52- First Amended Complaint

8/16/2019 52- First Amended Complaint

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IN THE UNITED STATES DISTRICT COURTEASTERN DISTRICT OF ARKANSAS

EASTERN DIVISION

STEPHANIE DEVAZIER, as classrepresentative in Sara Stewmon vs. SEECO, Inc.,Desoto Gathering Company, LLCand Southwestern Midstream PLAINTIFF

v. Case No. 2:16-cv-00067-KGB

BEN H. CARUTH, et al. DEFENDANTS ________________________________________________________________

FIRST AMENDED COMPLAINT FOR TEMPORARY INJUNCTIONAND PERMANENT INJUNCTION

________________________________________________________________

Comes the Plaintiff, Stephanie Devazier, by her attorneys E. Dion Wilson,

B. Michael Easley and Timothy R. Holton and pursuant to FRCP 15 A (1) (b), for

her First Amended Complaint for Temporary Injunction and Permanent Injunction,

states:

Plaintiff ’s first complaint for temporary and permanent injunction

is incorporated herein by reference and is now amended as follows:

1. The Plaintiff Stephanie Devazier is an adult resident of St. Francis

County, Arkansas, and is, by appointment of the Circuit Court of St. Francis

County, the class representative for all members of the class certified in the matter

Case 2:16-cv-00067-KGB Document 52 Filed 05/31/16 Page 1 of 22


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of Stewmon v. SEECO, DeSoto Gathering Company, LLC and Southwestern

Midstream Services Company . She brings this action in her capacity as Class

Representative, and does so in accordance with her duties and responsibilities as

such duly appointed class representative.

2. All Defendants (hereafter referred to as “Defendant lawyers”) are

attorneys who are involved in the matter of Connie Jean Smith v. SEECO, DeSoto

Gathering, Southwestern Energy Services Company and Southwestern Energy

Company . (Smith v. SEECO )

The individual Defendant Lawyers are as follows:

Ben H. Caruth, Morrilton, AR. ; Jason E. Roselius, Oklahoma City, Ok;

Brad E. Seidel, Austin Tx.; Edward Allen Gordon, Morrilton, AR.; Tanner W.

Hicks, Oklahoma City, OK.; Erik P. Danielson, Fayetteville, Ar.; Sean M.

Handler, Radnor, Pa.; Brian L. Cramer, Oklahoma City, Ok.; Jack A. Mattingly,

Jr. Seminole, Ok.; Andrew King, Little Rock, Ar.; Frederick H. Davis, Little

Rock, Ar.; Jess L. Askew, Little Rock, Ar.; Michael Vance Powell, Dallas, Tx.;

Marc Tabolsky, Houston, Tx.; Robert K. Ellis, Houston, Tx.; Matthew K.

Kansen, Dallas, Tx.; Rex M. Terry, Fort Smith, Ar.; Paul Yetter, Houston, Tx.;

and Thomas A. Daily, Fort Smith, Ar.

Defendants Caruth, Roselius, Seidel, Gordon, Hicks, Danielson, Handler,

Cramer, and Mattingly are appointed class counsel in the matter of Smith v.



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SEECO and are referred to hereinafter collecti vely as the “Caruth Defendants .”

Defendants Daily, Terry, Askew, King, Davis, Tabolsky, Yetter, Ellis,

Powell, and Hansen represent the Defendants in the Smith v. SEECO matter and

are hereinafter referred to collectively as “SWN Defendants.”

3. This matter was originally filed in the Circuit Court of St. Francis

County Arkansas. The SWN Defendants filed a notice of removal in the Circuit

Court of St. Francis County, and pursuant to that Notice of Removal, this matter

has been lodged with this United States District Court.

Facts and Allegations

4. On September 27, 2013, Sara Stewmon filed a class action complaint

against SEECO, DeSoto Gathering and Southwestern Midstream Services

Company. That action is hereinafter referred to as Stewmon v. SEECO et al .

On September 30, 2014 the Circuit Court of St. Francis County, Arkansas,

The Hon. L.T. Simes presiding, issued an order certifying a class in Stewmon v.

SEECO et al . The class is comprised of the following persons:

“All residents of the State of Arkansas who entered into leases withDefendant SEECO (up through September 27, 2013) for the development and

operation of natural gas wells on property located in the State of Arkansas andwho signed leases allowing for deduction of reasonable costs for gathering,compression, treatment and marketing. Specifically excluded are any leases whichhave non-Arkansas residents as parties to the lease.”

