My name is Dwight Mitchell. I live at 323 Park Road 4-5 Madison, TN 37115. I was born in Hartsville, TN 12/22/1962. I attended High School in Hartsville, TN and graduated in 1981 and went to work for the Beene at Beene’s Nursing Home. They helped send me to College at Vol State Community College from the time of 1982 to 1984. I then went to Tennessee State University from 1984-1988. I went into Health Care Administration and Planning. I got my degree in 1988 in Health Care Administration and Planning. I also got a diploma from MeHarry Medical College in Health Care Administration and Management. I then went in May of 1988 to the US Army Academy of Science in the Army Reserve where I got my diploma in medical specialists in November of 1988.
In 1989, I rented the house at 700 McMurry Highway 25 from the Beene. My aunt, Hattie McDonald, had a residential home for the aged there at the time. I rented out from Fred and Wilma Beene for a year. I came back the next year and bought the place from Fred and Wilma Beene. On February 2nd, 1990, I bought the place from Fred and Wilma Beene under the US Department of Housing and Urban Development. That would be a HUD program.in that program Fred and Wilma Beene asked for $75,000. It was $76,434.84 and they gave me a down payment of $6,330. I applied this to the loan. The loan was with the Bank of Hartsville and Mr. C.K. Smith was the lawyer at that time that wrote up the loan and also did the title search.in the warranty deed of this loan, it is stated that tract 1 is 6.7 acres, tract 2 is 7.4 acres. At this time, we were told that we had around 14 acres.
We were not given any surveys or plats at that time. The only thing I ever received was from May of 1966 plat that stated 14 acres. I believe I found it somewhere in the courthouse. It showed 14.6 acres. The reason that I went to the courthouse and looked that up was I went in contract with a Harry Senter who was a gentleman who raised me from childhood. He had farm equipment. We came to this agreement in March 22nd, 1989.in 1990-1991 his tractor was burned when we were at my house. His tractor was burned and his dog was killed. Mr. Senter was always stating that I had more acreage because when he would plow the fields the squares of the acreage didn’t add up. Mr. Senter was also later murdered and the person that murdered him still hasn’t come to justice.
In July of 1990, we also borrowed $2,961.12 from the Bank of Hartsville and trustee James H. Crabtree in Book 43 or 45 on page 292-294. And also made loans from them in 1992-1994 with Community First Bank and Trousdale Bank and Trust. Dale Dies was the president of these banks. No plats and surveys were shown to me by the Bank of Hartsville, Community First Bank, or Trousdale Bank and Trust from 1990-1994. This is very important because the one that was done in 1990 by the Bank of Hartsville for the $2,961 shows tract 1 as 6.7 and tract 2 as 7.48 and that is what was stated in the first deed of trust that we received. It is a variation of the descriptions that were done later.
From February 2nd, 1990 until the end of 1994 I was paying Mr. Fred Beene back the $6,000 for the down payment on the $75,000 loan. I eventually paid it off. My wife and I, which was Regina Mitchell, were dating at the time and came down to Madison and paid Mr. Beene off the balance of that money. At that time, he should have had a lien against something for the $6,000.
On May 23rd, 1994, My ex-wife, Rachel Mitchell, signed over all the property of tract 1 and tract 2,6.7 and 7.48 to me, Dwight Mitchell, and this was put in deed book 47, page 11-13. It was registered by Ms. Pam West. The registered date was May 23rd, 1994. On the 7th of February, 1994, the Honorable Charles C.K. Smith, presided over a divorce decree. It was put in book C, page 381-389 and it was dated on the 4th day of February, 1994.in this marital dissolution agreement, on the 16th of December 1993, in number 3 of that, it states that the Defendant shall be awarded the parties’ house and 17 acres of land located on 700 Highway 25 East in Trousdale County, Tennessee.in that also after you get down to number 8 it also shows that I was indebted to Mr. Fred and Wilma Beene for the $6,000 that I borrowed for the down payment but when you get to number 9, it is not there. It skips over to number 10. There is a whole page that is missing in my divorce decree. I feel that that page shows that the pieces of the property that I had and the structure of the property and the boundaries of the property that would show more than 14 acres.
At the end of 1994, I went to Trousdale Bank which was Bank of Hartsville to set up a loan to build on to the retirement home. Trousdale Bank stated that they could not do it so I went to Citizens Bank. They stated that they would be interested in it. At the same time, I was working with Citizens Bank in Nashville setting up a SBA loan. I used a loan with the Citizens Bank in Hartsville of $185,000 to build the adjacent part of the retirement home which ended up being over 6,000 square feet. At that time, I went over the budget. The contractor came to me and told me that I was over the budget and that I needed to pay him. I went to Wilson Taylor who was the bank president and told him that I was over and he told me that he couldn’t give me any more money. I left the bank at that time and got back a response with the contractor and told him that I had a SBA loan with Citizens Bank in Nashville. He got with the president, Mr. Wilson Taylor. Mr. Wilson Taylor called me back into the office asking me why don’t I take my SBA loan and use it there in Hartsville. With the situation I was under, not getting any more money, I felt like I had no choice and I brought the SBA loan from Nashville to Hartsville.
Mr. Wilson Taylor applied for the loan but the problem we have with the loan is that we didn’t know at that time because they only gave us 3 pages to look at and the 4th page to sign we didn’t see the whole package until 9/30/09 when we were in bankruptcy. February 21,1995, we received $200,000, the amount the property was worth probably under the loan number SBA GP. 784826-30-06-nash. It shows as a request in November 1994, Citizens Bank president, Mr. Wilson Taylor, stated that they wanted to take 700 Highway East Main Street that would be the junction between highway 25 and the street of East Main so it would be on that side in Hartsville, but when we looked at the attachment of the description, it shows another piece of property that is deed book A1P471, the plats I did not see until 2009. No plats or surveys were titled or insurance was shown in February of 1995.
The plats were changed without my knowledge in 1995 and this will be very important when we get to 2009 because it will show we just found out about the title insurance and everything in 2009.
I could not have had any knowledge of the 5 acres in 1994 because Jackie Dillehay did not do the survey until February 5th, 1995. This tract of 5 acres did not exist to my knowledge in November 1994 so there is no way Mr. Wilson Taylor could have known of the 5 acres in 1994 when he asked for the loan. We didn't transfer or even give the OK to separate the 6.7 acres.
