NOTICE OF DEPOSITION OF THE OFFICIAL COMMITTEE OF

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					                 IN THE UNITED STATES BANKRUPTCY COURT
                        MIDDLE DISTRICT OF ALABAMA
                               SOUTHERN DIVISION
                                      )
IN RE:                                )   Chapter 11
                                      )
                             1
   SMALL LOANS, INC., et al.          )   Case No.: 11-12254
                                      )
               Debtor.                )


             NOTICE OF DEPOSITION OF THE OFFICIAL COMMITTEE
            OF UNSECURED CREDITORS PURSUANT TO BANKRUPTCY
         RULE 7030(B)(6) AND FEDERAL RULE OF CIVIL PROCEDURE 30(B)(6)

TO:      R. Kyle Woods
         John D. Elrod
         Greenberg Traurig, LLP
         3290 Northside Parkway, NW, Suite 400
         Atlanta, Georgia 30327
         Proposed Counsel for The Omnibus
         Official Committee of Unsecured Creditors


         PLEASE TAKE NOTICE that debtors and debtors in possession, Small Loans, Inc.

(“Small Loans”), The Money Tree, Inc. (“The Money Tree”), The Money Tree of Louisiana, Inc.

(“The Money Tree LA”), The Money Tree of Florida, Inc. (“The Money Tree FLA”) and The

Money Tree of Georgia, Inc. (“The Money Tree GA”) (collectively, the “Debtors”), by and

through undersigned counsel, will, pursuant to Rule 7030(b)(6) of the Federal Rules of

Bankruptcy Procedure and Rule 30(b)(6) of the Federal Rules of Civil Procedure, take the

deposition upon oral examination of the Official Committee of Unsecured Creditors of the

Money Tree, Inc. (the “UCC”), through the person designated by the UCC to be examined as to

the subject matter and documents identified in Exhibit “A,” before a Notary Public or other

1
   The related Debtors along with the last four digits of each Debtors' federal tax identification number and
respective case numbers are Small Loans, Inc. (3224) Case No. 11-12254, The Money Tree Inc. (1386) Case
No. 11-12255, The Money Tree of Georgia Inc. (9228) Case No. 11-12258, The Money Tree of Florida Inc. (5315)
Case No. 11-12257, and The Money Tree of Louisiana, Inc. (2592) Case No. 11-12256. Case information and the
Debtors' respective addresses can be found at the dedicated website for these cases:
http://www.kccllc.net/SmallLoansInc.

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qualified officer, on Thursday, April 19, 2012, at 10:00 a.m. at the offices of Baker Donelson

Bearman Caldwell & Berkowitz, P.C., 420 Twentieth Street North, Suite 1600, Birmingham,

Alabama, 35203.

         You are invited to attend and participate as you deem appropriate.

                                                     /s/ Max Anderson Moseley
                                                     Max A. Moseley
                                                     Jan M. Hayden
                                                     Bill D. Bensinger
                                                     Proposed Attorneys for Debtors and
                                                     Debtors-in- Possession,
                                                     SMALL LOANS, INC., et al.

OF COUNSEL

BAKER DONELSON BEARMAN
CALDWELL & BERKOWITZ, PC
420 20th Street North, Suite 1600
Birmingham, Alabama 35203
Telephone: (205) 244-3817
Facsimile: (205) 488-3817




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                                         EXHIBIT A

                                        DEFINITIONS

As used herein, the following words have the following meanings:

          1.      “Debtors” means, collectively, Small Loans, Inc. (“Small Loans”), The Money

Tree Inc. (“Money Tree”), The Money Tree of Georgia Inc. (“Money Tree GA”), The Money

Tree of Florida Inc. (“Money Tree FLA), and The Money Tree of Louisiana, Inc. (“Money Tree

LA”), including all officers, directors, attorneys, agents, employees, and representatives acting

on behalf of same.

          2.      “Committee,” or “you,’ means the Official Committee of Unsecured Creditors in

this Chapter 11 proceeding, including all members, officers, directors, attorneys, agents,

employees, representatives, and otherwise acting on behalf of same.

          3.      “Person” shall encompass both natural and juridical persons, including, without

limitation, any individual, corporation, company, association, partnership, business, public

agency, department, bureau, board, commission, or any other form of public, private, or legal

entity.

          4.      “Documents” means any writing, graphic matter, record, or other tangible thing,

however produced, reproduced, or preserved, including, but not limited to, letters, reports, other

written communications, correspondence, telegrams, e-mails, computerized instant messages,

memoranda, summaries, records of oral conversations, original or preliminary notes, diaries,

calendars, travel records or itineraries, forecasts, analyses, projections, work papers,

photographs, tape recordings, models, statistical statements, graphs, laboratory and engineering

reports and notebooks, charts, plans, drawings, minutes or records of meetings, minutes or

records of conferences, expressions or statements of policy, lists of persons attending meetings

or conferences, reports and/or summaries of investigations, opinions or reports of consultants,
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appraisals, evaluations, financial statements, records, summaries of negotiations, contracts,

agreements, leases, loan agreements, loan documents, brochures, pamphlets, advertisements,

circulars, trade letters, press releases, invoices, receipts, including preliminary drafts or revisions

or copies of any of the foregoing if the copy is in any way different from the original now in your

possession, custody or control, or the possession, custody or control of your counsel,

independent public accountants, evaluation consultants, engineering consultants, agents,

employees and/or persons acting on your behalf.            As used herein, “control” means actual

possession, constructive possession, beneficially owning, power to obtain, and ability to obtain

any document.