5. Attorneys E. Dion Wilson, B. Michael Easley and Timothy R. Holton



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were appointed as class counsel by Judge Simes. Your Plaintiff herein, Stephanie

DeVazier, was appointed as class representative by the Circuit Court of St.

Francis County following the death of Mrs. Stewmon, who was appointed as the

original class representative.

6. On July 25, 2014, the Caruth Defendants herein filed a case in the

United States District Court for the Eastern District of Arkansas on behalf of out-

of- state persons who had SEECO leases. That case is styled Connie Jean Smith

v. SEECO, DeSoto Gathering, Southwestern Energy Services Company and

Southwestern Energy Company, (Smith v. SEECO ). The class initially sought

to be certified in Smith v. SEECO specifically excluded citizens of the State of

Arkansas and by specific reference, excluded members of the Stewmon v.

SEECO et al . class.

7. As set forth above, on September 30, 2014, the Stewmon v. SEECO

et al class was certified by the Circuit Court of St. Francis County. At that time,

the Smith v. SEECO case in federal court had yet to even have the initial Rule 26

Scheduling Conference, (the beginning point of federal cases).

8. Following Class Certification in Stewmon v. SEECO et al the

Defendants (SEECO, DeSoto Gathering and Southwestern Midstream Services)

appealed the Class Certification to the Arkansas Supreme Court where the matter

remains pending.



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The Stewmon v. SEECO et al Class remains certified, Stephanie

DeVazier remains as class representative and attorneys Wilson, Easley and

Holton remain as class counsel, representing all members of the Stewmon

class.

9. On April 11, 2016 the United States District Court for the Eastern

District of Arkansas, Hon. Brian Miller, issued an order in Smith v. SEECO

certifying a class which includes members of the already certified Stewmon v.

SEECO et al class. The Smith v. SEECO class was certified more than 18

months after the certification of the Stewmon class. (As related above, the

Stewmon v. SEECO et al class remains certified and attorneys Wilson, Easley

and Holton are class counsel for all members of that certified class).

10. The Caruth Defendants submitted proposed notices to be sent to

members of the class certified in Smith v. SEECO by motion on May 11, 2016.

The SWN Defendants herein have responded to the Motion to Approve Notice as

submitted by the Caruth Defendants.

11. As related above, Stephanie DeVazier is the class representative for:

“All residents of the State of Arkansas who entered into leases with

Defendant SEECO (up through September 27, 2013) for the development andoperation of natural gas wells on property located in the State of Arkansas andwho signed leases allowing for deduction of reasonable costs for gathering,compression, treatment and marketing. Specifically excluded are any leases whichhave non-Arkansas residents as parties to the lease.”

12. “Class certification gives rise to an attorney -client relationship between



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potential class members and class counsel.” Gortat v. Capala Bros., Inc. , 2010 WL

1879922, at *2 (E.D.N.Y. 2010).

Pursuant to the class certification order which remains in full force and

effect, attorneys Wilson, Easley and Holton represent:

“All residents of the State of Arkansas who entered into leases withDefendant SEECO (up through September 27, 2013) for the development andoperation of natural gas wells on property located in the State of Arkansas andwho signed leases allowing for deduction of reasonable costs for gathering,compression, treatment and marketing. Specifically excluded are any leases whichhave non-Arkansas residents as parties to the lease.”

13. Stephanie DeVazier, as class representative, and Class Counsel,

Wilson, Easley and Holton, have “a duty to act as a fiduciary who must serve as

guardian of the rights of absent class members.” Ballard v. Martin , 349 Ark. 564,

575 (Ark. 2002) citing Grunin v. Int’l House of Pancakes , 513 F.2d 114, 121 (8 th

Cir. 1975).

14. Any communication issued in the Smith v. SEECO case which is sent

to potential class members would necessarily involve communication with

members of the Stewmon v. SEECO et al . class who have been and remain

represented by class counsel, attorneys Wilson, Easley and Holton, and who are

represented by Plaintiff Stephanie DeVazier as class representative.