The other problem that we see with the SBA loan for $200,000 was also that at the end of the attachment, it states that this is a part of the property which was conveyed to Dwight Mitchell and wife, Rachel Mitchell, by Fred Beene and wife, Wilma Beene by deed dated February 2nd, 1990 recorded February 5th, 1990 at 1:30 in deed book 34 page 169, Registrar’s office of Trousdale County and a part of the property which Rachel conveyed to Dwight Mitchell by deed dated May 23rd, 1994 recorded May 26th, 1994 in deed book 47, page 11, Registrar’s Office of Trousdale County. The only problem with that is when you look at the structure of the attachment in book A-1 page 471, in none of the deeds that the Beene gave me or the deeds that my ex-wife Rachel signed over to me had deed book A-1 page 471 in it. The only one that has that book is the trade school and that is an issue that will be brought up later when we get to 2010. The problem is that there is no way that this piece of property could be there unless it is more property that should have been given to me at the first deed book in February 2nd, 1990.
Also in the structure agreement where we signed on February 21st, 1995, was given to me by Citizens Bank. It was a piece where we signed at that was a problem for me. It says at the bottom where I signed at Notice to the Borrower: do not sign this agreement before you read it. Then it says you are entitled to a copy of this agreement. What this is bringing to me is that something that is in this agreement that should not be in it and we didn’t get a chance to read it because we didn’t get a structure of the whole loan at that time. At that time we was only given a page and told sign here, sign here and we’ll take care of the rest by Mr. Wilson Taylor. Some of the stuff could have been put in later, we don’t know. But what we have problem with is that this is the only one that it has this notice to the borrower. All the other loans don’t have it.
Next was loan number GP-952156-30-10-NASH. On August 29th, 1996, Wilson Taylor presented only 3 pages for us to look at and the 4th page to sign for 700 McMurry Blvd, Hartsville, for collateral that we didn’t see. It was asked for approximately 14 acres. We feel that this was over-collateralizing.in 1995, we received a loan for $200,000 and only put up 5 acres and the only percentage we had to come up with was 25%.in 1996, we only had to come up with 20% of $50,000 was only $10,000. We thought that he was going to take it against the 5 acres that was on the East Main side and put it towards that. We later found out when we went into ban bankruptcy that he put the whole 14 acres up. We feel that this was over-collateralizing. We base this on the letter of October 31st, 1996 to Mr. Wilson Taylor, Bank President, from Dennis R. Gardinson, Chief Economic Development, which states in the letter that he is complying to Mr. Wilson Taylor’s letter on October 8th, 1996 with them wanting to delete the 14.6 acres and substitute it with the 5.01 acres. I did not know about this letter until but the Deed Book 78P124-130 shows all of the property and Deed Book 82P395-402 shows all of the property. We were under the impression that this amount of property would not be encumbered. We also have an issue with the correction of deed that was done on August 1st, 1997. We feel that the deeds for August 1st, 1997, were fraudulently done. Reason being, during that time they were in the process of trying to find a place for the high school in 1996-97. They would have found a place to put the high school.
I was approached by people from Hartsville that wanted to buy the place but I didn’t want to sell, so what happened after that, the State of Tennessee came against my license and closed me down. During this time, we received our license back at a hearing. Citizens Bank would not give me any funding or any loans to get the business back up. The reason why I know I wouldn’t have signed it at that time, our relationship with Citizens Bank was strained because we couldn’t get any funding so I don’t think I would have signed a collateral agreement in 97 when we were still out of business and trying to get them to get me some money. We also were using 401-Ks that my wife and I had. I also had to get a high interest loan with Bill Jones for $12,000 and it ended up over $20,000. I also had to go to Trousdale Bank and borrow $13,000 so there is no way that I would have come in and signed a collateral agreement at that time because Citizens Bank and our relationship was very strained at that time.
I also had to start a concrete business and that is how we were paying the Citizens Bank notes with no resident’s in the facility. We started receiving some relief from the Bank and the State after the city of Hartsville found a place to put the high school. We also met with the superintendent at that time, Mr. Linville, and also with the Honorable Joe Bell, and they were inquiring about this issue of the property.
I would also like to note that from 1989-1996 we were receiving funding from a pilot program with the Department of Health and Environment and it’s called the Enabling Program. After we restored our business in 1997, this funding was no longer available to Sun Valley making it where my Aunt, Ms. Hattie McDonald, was the only home for the aged that was receiving this funding in Hartsville. Without us getting this funding, Citizens Bank or the State had to get a high interest rate loans as I stated before from Bill Jones. We went on from 97-02 working in concrete to get the business back up which we did.in we made a request for an SBA loan because we got audited by the IRS. We had a lady there in Hartsville that was doing our taxes. We feel that the taxes were done wrong. We ended up having to pay the IRS $20,000 so that was why we went to SBA and Citizens Bank to try to get a restructure of all our loans.
In the restructuring of the loans, I requested all of my loans to be combined with a fixed rate. I had a meeting at that time with Tommy Thompson, who was the District Attorney, who I didn’t know was a board member at that time. He stated to me that I had to be selling drugs to keep the notes paid. I also met with Mr. Phillip Holder, a board member, who stated to me that he objected to the loan although the rest of the board members said yes and I should have been glad that I’m getting the loan. At that time, I had no choice; I had to pay the IRS so I had to get a loan with them. You can say it was like intimidation. I had a witness with me at both meetings—my dad, Mr. William C. Mitchell. I had to hurry up and pay the IRS. The lady that I stated did our taxes and the way it was structured wrong, I later found out that she also wanted to buy the place. The bank stated, through Mr. Wilson Taylor, that they would only take 1 acre for the whole $85,000, but in the SBA loan paperwork they stated that 8 commercial acres, which we had never been told that we had 8 commercial acres, the bank split our loans of $85,000 against our will. $63,000 was a loan was by SBA and then the $22,000 Citizens Bank held. It should have been for the 1 acre but they took and encumbered all the property at that time without our knowledge. We later found out that in 2007 or when I requested the SBA paperwork, that they encumbered more land than they told SBA they had and what happened with all three of the loans, the property had been switched in each loan.
In this loan request, I requested to pay Bill Jones back the $20,000 that had 20% interest which is an issue in itself. Mr. Bud Blackwell did some work on the place which was a legitimate loan of $10,000 and we paid him $9,000 back. Trousdale Bank and Trust which we borrowed $13,000 and we were looking to pay $9,000 back and the one that didn’t get paid, my wife Regina which was $10,000.
