thereof, and respectfully shows unto this Honorable Court as follows:
l.
Rembert admits Paragraph 1 of Plaintiffs Petition.
2.
3.
Rembert admits Paragraph 3 of Plaintiff's Petition.
4.
Rembert admits Paragraph 4 of Plaintiff Petition. By way of further Answer, Rembert is
a claimant of funds noted in Plaintiff's Petition, and believes that he is the Respondent identified
in Paragraph 4 of said Petition as John Doe 1. Rembert acknowledges that there may be other
claimants of the funds noted in Plaintiff's Petition, and that ifhe is not John Doe 1, he should be
specifically named as one of the claimants for such funds.
5.
6.
7.
8.
9.
10.
Rembert admits Paragraph 10 of Plaintiffs Petition. By way of further Answer, Rembert
shows that in anticipation of closing a real estate transaction of which Defendant, Michael A.
Eddings was to be the closing attorney, Rembert at the direction of Defendant, Ytichael A.
Eddings caused certain funds in the amount of $3, lOO.OO to be wire transferred or deposited in
the Trust Account of Plaintiff on or about October 26, 2011 ("Funds"). The real estate
transaction did not occur, due in part to Plaintiffs filing the within action, so that the Funds
belonging to Rembert were part of the funds paid into the Registry of this Honorable Court by
Plaintiff. Rembert stands ready to provide all such documentation necessary or desirable to
prove to this Honorable Court and others that Rembert is entitled to the Funds at such time as
Plaintiff or this Honorable Court requests.
11.
12.
13.
14.
Rembert admits Paragraph 14 of Plainti ff' s Petition.
15.
Responding to the unnumbered .. WHEREFORE" paragraph of Plaintiff's Petition,
Rembert responds seriatim to the sublettered paragraphs as follows:
(b) Rembert has no objection to this subparagraph.
(c) Rembert has no objection to this subparagraph.
(d) Rembert has no objection to this subparagraph.
(e) This subparagraph requires no r6Sponse.
16.
Rembert demands strict proof of any and aU allegations contained in Plaintiff's Petition
Having fully responded to Plaintiffs Petition for Int<..-rpleader, Rembert prays unto this
(b) The Rembert's funds in the amount of Thirty One Hundred and 00/100' s
($3,100.00) Dollars paid by Petitioner into the Registry of this Court be disbursed
to Rembert as the Court may deem appropriate;
(c) That Rembert be pcnnittcd to recover attorney fees and costs from the funds paid
into the Registry of this Court;
(d) That a hearing on said matter be set down for determination as soon as possible;
and
(e) For such other and further relief as this Honorable Court deems just and proper.
-t'"
RESPECTFULLY SUBMlTI'ED this day of November, 2011. I ~
o. WAYNE SPENCE, P.C.
Columbus, GA 31906
Phone: 706-324-7600
Fax: 706-324-0856
BUCI-IANAN & LAND, LLP
A'l'TORNEYS A'l' LAW
1425 WYNNTON ROAD
P. O. BOX 2848
COLUMBUS, GEORGIA 31902
JERRY A. BUCHA:-IAN ;0 TELEPHONE: (706) 3z3-2848 Writer's E-Mail Address:
BENJAMIN A. IJAND ;0
1706) 3234242
ben land@buchananland.com
.JAMES D. LAMB
WWW.BUCHANANLAND.CO:M
TIUSHA D. HARGROVE
,\VILLIAM A. BUCIlANAN
LORI M. LEONARDO
ADMITTED IN GA & AI-
November 21,2011
By Hand Delivery
Honorable Judge Bemon G. McBride, III
100 10lh Street
Government Center
Tower, 4th Floor
Columbus, GA 31901
Re: Columbus Bank and Trust Company, A Division of Synovus Bank
v. Law Office of Michael A. Eddings, P.C., et al.
Superior Court of Muscogee County, Georgia
Civil Action File No. SU-11-CV-3875
Dear Judge McBride:
This should confirm that I represent TRC Global Solutions, Inc. in the above referenced
mattcr. I have enclosed copies of the following documents I have filed today.
1. TRC Global Solutions, Inc. 's Answer to Petition for Interpleader;
2. TRC Global Solutions, Inc. 's Motion for Payment of Funds from Registry of
Court; and
3. Notice of Hearing.
I look forward to addressing this matter with you on Monday, November 28,2011.
lir:?jre1
y
,
\./ tt n-, j 1"\ a
Benja i A. Land
Forth rm
BALlpj
Enes.
ec: Michael A. Eddings
Michael Moore, Esq.