15. Thus, any communication by the Defendant lawyers herein with:

“residents of the State of Arkansas who entered into leases with Defendant SEECO (up through September 27, 2013) for the development and operation of natural gas wells on property located in the State of Arkansas and who signed



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leases allowing for deduction of reasonable costs for gathering, compression,treatment and marketing. Specifically excluded are any leases which have non-Arkansas residents as parties to the lease”

would per se be a violation of ARCP 23, and Rules 4.2, and 7.3 of the

Rules of Professional Conduct.

16. Any contact by these Defendants with Plaintiff Devazier’s absent

class members would be detrimental to them and their causes of action because of

certain conduct of the Defendants herein which has created an absolute conflict of

interest between the Defendants and members of the Stewmon v. SEECO et al .

class and its representative, Plaintiff Devazier.

17. The conflict of interest between these Defendants on the one hand and

the members of the Stewmon v. SEECO et al . class and its representative,

Plaintiff Devazier, on the other is such that it cannot be remedied or papered over.

Further, the conduct of these Defendants as set forth in the subsequent

paragraphs in this complaint, constitutes intentional and fraudulent conduct

involving intentional misrepresentations of material facts, conspiracy and fraud as

it relates to your Plaintiff herein and the absent members of her class.

18. As set forth specifically hereinafter, these Defendants have entered into

an improper agreement which was materially adverse to the interests of the

Plaintiff herein and members of her class. As such, allowing any notice to issue

from these Defendants directly to the members of the Stewmon v. SEECO et al .



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class would directly harm the Plaintiff and members of her class.

“GLOBAL” MEDIATION AND CONFLICTS OF INTEREST

19. Roughly one month after Stewmon v. SEECO et al . was certified,

and as the Smith v. SEECO case was in its procedural infancy, the SWN

Defendants asked the Caruth Defendants to explore a possible global resolution to

all claims against SEECO from any and all SEECO royalty owners. To that end,

the SWN Defendants asked the Caruth Defendants to contact counsel in Snow v.

SEECO. (Snow is another class action case which was filed against SEECO only,

and includes only Arkansas residents. Snow was certified after Stewmon v.

SEECO et al . was certified and does not encompass all of the Stewmon v.

SEECO et al . defendants, nor does it include all of the valid and viable causes of

action included in Stewmon v. SEECO et al .)

At the behest of the SWN Defendants, the Caruth Defendants were

instructed to see if the Snow counsel were willing to explore a global resolution to

all claims against SEECO, nationwide. There was one specific and unmovable

requirement imposed by the SWN Defendants:

All parties to the global mediation talks had to agree not to advise or “tip

off ” the class counsel appointed in Stewmon v. SEECO et al . about the mediation

or efforts to achieve a global resolution to the SEECO litigation.



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20. Thereafter, all the Defendants herein agreed to exclude the class

counsel appointed in Stewmon v. SEECO et al . from any knowledge of these

secret negotiations. Shortly thereafter, the Defendants herein did travel to

California to engage in mediation to try and achieve a global settlement, all the

while maintaining their agreement to not tip off class counsel or the class

representative for the Stewmon v. SEECO et al . class to these negotiations

which, if successful, would directly impact the members of the Stewmon v.

SEECO et al . class.

21. By agreeing to hide these negotiations from the Stewmon v. SEECO et

al . class counsel and class representative, all while knowing that the Stewmon

class was already a certified class with appointed class counsel, the Caruth

Defendants and their client, Connie Jean Smith, colluded with the SWN

Defendants in a way which was materially adverse to the interests of the members

of the Stewmon v. SEECO et al . class which includes your Plaintiff and her

absent class members (all of whom now fall within the class definition in Smith v.

SEECO and who would receive any notice issu ed in Smith unless Plaintiff’s relief

is granted).

22. Shortly after the secret mediation, the entire scheme became public

during a hearing in front of Hon. Billy Roy Wilson to whom the Smith v. SEECO

case was originally assigned. At that hearing Paul Yetter, one of the SWN



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Defendants, sought to discover agreements between Smith’s counsel and counsel

representing Snow in the state court action.

Yetter argued: “If you have an agreement in which you're trading off some

-- your freedom to act zealously for your putative class in exchange for fees or

something with a third party in a different class, that agreement is not only

discoverable, it is something that the Court and the putative class needs to know

about .” (emphasis added).