In I received a called from Judge Linville. I met him at his office at the courthouse. I was approached by Judge Linville regarding selling my property. He offered $400,000. I declined. He stated that if I don’t have a business, I just have raw property. Later that day after the meeting, I found out they were looking for a piece of property for Hartsville General Hospital and also that they wanted to put up some stores in that area. Later, in 05, exactly as they said, the State came out to survey me and one of the surveyors, Mr. Wiggins, who was a surveyor from the State of Tennessee stated to me that he was accompanied by Mrs. McDonald. Mr. Wiggins told me that he would have to meet with some of the people in the city of Hartsville to see what was going to be done about my business. I thought it was very strange that a surveyor from the Department of Health would have to come and meet with people in Hartsville to see what they were going to do about my own business.
At that time, I was accused by complaints that ranged from not feeding people to rape.in that same time, I was approached by the same gentlemen who wouldn’t give me his business card or anything stated that he had some people from Gallatin hospital looking for a place to put a hospital and that they would have to get anywhere from about a million dollars. The gentleman laughed and walked off. I never got his name, number, or anything but it was a gentleman that came to me before about selling that piece of property.
During that time in I went to a hearing regarding my license. During that hearing we showed that it was false about our mission of discharged status that our records were kept up. We also showed where Mrs. James stated that we had insufficient staff; we showed that we had people there. We also showed the attendants during the evening hours. We showed that we had someone there at night. We showed also that we had a service coming in for pest control. We also showed that we had food. As for the allegation that we didn’t have 48 hours worth of food—the surveyor took a picture of a freezer, which was an old freezer, showing that it was empty but did not show the freezer that had food filled half way. We proved that this allegation was false. We also showed that the allegation regarding them saying we were not giving the residents their medicine was false. We proved the medications were given. We also showed that the physician’s reports were done. We also showed in the survey that Mr. Wiggins was also stated that he had to come to Hartsville and sit down and talk with the people of Hartsville about my property.
We also showed that Hartsville Hospital illegally took records from our facility, kept them for 2 months. We also showed that the police department put up yellow tape and kept it up for months in our place and wouldn’t take it down and told us that we couldn’t take it down and making trouble for our business. We also showed in that same document in volume 1 where a judge told me that they wanted to buy my property and that if I didn’t have an existing business then I would just have raw property. We also showed that the allegations of me selling drugs were written up. We also showed that the State had allegations that we raped a patient in the place in 2005. We also showed on August 24 that they came out again to survey us. September 10 they came out to survey us. October 18 they came out to survey us. October 22 they came out to survey us. December 29 they came out to survey us. February 28 they came out to survey us. February 28 again, and then June 13. When they usually just come out once a year. They came out one, two, three, four, five, six, seven times. We feel that this was an effort of intimidation to make us close the place down. At the end of the trial when they saw all the things that had been done, they pulled me to the side and asked me to come outside. My wife, Bishop murry was there and asked me to plead with a deal to go under a probation period. I agreed with that. The reason why I agreed was because in 1996, they made allegations that I had residents that were under 55 years of age and now I am realizing that that was against the 14th Amendment but we tried to apply to it. They also said that we had 18 residents. At that time we had already put in a request for more beds and we were under the impression that they were already going to come out and survey us at that time and give us the beds. As a matter of fact at that time my Aunt Hattie was giving me residents to fill the place up so that helped us out from April of 96 to August of 97 but we lost all the residents and I didn’t want that to happen again even though we won the case and opened it back up again.
We also went into an agreement with them and agreed to probation and did everything we agreed to do, probation was lifted in that year.in 06, I was at full capacity. We had 15 clients. I went to Citizens Bank and sat down and talked to Ms. Betty Hibdon and came up with a plan to renovate the business, to get funding through renovating the business through Medicare/Medicaid waiver program to get funding for more employees to come in with help for the clients. This Medicare waiver program would be setup where we could get homecare for my residents; we could also get housing allowance. It would provide respite care, personal care service, and home care service. I presented the plan to Citizens Bank, they turned it down, and didn’t give me any information why they turned it down they just said they turned it down. I still have the package to show that the package was the same kind of package I did all my SBA loans with. This was in 2006 when they turned it down and we were current in our payments and had everything taken care of and the bank still turned it down without taking it to SBA.
In July, the 17th or 18th I had a resident named Ms. Vaughn who I took to Dr. Lightford for care.in that time, Dr. Lightford told me to wash her foot with Clorox and water 20-30% and either 70-80% water. We washed her foot on the 18th, 19th, 20th of July. A nurse from Guardian Home Healthcare came to check Ms. Vaughn’s foot. I believe it was Terry Harvey, RN. She stated in the paperwork with the State that she came, checked the foot, was going to get back in touch with Dr. Lightford about the care, but she never did get in touch with them so they didn’t have doctor’s orders for wound care on the 20th. On the 23rd, guarding home health came back out again, still with no wound care statement or order from the doctor. On Wednesday the 25th, they came back out. We were still washing her food with Clorox and water and the social worker came out. I made the emphasis to the social worker and the RN that the resident was not getting proper wound care. We had a gentleman there before and he was getting his foot soaked. After he got his foot soaked they would use BETADINE and a solution to soak his foot and then they would turn around and wash it with a solution that was a cleanser like Clorox. I stated to them that I had trouble before and I didn’t want any more trouble and that the care they were giving was not proper.
This was on Wednesday, the 25th, on Wednesday, the 27th a nurse came out. This nurse has never been seen in court or has never been documented or been at the court hearings on the 27th. That nurse didn’t bring any supplies or bring anything for the patient’s wound care on that date. We were still washing her foot with Clorox and water, we’d put some in when we’d bathe her. On the 30th is when the issue came up. A “Ms. Gibson” came to see Ms. Vaughn. What Ms. Gibson did not know was that my mother was doing care for her foot. On the 27th, I was there, we washed her foot that morning. Saturday my mother washed her foot. Sunday, we know that the foot was washed because most Sunday’s Ms. Vaughn goes to the church or the church members would come out to see her, so we made sure that she was cleansed and taken care of that day and the wound had been properly taken care of. On the 30th when Ms. Gibson came, she didn’t realize that my mother had already washed Ms. Vaughn’s foot. At that time, Mr. James Murray was also there. Ms. Gibson comes in and stated in her deposition that she came in and asked for someone that works there, my mother came; she showed where the room of Ms. Vaughn was. She also stated that she found maggots in the foot. She had been there approximately 10-15-20 minutes, there is no way maggots could have grew at that time that quickly and what we’re saying is, if her foot was being washed by bleach and water from the 18th-30th, there is no way maggots could occur. How we know that is because the doctor, Dr. Samson, states in his notes that he washed her foot with bleach also and the same thing that doctor did, we did. We feel that these maggots were placed in the foot to damage Sun Valley. At the present date we have a lawsuit against Guardian Home Health. The thing we’re saying is that this was a planned situation to immediately put us out of business.