STATE OF GEORGIA
COLUMBUS BANK AND TRUST *
COMPANY, A DIVISION OF SYNOVUS *
BANK *
*
Petitioner,
*
*
v. * Civil Action File No. SU-II-CV-387S
*
*
*
*
*
DOE 1, JOHN DOE 2, JOHN DOE 3, et at,
*
*
Respondents.
*
TRC GLOBAL SOLUTIONS, INC.'S ANSWER TO PETITION FOR
INTERPLEADER
COMES NOW TRC Global Solutions, Inc. ("TRC"), identified as "John Doe" in
the above-styled action, and files this its Answer to Petitioner's Petition for Interpleader,
and respectfully shows the Court the following:
1.
TRC admits the allegations contained in Paragraph 1 of Petitioner's Petition for
Interpleader.
2-3.
TRC is without knowledge or information sufficient to form a belief as to the
truth of the allegations contained in Paragraphs 2 and 3 of Petitioner's Petition for
Interpleader.
4.
Responding to Paragraph 4 of Petitioner's Petition for Interpleader, TRC admits
that it is a claimant of the funds in question. TRC further shows the Court that the
amount ofits claim is $145,621.82.
5-7.
truth of the allegations contained in Paragraphs 5, 6, and 7 of Petitioner's Petition for
Interpleader.
8.
TRC admits the allegations contained in Paragraph 8 of Petitioner's Petition for
Interpleader and further shows the Court the following:
At the time Petitioner paid the balance of the trust account at issue into the
registry of the Court, the trust account contained a total of $145,621.82 that was paid into
the trust account for the benefit of TRC. Those funds rightfully belong to TRC and/or
should be paid to others on TRC's behalf. Those funds were paid into the trust account
as a result of a real estate closing that occurred on October 25, 2011. That closing was
designed to consummate the sale of real estate located at 2238 Birchwood Drive,
Columbus, Georgia, 31909. TRC was the seller of this property, and Amanda Elizabeth
Waller was the buyer. As part of that closing, TRC fulfilled its obligation to sign the
deed to the property over to the buyer. In return, sufficient funds were deposited into the
trust account to cover the following obligations ofTRC which were to be paid with said
funds as the consideration for TRC's transfer of the property:
$135,930.49 to be paid to Chase Home Finance, LLC ("Chase") to satisfy TRC's
debt to Chase (which debt is secured by a security deed against the property in
question)!
As a result of this debt and the property taxes described below not being paid as
intended, Chase has paid the property taxes and TRC has paid the November mortgage
I
$6,770.00 to be paid to Coldwell Banker Kennon Parker Duncan & Key to satisfy
a real estate commission for the sale of the property in question
$30.00 to be paid to The Law Office of Michael A. Eddings, P.e. for a wire fee in
connection with the transaction for the sale of the property in question
$12.00 to be paid to the Clerk of Superior Court for certain government recording
and transfer charges in connection with this transaction
2
$983.00 to be paid to Associated Title & Closing Company, LLC for a closing fee
and related overnight fee in connection with this transaction
$1,097.33 to be paid to the Muscogee County Tax Commissioner for property
taxes on the property in question
3
$399.00 to be paid to Home Buyers Resale Warranty Corp. for a home warranty
on the home situated on the property in question
$400.00 to be paid to Gary G. Lawson, P.e. for a closing fee in connection with
this transaction
A true and correct copy of the Settlement Statement (HUD-I) for the closing of this
transaction is attached hereto as Exhibit 1. The funds that should have been paid out of
the trust account to Chase Home Finance, LLC ($135,930.40), Coldwell Banker Kennon
Parker Duncan & Key ($6,770.00), Associated Title & Closing Company, LLC
($983.00), and Gary G. Lawson, P.C. ($400.00) were not paid as they should have been
payment to Chase. As a result, the amount owed to Chase, as of November 28, 2011, is
$135,767.51. That amount will increase by $22.21 per day for every day the debt is not
paid. The $135,767.51 figure is the amount that should be paid to Chase out of the funds
currently in the registry of the Court, as of November 28,2011. For every day that passes
after November 28, 2011, $22.21 should be added to the amount that should be paid out
of the registry of the Court to Chase-subject to the cap of $135,930.49, which is the
amount actually paid into the trust account for the satisfaction of the Chase debt.