23. Judge Wilson did not order production of any such agreements because

he was not inclined to certify a class in Smith v. SEECO at that time. However,

Judge Wilson added : “if there's something of the nature you're suggesting that I

find out, I'll ask about it at a later time, if I start to certify the class .”

24. Significantly, at the time of the above quoted argument, Defendant

Yetter and his co-counsel were making efforts to challenge the adequacy of

Smith’s counsel because of collusion between the Caruth Defendants herein and

counsel for Snow in the state case. Interestingly, all the concern about the

adequacy of the Caruth Defendants herein to represent the Smith v. SEECO class

members disappeared once the SWN Defendants herein had a class certified which

hijacked the state court class actions to what all the Defendants herein perceived as

a more favorable venue.

Indeed, the certification of the broader Smith class was the culmination of



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SEECO’s stated intention of rushing a nationwide class action through their chosen

forum in federal court so as to strip the Arkansas state courts of jurisdiction.

25. As a result of the collusion between all Defendants herein, the class

certified in Smith v. SEECO no longer has even the appearance of an adversary

proceeding, and all the prior concerns about the adequacy of the Caruth

Defendants as class counsel somehow vanished and are apparently forgotten.

26. This collusion has resulted in a breakdown of the adversarial system

wherein there was no chal lenge to the adequacy of Smith’s counsel, to Smith

individually, and no effort to uncover the conflicts of interest Smith and her

counsel have with absent members of the class Smith sought.

27. As a result, no challenge to adequacy was made even when SEECO

had first-hand knowledge that Smith’s counsel had colluded and conspired with

SEECO in certifying the broader class and in hiding the mediation aimed at

“global” resolution from duly appointed class counsel in Stewmon v. SEECO et

al . The SWN Defendants and the Caruth Defendants through their collusion have

acted in a way which is materially adverse to your Plaintiff herein, and the

members of the Stewmon v. SEECO et al . class who she has been appointed to

represent.



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PREVIOUS RULE 11 VIOLATIONFOR COLLUDING TO FORUM SHOP

IN DIFFERENT CLASS ACTION CASES

28. In this particular case, the collusion between the Defendants herein

has led to the appointment of class counsel who have acted adversely to the

members of the Stewmon v. SEECO et al . class members who are included in

their class.

Even more concerning however is the fact that two of the law firms

appointed to represent the Smith v. SEECO class have been involved in improper

class action conduct in a case which was pending in the Western District of

Arkansas. In fact, one of the Caruth Defendants herein who has been approved as

class counsel in Smith v. SEECO was found to have acted in bad faith and in

violation of Rule 11 for conduct in a class action which was pending in the

Western District of Arkansas.

The Caruth Defendants herein include attorneys with two out of state law

firms, the Mattingly & Roselius Law Firm and the Kessler, Topaz, Meltzer &

Check Law Firm. Members of these two law firms have been appointed as class

counsel in the Smith v. SEECO case.

29. Significantly, attorneys with those law firms were involved in a class

action which was filed in the United States District Court for the Western District



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of Arkansas, Adams v. United Services Automobile Association, et. al . 2:14 cv

02013, PKH.

Attorneys with those two law firms were found to have violated Rule 11 in

the Adams case, by “stipulating to dismissal for the improper purposes of seeking a

more favorable forum and avoiding an adverse decision.”

On April 14 th, 2016 Honorable P. K. Holmes, III, entered an Order in the

Adams case and held that the aforementioned conduct was not an isolated incident

and was not for the benefit of the class members: “Plaintiffs’ counsel have

embraced the practice of neg otiating lucrative attorneys’ fees from various

defendants using the threat of class action as leverage, as evidenced by their

willingness here to negotiate a settlement that primarily benefits Plaintiffs’ counsel

and [the Defendant] USAA.” Holmes’ Order specifically mentioned 5 other class

action cases involving these same lawyers where this process had occurred, and

further opined that the practice constitutes an “abuse of the judicial process.”

Significantly, Jason Roselius, a principal in the Mattingly Roselius Law

Firm, and one of the class counsel appointed to represent the Smith v SEECO class

members, was found to have personally acted in bad faith with regard to the Rule

11 violations found in the Adams class action matter.

30. The silence of the SWN Defendants herein as it relates to the adequacy

of class counsel in light of the Adams findings by Judge Holmes is especially



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telling. The SWN Defendants and Caruth Defendants herein have obviously

jettisoned even the appearance of an adversarial class certification relationship.