After this occurred, the state came out on August 2nd, did a survey, found nothing that was wrong, went back. We received a letter in August 13, we were told in the letter that we could stay open and on August 13th we received another letter that we were under suspension from admitting any new residents, but we could remain open. On August 14th, Mr. Jerry Blasingame, he was a very rude man, he was from the % the came from the facility and stated that he was closing the place down. I asked him what right he had to do that and I wanted to talk to my lawyer. What I didn’t know was that on August 15th, Ms. Gibson and Ms. Terry Harvey, Ms. Mullins, were at a secret hearing with the State of Tennessee and I have the transcripts of the proceedings, it was a trial for suspension of a license and closing down for an emergency.
On Wednesday August 15, Trousdale County Sheriff’s Department accompanied by the Tennessee Department of Health and the Ombudsman, Blasingame, served a warrant to surrender our license. We did not agree because we felt that this warrant was unmerited. We later found out this warrant was served illegally. Mr. Jerry Blasingame had no right to be in the facility. We also found out later that who District Attorney Tommy Thompson helped move some of the resident’s things out of the place and that was illegal and he was the one who served the warrant. We found in the September 29 that these maggots were placed in the resident’s foot by Guardian Home Health and its representative Ms. Gibson.
We feel that number one, they didn’t have a right to be in the facility, number two, they didn’t have a right to move anyone, and they didn’t have a right to take all the records and make copies. They illegally violated the 14th amendment of Sun Valley, Dwight Mitchell, and the residents. Sun Valley was not given due process in August 15 because of the suspension. Sun Valley was not given a speedy trial because the business was closed down on August 15th, had trial in August, Judge stopped the trial, did not convene until November 14. Board members would not come back, had the next trial in September. Accuser, Ms. Gibson, could not be found that was in September and she could not be found. September 24, I filed a petition for appeal of the administrative order that was entered September 10. This appeal has to this date not been heard.By December I had been out of business for 5 months with no appeal process and at that time Alternative Health Care, Inc., Inc. Came by with a contract for renting out the place and renting to own. Mickey Riggirio, his sister and Mick Riggirio allowed Alternative Health Care, Inc., Inc. To come with a contract in January. He wanted to lease then purchase the facility for $460,000. He gave us a $40,000 deposit which enabled us to catch up with the notes with Citizens Bank. Before this with Mickey Riggirio, Mr. Bill Jones wanted me to sign a contract with Mr. Stanley to have a 30 day contract on the property. He also stated that Ms. Lily Massey wanted to buy my property and her maiden name was Oldham, a family that owned a lot of property in Hartsville. Mr. Riggirio owed me $4,000 with Alternative Health Care, Inc., Inc. And did not make another payment after the down payment. Mr. Riggirio and I went to Citizens Bank and he told me that he would get a loan from Citizens Bank to pay me off but when he went to the bank he didn’t get the money to pay me off. Mr. Riggirio had a meeting with me and stated that he was not going to pay me and wanted me to sign some plats. This was around April 17. I still have those plats. They are a final subdivision. I feel that this was used to develop the property so it could enhance the amount of money that he could have got off the property. I knew that Mr. Riggirio could not get me to sign the paper to hold the rent that he had for my land. Mr. Riggirio stated to me that if I didn’t lower the price, that he would turn me back over to Hartsville and that they would take the property.
This was around April 17.2008.in July, the bank stated that they were going to foreclose. I then met with Mr. Ed Kendall’s office where I met Marjorie Kendall. At this time, Alternative Health Care, Inc., Inc. Owed me about $24,000. On August 18, Alternative Health Care, Inc. Made a check to Mr. Kendall. I had not received any money from Alternative Health Care, Inc. Since January. On August 19, Alternative Health Care, Inc. Wanted to meet with me at Mr. Ed Kendall’s office to do an addendum to the contract.in the addendum he wanted me not to be able to file bankruptcy. I knew that this was illegal and the contract would be voided. On September 29, Mr. Riggirio wrote a check to Citizens Bank for $2,416.36. On September 29, he wrote another check for $1,583.64 for me to receive my money. Mr. Riggirio made me sign a final subdivision plat for Dwight Mitchell on 8/20. The money was held by Marjorie Kendall and Citizens Bank tried to set up an agreement with Marjorie Kendall for payments. March 23, Mr. Riggirio was still 4 months behind on his payments. On 12/29, I was put into bankruptcy because of the non-payments of Mr. Riggirio. I was in chapter 13 and represented by Mr. Kendall from 12/29 to 2/12.
LLC executive director was trying to buy the place. They wanted to pay for the property for $505,000. The company was scared off by Alternative Health Care, Inc. That was in the place. I went back into bankruptcy on 4/30 with Kevin Key in Chapter 13. Mr. Kevin Key brought Alternative Health Care, Inc.in about the contract. Mr. Riggirio stated that he had a silent partner. It is my opinion that Citizens Bank could have been one of his silent partners. Mr. Riggirio was being represented by Mr. Larry Edmonson who is a trustee of the courts. Mr. Edmonson then became the lawyer of Citizens Bank and was in chapter 13,4/30 to 8/14 with Mr. Kevin Key on 9/6, filed chapter 11 and 10/9 met with the meeting of creditors, asked the courts and my attorney to make Citizens Bank show that they were a creditor. This was never done at the meeting of the creditors. On 10/29, Mr. Edmondson which was Alternative Health Care, Inc.’s lawyer, Mickey Riggirio, stayed in the chapter that Mr. Kevin gave from 9/6 to 3/16. On 2/4, Citizens Bank of Hartsville filed a witness list of creditors by Mr. Thomas Edmonson but from 12/29 to 2/10, none of my attorney’s made a witness list or put any evidence in the courts. Some of the evidence that was not put in the courts was in SBA exhibit number 9 that I showed from Ms. Beverly Smith that I received from her 10/17.in it, it shows that the bank showed 8 acres that they were going to put for commercial acres, but it also shows that they were only supposed to use one acre. It also shows that they weren’t supposed to subdivide it; they were only supposed to put the whole 85 into one note. At the time of the loan in none of this was revealed to me. We were only given the back page to sign and probably one page after that. It was all we were shown, we were not shown the whole package. We never knew about the loan until 10/17.