2 This $12.00 charge has been included in Chase's payoff figure referenced in footnote l.
Thus, in order to avoid a double payment, TRC is not requesting that a separate payment
of $12.00 be made to the Clerk of Superior Court.
3 As referenced in footnote 1, these property taxes have since been paid by Chase. As a
result, there are no property taxes currently owed, and the amount of the debt to Chase
has increased due to the tax payment.
and remained in the trust account at the time Petitioner paid said funds into the registry of
the Court. Thus, those funds are presently part of the funds that are in the registry of this
Court. On information and belief, it appears that the funds that should have been paid out
of the trust account to cover the other obligations described above were likewise not paid
and also remained in the trust accoWlt at the time Petitioner paid said funds into the
registry of the Court.
The funds deseribed above are now in the registry of the Court and, absent an
Order of the Court, cannot be paid to the entities that are entitled to be paid on TRC's
behalf. The Court should enter an Order directing the payment of these funds to the
entities described above (without deduction for attorney's fees or other costs and with the
balance of any funds remaining after the payment of these entities to be paid to TRC),
thereby allowing this real estate transaction to be finally consummated as intended by the
parties thereto. Absent such an Order, TRC will be irreparably harmed.
9-10.
truth of the allegations contained in Paragraphs 9 and 10 of Petitioner's Petition for
Interpleader. Responding further, TRC shows that there is no uncertainty as to TRC's
rights in this matter.
11.
i
i
On information and belief, TRC admits Paragraph 11 of Petitioner's Petition for
Interpleader.
12.
f
I
TRC is without knowledge or infonnation sufficient to fonn a belief as to the i
truth of the allegations contained in Paragraph 12 of Petitioner's Petition for Interpleader.
However, TRC responds that there is no uncertainty as to its rights in this matter. For the
reasons shown above, it is entitled to have $145,621.82 paid out of the funds at issue at
this time for its benefit. Said payments should be payable to the entities described above
in Paragraph 8 ofthis Answer.
13-14.
TRC shows that Paragraphs 13 and 14 of Petitioner's Petition for Interpleader
constitute legal conclusions requiring no answer, and therefore, TRC neither admits nor
denies the allegations contained in Paragraphs 13 and 14.
15.
TRC denies each and every other allegation contained in Petitioner's Petition for
Interpleader not specifically admitted or otherwise answered hereinabove.
WHEREFORE, having fully responded to Petitioner's Petition for Interpleader,
TRC requests the following relief:
A. That it be given the judgment of this Court;
B. That an Order be entered directing the payment of $145,621.82 from the
funds currently in the registry of the Court as follows:
$135,767.51 to be paid to Chase and an additional $22.21 per day to be
paid to Chase for every day after November 28, 2011, provided that the
amount to be paid to Chase out of these funds shall not exceed
$135,930.49 (the amount paid into the trust account for the satisfaction of
the Chase debt);
$6,770.00 to be paid to Coldwell Banker Kennon Parker Duncan & Key;
$983.00 to be paid to Associated Title & Closing Company, LLC;
$400.00 to be paid to Gary G. Lawson, P.C. for a closing fee in connection
with this transaction;
The payment of all other sums that shou1d have been paid to the entities
described in Answer but which were not paid;
The payment to TRC of $145,621.82 less the aggregate amount of the
payments described above; and
C. That it be granted any and an other relief allowed by law.
This ZIs f day of November, 2011.
BUCHANAN & LAND, LLP
BY;CL:,A,W
B ~ n d
William A. Buchanan
Attorneys for TRC Global Solutions,
Inc.
(706) 323-2848
OMS Approva! No. 2502'(}265
A. Settlement Statement (HUO.i)
B. Type of ......n
1./& FHA 2.0FIHS
EXHIBIT
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Ale Number. 1-1.0150
L """'l..IEMSN1" CHARGES: PAID FROM I PAID fROM
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SETTUaMENT SETTlEMENT
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iTolal m0fl1l"ly amount ()WeQ including esClOW accQlmt .... have a monlhly -,;,;;;;;" for such prope,lJ' --._,.
i lax"" .TId fiom"""""l(' In$Ora,,><:., Vou must pay Ihese lIem. direcUy yours.,I.