As a result of this collusion, the conflict of interests between the Caruth

Defendants and Plaintiff Devazier and her absent class members is obvious and

cannot be overlooked.

31. The Smith V. SEECO case has seen a similar abuse of process to

Adams in that Roselius and the other Caruth Defendants herein have colluded with

the SWN Defendants in efforts to make end-runs around the certified Stewmon v.

SEECO et al class by their covert attempts at a mediation which was strategically

hidden from Stewmon class counsel but was purportedly aimed at a “global”

resolution. Further, by agreeing to the certification of a broader class than

originally sought for the purpose of stripping the state courts of their jurisdiction,

all of your Defendants herein have also colluded for the improper purpose of

seeking a more favorable forum and avoiding an adverse decision.

32. Any appearance of an adversarial proceeding in Smith v. SEECO has

vanished with SEECO’s counsel’s failure to challenge in any way the adequacy of

the flawed counsel appointed to serve as class counsel in Smith, which amounts to

tacit agreement with their appointment, or at a bare minimum complacency. In the

face of SEECO’s counsel’s first -hand knowledge of the Caruth Defendants’

conflict of interest, and in their failure to inquire as to the Rule 11 violations which



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are detailed herein, SEECO has abandoned an adversarial position for their stated

intention of rushing through a broader class action in federal court.

33. Connie Jean Smith, the appointed class representative in Smith v.

SEECO , has similarly failed to carry out her fiduciary duties to all class members

by failing to question the ability of her counsel to act in the best interests of her

absent class members.

34. A failure to provide the Plaintiff the requested relief would subject her

absent class members, whom she is charged with vigorously and tenaciously

protecting, to communications which would materially mislead those absent class

members about the nature of Smith v. SEECO , about the material conflicts posed

by the inadequate class counsel and class representative appointed therein, and

would wholly omit an honest description of the collusion and conspiring which has

occurred between your Defendants herein to date.

Without full disclosure of the collusion, conflicts of interest and disciplinary

history of class counsel, no absent class member could make an intelligent decision

with regard to this class action, and as such, they would be denied their due process

rights which are supposed to be protected and safeguarded by the Court, Berger v.

Compaq Computer, 257 F3d 475, 480 (5 th Cir. 2001).



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THE PROPOSED NOTICE IN SMITH V. SEECO

35. The collusion between the Caruth Defendants and the SWN

Defendants shows itself once again in the proposed class notice which has been

filed by Smith’s counsel. To begin, the brief mention of Stewmon v. SEECO et

al which is included in the proposed notice would leave the absent class member to

believe that to opt-out of Smith so as to proceed in the previously certified

Stewmon state court action would expose them to higher legal fees and/or expert

witness fees, which is completely false. Any attorney fees in Stewmon v.

SEECO et al would be subject to award and approval by the Circuit Court of St.

Francis County. Also, the proposed notice makes no mention of the conflict

between the Defendants herein and the Plaintiff and members of her class which

was created when these Defendants agreed to secret negotiations which they kept

secret from the class counsel and class representative of the Stewmon v. SEECO

et al class.

36. The collusion between the Caruth Defendants and the SWN Defendants

continues by agreeing to certify the broader class in an attempt to hijack or usurp

the Arkansas state court’s jurisdiction, and by conspiring to communicate directly

with your Plaintiff herein and her class members instead of through their court

appointed counsel. The proposed notice also sets a shortened time frame of 45

days for individuals to opt out of the class, instead of the recommended time frame



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of 90 days.

37. The proposed notice includes no mention of the previously described

Rule 11 violations which were committed by Class Counsel.

38. Lastly, the proposed notice creates unnecessary burdens to opting out

of Smith v. SEECO , which appears rooted in the Defendants common goal of

rushing this litigation through in federal court in order to strip the Arkansas state

courts of their jurisdiction, with absolutely no regard to the consequences for the

absent class members.

Specifically, the notice requires that absent class members who wish to opt-

out or exclude their claim from Smith v. SEECO provide the property

name/property number for any well which they wish to exclude. The property

name/property numbers are not easily ascertained by absent class members as this

may entail reviewing numerous documents to determine the specific well name and

property number which has been assigned in the SEECO owner system. By

making this a requirement for opting out of the Smith v. SEECO class, it creates

an undue burden on absent class members which is unnecessary and not designed

to further any legitimate objective in terms of the Smith v. SEECO class action.