Other evidence that was not put in was in my US bankruptcy case number 309-10241, the loan that was number 99944060 I never knew what part of the tracts he was going after. He always told me he was going on the East Main side and how I can prove that in the claims is that the motion the bank filed on September 30, it states on page 6 Citizens Bank, Wilson Taylor, your request dated November 4,1994 for SBA guarantees 75% of a loan in the amount of $200,000 to be made by lender to Dwight J. Mitchell doing business as Sun Valley home for the aged. 700 Highway 25, East Main, Hartsville. 37074 is hereby approved by the 7A. When you go back to the last page it talks about 700 McMurry. Those are two different pieces of plots. Under the collateral, this deed says the first deed of trust on SBA form 930 on the real estate property located at 700 Highway 25 East Main Street, Hartsville. The other evidence that was not put in was on the title of the other provision on this file. It states that title interest satisfactory to the lender is required as to all real estate pledges to secure the loan and any guarantee thereof and lender shall be in receipt of writing verification. Lien holder if any specified in this authorization. Title insurance or plats were never shown. This is what made me start investigating what was title insurance.in that same bankruptcy 309BK10241, Citizens Bank also showed an account number 99944062 on the 3rd page of 33, it states that the note was $682 and should have been paid off in 10 years. The note was stated November 26,1996, which meant that this loan should have been paid off November 26. They are still saying that I owe money on that and they got it at like $375,000.
On collateral they were going after the 14 acres which was never shown to me. It was shown that the 5 acres could hold that. What happened was that they were saying they were going to for? $50,000 take the whole 14 acres. We feel that after investigating we feel that loan 99944062 was number one: over-collateralized, and number two: information that would have changed the loan, was hid from us. Some letters that Mr. Wilson Taylor wrote to SBA was never given to us. We never saw those letters showing that it was a situation that even SBA felt there was more property and the letters was never shown.
Also, it states in the letter to look at 2C which is collateral. Wilson Taylor, president of Citizens Bank wrote that he wanted to take the house and approximately 14 acres for $50,000, but in the first of the letter he wrote to SBA he didn’t state anything about the house and 14 acres; we feel that this was done deliberately to collateralize all the property. When we signed the note, we only had before us, about 3 or 4 papers, and when we signed them, they didn’t have anything on them about collateral. Another problem with this loan for $50,000 is that it states in 4 other provisions that title insurance satisfactory to the lender is required as to a real estate pledge to secure the loan and any guarantee thereof and lender shall be in receipt of written verification from each prior lien holders, if any, that it’s balance does not exceed the amount specified in this authorization. The problem with this loan is that the title insurance would not cover this loan.in the title insurance which was given to me on November 16, and the policy was done in 1995,1996, and which I knew nothing of, but in those title insurance that was given to me in November 18, and the bankruptcy papers that Citizens Bank filed on 9/30/09, so they knew of this, and never told me anything about it or never showed anybody during this time. The first loan that was done by Stewart Title company back in February 21,1995 for the $200,000 loan that would be loan 60, it states in the schedule B part 1 this policy does not insure against loss or damages by reasons of the following: Rights or claims of parties in possession not shown by public records, conflict in boundary lines, encroachment, easement, variations in areas or content, party walls, and or and facts that are correct, surveys or a physical inspection of the premises disclosed. It also states that the easement or the rights of ways receipted in book V page 520.in that book, that is property that was deeded to the State of Tennessee and there is something wrong with that deed. I researched and we’ll talk about that later.
In the second title insurance, for the $50,000, this would be account number 62 schedule B part 1. This policy does not insure against loss or damages by reason of the following: disappearance conflicts in boundary lines, encroachment, easement, variations in areas, or content, party walls, or any facts that a correct survey or physical inspection of premises would disclose. Deed of trust held by Citizens Bank in the original amount of $200,000 of record in book 67, page 124. This is very important. What it is saying is that it will not cover the $200,000 in account number 60 and it is showing that it is a situation or problem with that loan.
Also, it will not cover UCC1 fixture filing number 3750 held by Citizens Bank. It also states that it will not hold or cover the easement or right of way in book V page 520. Any and all easements and road right of ways. This is very important. This policy does not insure to the accuracy of the description of tract 1. Due to the inaccuracy of the legal description. If tract 1 is wrong in any of the deeds, then it makes all the deeds invalid because it can’t be shown as a correct piece of property.
For the loan amount $63,000, account number 64. It states in Fidelity National Title Insurance Co. On June 5, schedule B part 1, this policy does not insure against loss or damages by reasons of the following: disappearance conflicts in boundary lines, encroachment, variations in areas, party walls, or any facts that a correct survey or physical inspection of premises would disclose. The next one is very important. They are also saying that they will not cover deed of trust held by Citizens Bank in the original amount of $200,000 recorded in book 67, page 142. So that loan is saying it won’t cover because there is something wrong with the loan.
Next deed of trust held by Citizens Bank original amount $50,000 recorded in book 78 page 124 and the correction of deed book 882 page 395. We feel that this is very important because the correction deed was not signed by us. We knew nothing about the correction deed. We think that the deed was fraudulently done and that would make it invalid. The deed of trust held by Rodger A. Sindle in the original amount of $11,500 recorded in book 88 page 351. The deed of trust to Sindle investment which was also Bill Jones in the original amount of $20,000 recorded in book 97 page 331 as assigned to and held by international credit corp. At book 108 page 397. This is very important because it shows that at the time, on August 1, when the bank said we were signing corrections with the bank, we were borrowing hard money with Bill Jones. We borrowed $12,000 from him and had to pay back $20,000, so there is no way that we would have signed a correction of a deed at that time.