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Nola: H you arrl que.SI!oflS a!>cut tt.e SeHtement and loan Tenus on thiS ple3se contact your
_.,------------------- --_..
HUD-l CERTlFICATION
I hllve carefully reviewed the HUDl Settlement Statement and to the besl of my knowledge and belief. it is a bue
and accutate statement of all re.:eipls aM disbW"Sem"ms llIade on roy account or by me ill this tt'lInsaction.
I further certify thaI I haV\: a copy orlb<: H1JD..l Settlemenl Stalemen!.
1. if the PurchaserlBorrower, acknowledge receipt in full of the loan proceeds, aM if the SeUer, acknowledge
payment in full of the proceeds due me,
If tlris transaction involves a sale, 1 agree 10 adjust the laX proratiollS shown on tm: Statement wben the
actual ad valorem tax bill is rendered.
If this transaction involves a sale. as part of the consideration therefore. I ag:ree thaI the cOlllr.ct between the porties
is by reference incorporated herein and made a part hereof, and thai the terms ll1Id conditiollS thereof shall survive the
closing alld shaU not merge uJXin dctivC1Y of the deed.
I swear Dr affirm Ilul t am of legal age and of sound mi.'!d, .and thB.l if I om the Seller, am a citizen of tile United
SillIeS of America, or if. corporation or otber entilY. am duly fanned under !he laws of !be United States of Amenta or
one of the Stale. thereof, an<! affmn my non, foreign slatus.
Seller me Global Solutions, tnc., a
Wisconsin C;>rporati'm
by: Gill)' O. Lawson. Anomcy in Fact
Borrower
SeUer ..---"',,-----,------
To ll,e Ix.t of my knowledge the HUDI Settlement wlliGb I have prepared is a t{1J and 3CCUfate account
oftlle funds Which were received nnd bave bi!cn Or will be disbursed by tm: ulldersigned as part. or the l(cUleruent oflhis
transaction.
Pare: OctGber 15, If)ll
WA1Ul/lNG: It is D clime to knowirygly make fillse staiemcnts to rhe United States on tltis or allY other similar form.
PeLlalljes upon convictioo call include a fine a."ld imprisollmellt. For cet.,i1 see: Tide) 8: U.S. Code. SectiOIlS 1001 and
Secrion 10 10.

RUD-l Cl!.R.TmCA TION
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s..... or Amulco. '" if. _tiooOf.<hot..oily .,. duly _ _ Ibo Uo!!<d s..u:. of"-,,,, or
one. or the: Suw thaeot =Y QrOl.Arnisc. """J.:t,
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VERIFICATION
STATE OF CONNECTICUT
COUNTY OF NEW HAVEN
PERSONALLY APPEARED before the undersigned officer authorized to
administer oaths in and for said County and State, the undersigned, who being duly sworn
and put to oath, deposes and says on oath, and based upon his/her personal knowledge,
that the information contained in the foregoing Answer to Petition for Interpleader is true
and correct
This 21 st day of November, 20 II.
TRC Global Solutions, Inc.
BY:
uly Authorized Agent
' ~ ~ ~ ~ ~ ~ ~ ~ _____________
Sworn to and subscribed before me
This 21'1 day of November, 2011.
r
ires:
VALERIE A. JOHNSON
NOTARY PUBLIC
mCQMMI88ION EXPIRES JUNE 30. 2015
This is to certify that I have this date served the opposing parties in the foregoing matter,
with a copy of the above and foregoing by depositing in the United States Mail a copy of the same
in a properly addressed envelope with adequate postage thereon to:
Law Office of Michael A. Eddings, P.e.
do Michael A. Eddings, As Registered Agent
Suite B
Weissman, Nowack, Curry & Wilco, P.C.
One Alliance Center
4th Floor
3500 Lenox Road
Attorney for first American Title Insurance Company
P. O. Box 2648
P. O. Box 9031
Michael Moore, Esq.
Civil Process Clerk
P. O. Box 1702
This .Jj * day ofNovember, 2011.
(706) 323-2848

Benjamin A. Land
William A. Buchanan
Attorneys for TRC Global Solutions, Inc.
STATE OF GEORGIA
BANK
Petitioner,
v.
DOE 1, JOHN DOE 2, JOHN DOE 3, et at,
Respondents.