39. If the notice were allowed to be disseminated to the absent Stewmon

v. SEECO et al class members (who are represented by Stewmon class counsel

and whom Devazier was appointed to protect) without the consent of their counsel



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who were appointed in Stewmon , not only would it violate that attorney-client

relationship, it would act to give the absent class members biased and incorrect

information about their rights. It would fail to fully and completely apprise them

of the problems with the Caruth Defendants who are appointed as Smith’s class

counsel including the Rule 11 violations. It would also fail to inform them of the

direct conflict of interest the Caruth Defendants have as it relates to the absent

Stewmon class members whose appointed class counsel and class representatives

were specifically excluded from the secret global settlement negotiations.

40. As such, the Notice which the Defendants intend to send directly to

your Plaintiff and her putative class members constitutes a fraudulent

misrepresentation because of the material omissions, inaccuracies and counsel’s

improper behavior to the Stewmon class members which are detailed in this

Amended Complaint for Injunction.

41. If Plaintiff’s relief is not granted and Defendants are allowed to have

harmful and biased communications with your Plaintiff and the members of her

certified class whom they conspired and colluded against, such communications

would improperly bypass Devazier and duly appointed class counsel completely,

and have the effect of nullifying her appointed position, and violating the duties

entrusted to her, and so would also injure her personally, as well as in her

representative capacity.



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42. Plaintiff has no adequate remedy at law. Time is of the essence for

this Court to enjoin the Defendant Lawyers herein from committing acts which (A)

violate Rules 4.2 and 7.3 of the Arkansas Rules of Professional Conduct, and

ARCP 23 (B) are not in the best interests of the class of Arkansas royalty owners

certified by the late Judge Simes and (C) are harmful to Devazier and the absent

class members of the Stewmon class whom the Defendants conspired and colluded

against.

WHEREFORE, PREMISES CONSIDERED , Plaintiff prays that this

Court issue an initial Temporary Injunction and thereafter a Permanent Injunction

as follows:

Defendants BEN H. CARUTH, JASON E. ROSELIUS, BRAD E.

SEIDEL, EDWARD ALLEN GORDON, TANNER W. HICKS, ERIK P.

DANIELSON, SEAN M. HANDLER, BRIAN L. CRAMER, JACK A.

MATTINGLY, JR., ANDREW KING, FREDERICK HART DAVIS, JESS

L. ASKEW, III, MICHAEL VANCE POWELL, MARC TABOLSKY,

ROBERT K. ELLIS, MATTHEW K. HANSEN, REX M. TERRY, R. PAUL

YETTER, AND THOMAS A. DAILEY and their agents, and/or employees, be

restrained and enjoined from communicating directly with:

residents of the State of Arkansas who entered into leases with Defendant SEECO (up through September 27, 2013) for the development and operation of



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natural gas wells on property located in the State of Arkansas and who signedleases allowing for deduction of reasonable costs for gathering, compression,treatment and marketing. Specifically excluded are any leases which have non-Arkansas residents as parties to the lease.

Plaintiff further prays that any communication involving any of the

aforementioned class of persons be sent only to their duly appointed class counsel,

E. Dion Wilson, B. Michael Easley and Timothy R. Holton, or in the alternative,

with the express consent of their appointed counsel.

Lastly, Plaintiff prays for all other relief, both general and specific to which

Plaintiff and her class are entitled to under the facts set forth herein above.

Respectfully Submitted,

THE HOLTON LAW FIRM, PLLC.

/s/Timothy R. HoltonTimothy R. Holton (2001101)John R. Holton (2009056)296 Washington Ave.Memphis, TN 38103(901)[email protected] [email protected]

EASLEY & HOUSEAL, PLLC B. Michael Easley (74041)P.O. Box 1115Forrest City, AR 72336


mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]


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WILSON LAW FIRM, PA.E. Dion Wilson (94014)423 Rightor StreetHelena, Ar. 72342870-338-6487



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CERTIFICATE OF SERVICE I do hereby certify that I have served a true and exact copy of the foregoingdocument via the Electronic Case Filing system on this 31 st day of May, 2016.

/s/Timothy R. Holton


52- First Amended Complaint

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Transcript of 52- First Amended Complaint