Also, it says that the UCC 1 number 3750 held by Citizens Bank would not be covered. Next was the policy that was not insured as of the accuracy of the description of the subject property due to the inadequacy of the legal description of tract 1. That is very important. It also states that the right of way of Main Street and Tennessee Highway 25 is not covered. It also talks about, in tract 2, that there is a discrepancy in it also. So the loan of $22,676.81, which is account 63. There’s a problem with that title insurance because that title insurance was done as the final title opinion done by Donoho, Taylor, and Taylor, Attorney at Law. The problem we have with that is that Ms. Taylor, Betty Lou Taylor, was the trustee of the bank and she was also is in, with Taylor and Taylor of Donoho, Taylor, and Taylor. Also, she is related to Mr. Wilson Taylor who was the president of the bank at that time. We feel that it could be some discrepancies in the deeds, the correction deed Ms. Betty Lou Taylor also did, the one for the $50,000, and the one for the $200,000, she did also and the one for the $63,000 and $22,000 she did also. There is some discrepancy in how these loans were set up. We feel that this loan and the rest of the loans need to be investigated because there might have been some “home-cooking” in some of these situations.
We also feel that Citizens Bank has made fraudulent claims as to how much we owe them. We make this statement based on what the bank filed in case 309-BK10241 and they filed a claim on 9/30/09.in this filing, the account number was 9944060, they stated in that claim that we owed $151,552.70.in the next claim, the one I just did was claim 8, the next claim 10 filed on 9/30/09 it also is 9944060, they stated that we owe $38,492.34. The next claim 4 filed 9/30/09 account 9944062 they claimed that we owe $3,409.91. Claim 7 on 9/30/09 account number 99944062 they claimed that we owe $22,806.87. Claim 6 filed 9/30/09 account 99944063 they claimed that we owed $20,809.30. Claim 5 filed same date account 99944064 they claimed that we owed $8,746.24. Claim 9 filed same date account 99944064 claims that we owed $53,909.07.
To sum this up, it comes to what they are claiming two thousand nine hundred and nine thousand seven hundred and twenty six dollars and fifty cents [$2,909, 726.50]. The only problem with that is a month later in the Motion of Citizens Bank of Hartsville for the relief of automatic stay in case 309-BK-10241 docket 22, they filed on 10/29/09, they stated in it that we owed them $375,000 it was because of 6 promissory notes and there is not 6 promissory notes. This amount is in excess of what they stated about $75,000. It is our belief that we have satisfied all the notes. We have paid Citizens Bank from 1994 over $595,000. We base this on the payment history that the bank sent to us on 1/13.in it, it shows that we paid exactly that amount. We believe that all the notes have been satisfied under SBA guidelines 7A and we feel that Citizens Bank has been satisfied.
Another issue we have is with the Motion of Citizens Bank for Relief from Automatic Stay that they filed on 10/29/09, Mr. Larry Edmonson filed it, they didn’t file the 97 correction, they filed the 96 one, showing that it must be something wrong with that in the collateral. They also stated that above deeds and trust, indebtedness is secured by the first property secured interest in liens upon the following real property: collateral property attached hereto exhibit A. They show the 96 loan of $50,000 but not the correction and what they are doing is taking all the money and putting it on one loan which that loan was for $50,000 and should have been paid off in 2006. They combined all the loans on that one loan, which is not right.
We filed a response on 11/18/09, the response to Citizens Bank of Hartsville Motion for Relief of Automatic Stay and in that letter we stated that Citizens Bank of Hartsville has only filed claims for 4 notes while the motion for relief states there are 6 notes. These 4 notes are the ones done on February 1,1995, November 26,1996, April 25, and May 30. We stated that the debtor states that the deeds of trust are inadequate and drawn in describing property only covers part of his tracts and descriptions are not what SBA approved for the loans. It also states that the 96 loan for $50,000 has been paid. It was a note that should have been paid in 10 years. This was done by lawyer Mr. Kevin Key.in case 309-BK-10241, docket number 32 was filed 12/15/09, it was a prehearing statement that showed what Citizens Bank of Hartsville believed was in the loan that they were saying we owed them $365,000 which also went down to $325,000. Our response to that was, we had 4 loans, those 4 loans had been satisfied. We also showed that Alternative Health Care, Inc. Put us in bankruptcy by not paying the notes, we also stated that debtor asserts that SBA requirements for these loans were not met. The default of the legal description does not match these actual tracts. The contested facts that Mr. Larry Edmonson and Mr. Kevin Key went over, was how many secured notes did the debtor sign with the Citizens Bank of Hartsville. What are the present balances on these notes? Whether the legal description match actual property. The contested legal issues were, number 1, whether the tracts of land were necessary to the debtors reorganization. Number 2, whether the reorganization is likely, number 3, whether the debtor has any equity in the property. That is very important we will come back to that. Number 4, whether it is entitled to an adequate protection. Number 5, whether the underlying notes are valid because of the failure to comply with SBA requirements, number 6, whether the legal descriptions in the deeds of trust match the actual tract of land, number 7, whether the note of Nov 26,1996 has been satisfied.in this, Mr. Edmonson and Mr. Key agreed to these but none of them were ever brought up in court. None of them were ever shown in court because Judge Payne would not let us bring in any evidence and neither did my lawyer have anything set up to put in evidence.
On February 1 or 2, Judge Payne ruled a motion of the United States trustees to dismiss case pursuant to 11-USC11 12 B 4.in number 4 Judge Payne makes the statement that the data has not proposed a plan of reorganization in this case and based on information and belief is unable to propose a feasible plan of reorganization since the secured creditor Citizens Bank of Hartsville obtain relief from stay on February 10 and is pursuing its remedies under the applicable state law.in this case Citizens Bank of Hartsville never showed that they were a creditor, we did not get a chance to show that Citizens Bank of Hartsville did not show they were a creditor, it was not thrown out based on the information it was thrown out because an organizational plan had not been submitted, which I had previously discussed with my lawyer about us needing to get that plan submitted. I also discussed with my lawyer about the one month plan of correction of responsibility of that. We did not do that. I then later appealed it myself February 9. I relieved Mr. Key as being my lawyer and started filing petitions after that.
The reason I relieved Mr. Key and feel I didn’t get a fair chance in that case with Judge Payne as the Judge, was: 1. Citizens Bank of Hartsville put in a lot of exhibits on hearsay and it was never challenged by Mr. Key. For example, Mr. Dillehay and associates, when they did the surveying plats, it should have been challenged because it is so small you can’t see it. We don’t know where the boundaries are located and Mr. Dillehay had to use a magnifying glass, states that this plats and deeds of survey is not adequate so we feel that they got to put in evidence that was not adequate.