*
*
*
*
*
*
* Civil Action File No. SU-11-CV-3875
*
*
*
*
*
*
*
*
TRC GLOBAL SOLUTIONS, INC.'S MOTION FOR PAYMENT OF FUNDS FROM
REGISTRY OF COURT
COMES NOW TRC Global Solutions, Inc. ("TRC"), identified as "John Doe" in
the above-styled action, and moves the Court to enter an Order directing the release of
funds from the registry of the Court, to be paid as described below.
TRC has filed a verified Answer in the above-captioned action. That verified
Answer is hereby adopted by reference as if fully set forth herein.
For the reasons set forth in TRC's verified Answer, the sum of $145,62l.82 was
paid into the trust account that is the subject of this action for the benefit of TRC. Those
funds rightfully belong to TRC and, to the extent they have not already been paid, should
be paid to the entities described in TRC's verified Answer. Those funds were paid into
the trust account as a result of a real estate closing that occurred on October 25, 2011.
That closing was designed to consummate the sale of real estate located at 2238
Birchwood Drive, Columbus, Georgia, 31909. TRC was the seller of this property, and
Amanda Elizabeth Waller was the buyer. As part of that closing, TRC fulfilled its
obligation to sign the deed to the property over to the buyer. In return, sufficient funds
were deposited into the trust account to cover the obligations of TRC, as described in
TRC's verified Answer.
The funds that should have been paid out of the trust account to Chase Home
Finance, LLC ($135,930.40), Coldwell Banker Kennon Parker Duncan & Key
($6,770.00), Associated Title & Closing Company, LLC ($983.00), and Gary G. Lawson,
P.C. ($400.00) were not paid as they should have been and remained in the trust account
at the time Petitioner paid said funds into the registry of the Court. Thus, those funds are
presently part of the funds that are in the registry of this Court. It appears that the funds
that should have been paid out of the trust account to cover the other obligations
described in TRC's verified Answer were likewise not paid and also remained in the trust
account at the time Petitioner paid said funds into the registry of the Court.
So that this real estate transaction may be finally consummated as intended by the
parties thereto, TRC requests that the Court enter an Order directing the payment of the
following funds from the registry ofthe Court at this time:
$l35,767.51 to be paid to Chase and an additional $22.21 per day t{) be
paid to Chase for every day after November 28, 2011, provided that the
amount to be paid to Chase out of these funds shall not exceed
$135,930.49 (the amount paid into the trust account for the satisfaction of
the Chase debt);
$6,770.00 to be paid to Coldwell Banker Kennon Parker Duncan & Key;
$983.00 to be paid to Associated Title & Closing Company, LLC; and
$400.00 to be paid to Gary G. Lawson, P .C. for a closing fee in connection
with this transaction.'
When the Court is presented with proof that the other entities described in TRC's I
TRC requests that the Court consider this Motion on an expedited basis due to the
fact that these funds are indisputably owed and should be paid at this time and the fact
that TRC continues to suffer harm each day that these funds are not paid.
WHEREFORE, TRC requests that the Court grant this Motion and direct that the
payments requested above be made at this time.
,--.:>! I-
This L J. day of November, 2011.
BY:
~ ~ ~ ~
Benjarrn . and
William A. Buchanan
Attorneys for TRC Global Solutions,
Inc.
(706) 323-2848
verified Answer have not been paid out of the trust account, the Court should enter an
Order directing the payment of those entities, with the balance of the funds paid into the
registry for TRC's benefit to be paid to TRC.
This is to certify that I have this date served the opposing parties in the foregoing matter,
with a copy of the above and foregoing by depositing in the United States Mail a copy of the same
in a properly addressed envelope with adequate postage thereon to:
Suite B
Weissman, Nowack, Curry & Wileo, P.C.
One Alliance Center
4th Floor
3500 Lenox Road
Attorney for first American Title Insurance Company
718 DowntownerBlvd.
P. O. Box 2648
P. O. Box 9031
Michael Moore, Esq.
Civil Process Clerk
P. O. Box 1702
This .2 fg day of November, 2011.
B Y : ~ ~
Benjamin A. Land
William A. Buchanan
Attorneys for TRC Global Solutions, Inc.
(706) 323-2848

Columbus Bank & Trust vs. Michael A. Eddings Lawsuit: Docket, Notice of Removal, Complaint, Exhibit A

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