Exhibit 4 the Darnell Survey of the 1 acre. The boundaries around that acre should have been challenged because the walls of that property is vague. Exhibit 5 should have been challenged regarding the statement that was done by Citizens Bank of Hartsville by Wilson Taylor on page 1 of SBA loan. It stated on November of 1994 for $200,000 700 Highway 25 East Main Street Hartsville under the 7A SBA plan this east main should have been challenged against the attachment that they show on the back page trustee book 67, page 142-147. It should be challenged because it states on there beginning at an iron pin, said pin in the south right of way of State highway 25, the northeast corner of the herein described tract, and a corner to the Trousdale county board of education as evidence in deed book A1 page 471, Registers Office of TCT. The only problem with that is, that it never shows up in any of the other deeds, that is before this. It states at the bottom that this is a part of the property which was conveyed to Dwight Mitchell and wife Rachel by Fred and Wilma Beene but if you look back at their deeds you don’t see that, so it should have been challenged to see if it was valid. Also the uniform commercial codes that the bank put in evidence as exhibit 6 should have been challenged because the title insurance states it won’t cover it and why they won’t cover it. There had to be a reason they won’t cover it.
Exhibit 7 should have been challenged because on page 2 of the SBA papers it states that the loan is for 10 years and the payment amount is $682 payable each month. This should have been challenged because the bank illegally changed the notes without me knowing. Also on page 1 the request of August 29 it only states for the $50,000 to be made to Dwight Mitchell D/B/A Sun Valley Home for the Aged, it doesn’t say anything about the home or the 14 acres. It should have been challenged there because they come back as collateral without showing me or showing anyone when Idiid the note which they only showed us the 3 pages and we only signed the last page, it doesn’t show anything about the 14 acres and the home.
Also it should have been challenged regarding the title insurance when it shows in the title insurance that it won’t cover this loan of $50,000 and the $200,000 before this loan. Also the correction deed should have been challenged because we didn’t sign it and someone signed it and put it as we signed it. It wouldn’t have been no way we would have signed it at that time because we weren’t in good relationship with the bank. Also there were three letters that was corresponding between Citizens Bank, Mr. Wilson Taylor, and SBA that I had never seen before. These 3 letters are stating there is an issue regarding the property and an issue regarding how much land I had. It was also an issue regarding how much of the collateral they should take. At the time we took out the loan, we understood they were going to use the 5 acres they were already using for the first loan. I think someone got greedy and tried to consume the whole property over $50,000 when in these letters—one, they should have been counted as hearsay until we could had someone from SBA come, get on the stand, and verify these letters, because these letters may be forged by Citizens Bank of Hartsville or anyone. They should have been challenged. Another thing that should have been challenged is Exhibit 12 which is the Lloyd Andrews surveyor’s appraisals of real property. We feel these appraisals were red-lined and I will explain why. Lloyd Andrews was an agent of the bank by doing the appraisals for the bank. The reason why I say they were red-lined, there is a pattern of low balling my property or Block busting. I go back to the first appraisal that was done on 5/23/94 for Citizens Bank of Hartsville. He stated the property was worth $160,000. August 12,1996, he stated that the properties were only $215,000. On October 31, he stated that the property is worth only $214,000 and he is doing it also at the same time for Citizens Bank of Hartsville. On Thursday July 8, Gene Carmen, which is where Mr. Lloyd Andrews worked, states that the property is worth $680,000 from 1994 to October the property didn’t go up any. When the time that I was in bankruptcy, the property went up to $680,000. I feel that this is showing red-lining.
Also, a final subdivision plat for my property which was put in Dwight Mitchell’s name was done by Mr. Carl Carmen survey had already been done for a subdivision in the located in the 7th district of TCT showing that this property is worth way more than what they had been saying it was worth. I feel that this was a state of red-lining to low ball my price so they could get the property and when they got the property they had plans to subdivide it and make millions off it.
The reason why this is important is that on October 12, I sent a letter to Ms. Betty Sue Hibdon of Citizens Bank of Hartsville requesting to get some of the equity out of my property. I stated that there was a misbalance of collateral with Small Business Association guaranteeing 80% of the loan and Sun Valley securing the 20%. This was on October 12. On October 22, I received a letter from Citizens Bank of Hartsville that says per your request for a full appraisal on your property located on 700 McMurry Blvd, —one: have contact Mr. Lloyd Andrews. Mr. Andrews is a TN State certified appraiser and is approved by the Citizens Bank of Hartsville board of directors. This is the first step in pursuing your request for extension or restruction. On January 4, this letter is from Citizens Bank to me and Sun Valley. It states this letter is in response to your request of Citizens Bank to subordinate our deed of trust. You stated that you have an individual willing to loan you sufficient funds to pay our loans current. If we would be willing to subordinate this request was presented at our executive committee on January 3, I was at the committee in agreement that we cannot approve your request because current appraisal value has decreased and this business is not operational. What they were saying is that the value of the property had decreased, but at the time property was going up sky high and there was a lot of commercial property that was not being commercial property. This was a partial appraisal and I asked for a full appraisal which was not given. This letter was January 4.
Around May 24, I sent a package to Citizens Bank showing the reason why I felt that this property had already been satisfied in being paid and also about the invalid deeds of trust, and asking them to release the property. They sent me a letter back on May 24 stating Dear Mr. Mitchell, you have requested that Citizens Bank release our liens on your property. We have financed known as Sun Valley Home for the Aged. This is to inform you that we will not release our liens and have again started the foreclose process.
We feel that Citizens Bank had no intent of working with Sun Valley or Dwight Mitchell. Their main goal was to seize the property. The reason why I state that is because of the foreclose letters and they go like this. The first notice of trustee sale was April 3, that I have on record. And it states deed book 78 page 124. Also trustee deed book 882 page 395. Also on April 3, states deed book 125 page 399.
The next foreclose letter that I have is from Donoho and Taylor. It was faxed to Mr. Ed Kendall. It says two notes. This was on 4/1. Has deed book 78 page 124, deed book 82, page 395, and also deed book 125, page 399. The next foreclose letter that I received it says notice of trustee sales trustee deed book 78, page 124, trustee deed book 82, page 395, and trustee deed book 125 page 399. And these were on September 11. The next foreclose letter was on June 18. Notice of trustee sale trustee 78 page 124, deed book 82, page 395, and also deed book 125, page 399. And these were on June 18. The next foreclose letter was on June 25. Notice of trustee sale trustee 78 page 124, deed book 82, page 395, and also deed book 125, page 399. And these were on June 25. The next foreclose letter was on September 10. Notice of trustee sale trustee 78 page 124, deed book 82, page 395, and also deed book 125, page 399. September 10.
The problem we have with these foreclosures is that they left out two of the deeds and we feel the reason they left them out is because they knew it was a problem with those deeds. The deeds they left out was in trustee book 67, page 142-147, that loan was for $200,000 and they didn’t put it in and we feel it was because the acreage was not valid and it made the deeds invalid. The other deed that they did not put in was in trustee deed book 127 37-40. The amount of this loan was $63,000. We feel that this loan, they didn’t include because they told SBA they were going to use 1 acre and in this deed they tried to get 14 acres and we think they realized this deed was invalid and didn’t put it into the foreclosure. The only deeds they put in was the trustee 78 page 124-130, deed book 82, page 395-402, this was for the $50,000. We feel they put this one in because they were going to try to encumber all the land when it shouldn’t have been encumbered. The loan should have been paid off in 10 years but they were going to try to manipulate and hurry up and foreclose this piece of property for all the property. The other deed was in trustee deed book 125, page 399-402. This loan was for $22,000. The only problem with this loan is they told SBA that they were going to take 8 commercial acres and in the deed book its stated 1 acre. This loan should have been combined with the $63,000, but they wouldn’t combine it and with us we thought that those two should have been combined.
On all these deeds Betty Lou Taylor’s name is on the deeds, we feel that was fraudulent. The other deeds that were made with property not shown. We feel that we have sufficed all the loans and Citizens Bank should release all property.
We based this under the case CC Holdings Tennessee Inc versus TN Gas Transport Inc. 169 Bankruptcy. 643 Bankruptcy. M. D Tennessee. 1994. Number 1: it states that TN law requires advances of interest in the property to include a description of the property. Number 2: the deed must designate the land intended to convey with responsible certainly. Number 3: the test is can a surveyor with deed before him can locate land, establish boundaries. Number4: if property description is insufficient, the deed is void and transfer no interest in the guarantors property. Number 5: a deed that identifies no particular tract of land is void for vagueness. This case was done by Judge Payne in 1994. We wanted to bring this before Judge Payne. It was not brought before him by my lawyer or a change for me to bring it before him, and we feel that if this could have been brought before the Judge that it would have shown that this piece of property was not deeded to Citizens Bank properly. When we could not get any relief from the courts, we got in touch with Federal and State institutions.
In July 30, we were brought up again against the state Department of Health abuse registry. We were coming to show that Ms. Gibson who was the nurse, said she found the maggots. We were coming to show she purged herself. We had a witness that was there that day that gave Ms. Vaughn a bath and didn’t see any maggots. Ms. Gibson did not show that day. The State said that they had subpoenaed her and she would not show. This was the abuse registry. The last page they didn’t sign like the first time back in 2007. The date on this was July 30. We came back with an appeal process. The docket number was 17.38-09376J. Mr. Kendall was sick at that time. He excused himself as my lawyer on September 23. Around September 25, I wrote an appeal to the administrative order entered on September 10.in this document, we used the TCA 273128 and the United States Constitution to show Guardian Home Health did not do any wound care education with Sun Valley. Number 2: that we were not given the proper chance to present ourselves at the meeting. They gave us only 15 minutes from the first time we met with the State. On the 15th, they didn’t even have us there. The next meeting they gave us 15 minutes to describe what happened. The next thing happened, we started winning the case and the Judge stopped the hearing and let it go for almost two months before we went back to trial because none of the board members would come back. We feel that we were discriminated against. Our civil rights were violated. We also showed that the ombudsman had no right to come into our facility because of a search and seizure law that the warrant the district attorney gave was unconstitutional. We were served with an unconstitutional warrant and with those grounds we feel that all those things should be thrown out. Number 3: that we had a right to face our accuser, Ms. Gibson. She didn’t show up and we asked that everything she said and stated be thrown out also. We feel that this has not been looked at and we sent it in on September 25 and here it is October 28 and it is still. Around October, we went to the state of TN Department of Financial Institution Consumer Resource Division. We wrote a letter stating that we felt our SBA loan was invalid and the reason why is because of how they structured them. We also stated that the first loan was a HUD loan and was invalid. We received a letter on October 8, which was in answer to our complaint against Citizens Bank and in the letter is says, “upon review of your complaint, matter against Citizens Bank by a member of the department of staff, it appears by information you provided that you are currently represented by legal counsel from the correspondence. The department has received this matter appears to be a factual dispute regarding whether a tract of land should have been included as part of the encumbrance on a deed of trust”.
March 8, we went to the NACA it’s the Neighborhood Assistance Corporation of America. At that time, Mr. Kevin Key stated that he wouldn’t mind if they would help us with the situation with Citizens Bank. Around March 19, we went to the EEOC to show the discrimination that was done by Citizens Bank and SBA. On April 24, the African American Country University wrote a letter to the assistant secretary of Fair Housing and Equal Opportunity and the date of that letter was April 24 which was regarding how my loans were situated. On April 24, the African Culture University sent to the United States Small Business Administration OIG they sent back with an account number 20100422.
On May the 2nd, the African Culture University sent a letter to the FBI in Cookeville regarding the situation with our property. On June 7th, the African Culture University sent a letter on the Office of the Inspector General of SBA the account number is 20100422 to try to get information about the situation with our property.
On 7/7/10, we sent a letter to the Consumer Assistant Program Board of Professional Responsibility of the Supreme Court of TN regarding the situation with our property addressing the issue that no evidence was put in, how the trial went in bankruptcy, and how Mr. Kevin Key didn’t put in any evidence and how the Judge didn’t let us put any evidence in.
On June 14, at 7:11 am, I, Dwight Mitchell, sent packages to OIG of SBA and also to the office of the Attorney General in Washington, DC. 950 Pennsylvania Avenue, North, West Washington DC 20530. Both of these were delivered by the USPS June 14 at 7:11. Both at the same time.
On July 13, the Consumer Assistant Program of Board of Professional Responsibility of the Supreme Court of TN sent me a letter they send to Mr. Key. This is file number 10002223 of the complaint of Dwight Mitchell, asking for information from Mr. Key about my case. On July 27, I received another letter from the Consumer Assistant Program of Board of Professional Responsibility of the Supreme Court of TN they asking a second request of Mr. Key giving him 5 days to respond to my letter.
On August 2, I get a letter from Ms. Beverly Sharp, Director of Consumer Assistant Program of Board of Professional Responsibility cap number 10002223 and it’s the response of Mr. Kevin Key.in this response at the end of the l
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