         5.       “Concern,” or “concerning,” means referring to, reflecting, or relating to, in any

manner logically, factually, indirectly or directly, the matter discussed.

         6.       “Communication” means any transmission of information by written, oral,

mechanical, magnetic, electronic, optical, digital, laser, photographic, pictorial, or other means,

including without limitation documents, personal conversations, telephone calls, meetings,

computer bulletin boards and e-mail messages, telegrams, facsimile transmissions, wires, and the

like.

         7.       “Identify,” when used in reference to:

         (a)      an “individual,” means to state his or her full name, present or last known

         residence address (designating which) and telephone number, and present or last known

         (designating which) business affiliation, job title, employment address and telephone

         number;




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         (b)      a “firm,” partnership, corporation, proprietorship, association, trust, estate, or

         other organization or entity,” means to state its full name and present or last known

         (designating which) address and telephone number; and

         (c)      a “document,” means to state the title (if any), date, author, sender, recipient, the

         identity of person signing it, type of document (i.e., a letter, memorandum, book

         telegram, chart, etc.) or some better means of identifying a summary of its contents, and

         its present location or custodian.

         8.       The term Motion to Appoint Chapter 11 Trustee shall mean the motion filed by

the Official Committee for Unsecured Creditors on February 27, 2012.

         9.       As used herein, “basis” or "bases" means any person, document, or otherwise

source of information supporting the matter or giving rise to the allegation discussed.



                                    SCOPE OF EXAMINATION

         1.       The factual bases for your allegation that the Debtors “have used their lengthening

stay in bankruptcy to liquidate their assets and pay insiders the proceeds, while seeking a vague

investment from a third party to reorganize,” as alleged in your Motion to Appoint Chapter 11

Trustee, ¶ 5.


         2.       The identity of any “insiders” to whom the Debtors have paid proceeds obtained

from the liquidation of their assets, as alleged in your Motion to Appoint Chapter 11 Trustee, ¶ 5.

         3.       The factual bases for your allegation that the Debtors “have been insolvent since

at least 2007,” as alleged in your Motion to Appoint Chapter 11 Trustee, ¶ 7.

         4.       The factual bases for your allegation that the Debtors “have been funding their

operations over the last 10 years primarily from the sale of debentures rather than through

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earnings from loans to consumers,” as alleged in your Motion to Appoint Chapter 11 Trustee, ¶

7.

         5.       The identity of and factual information pertaining to the “numerous conflicts of

interest” that you allege to exist on behalf of the Debtors’ management and as requiring the

appointment of a trustee in these proceedings, as alleged in your Motion to Appoint Chapter 11

Trustee, ¶¶ 11; see also ¶ 15.

         6.       The identity of and factual information pertaining to the “creditors” of the Debtors

who “loaned their life's savings to one or more of the Debtors, and rely on those funds to pay

utilities, mortgages, and to buy food,” as alleged in your Motion to Appoint Chapter 11 Trustee,

¶ 22.

         7.       The identity of and factual information pertaining to the “certain subsidiaries” that

management of the Debtors has incompetently failed to place into bankruptcy, as alleged in your

Motion to Appoint Chapter 11 Trustee, ¶ 24, and the factual bases for your belief that such

subsidiaries should have been placed in bankruptcy.

         8.       The factual bases for your allegation that management of the Debtors “has

breached its fiduciary duties to creditors,” as alleged in your Motion to Appoint Chapter 11

Trustee, ¶¶ 14-18.

         9.       The factual bases of your allegation that management of the Debtors “is not

competent to continue managing the Debtors' affairs,” as alleged in your Motion to Appoint

Chapter 11 Trustee, ¶¶ 19-25.

         10.      The factual bases of your allegation that “the Debtors' operations are tantamount

to a Ponzi scheme,” and that “the Debtors are, or were, effectively running a Ponzi scheme,” as

alleged in your Motion to Appoint Chapter 11 Trustee, ¶¶ 26-31.


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         11.      Information pertaining to any person you have contacted regarding any sale,

purchase, or otherwise investment in the Debtors, as alleged in your Motion to Appoint Chapter

11 Trustee, ¶ 5, and the content and extent of any communication between you and such person

or persons.

         12.      The factual basis for any other allegations contained in your Motion to Appoint

Trustee.




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                      IN THE UNITED STATES BANKRUPTCY COURT
                        FOR THE MIDDLE DISTRICT OF ALABAMA
                                 SOUTHERN DIVISION

In re:                                              )
                                                    )
SMALL LOANS, INC., et al.,1                         )    Case No. 11-12254-WRS-11
                                                    )
                                                    )    Jointly Administered
                 Debtors.                           )
                                                    )

     EMERGENCY MOTION FOR PROTECTIVE ORDER REGARDING NOTICE OF
     DEPOSITION OF THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS
    PURSUANT TO BANKRUPTCY RULE 7030(b)(6) AND FEDERAL RULE OF CIVIL
                           PROCEDURE 30(b)(6)

         COMES NOW, the Official Committee of Unsecured Creditors (the “Committee”) in the

bankruptcy cases of Small Loans, Inc., et al. (the “Debtors”), pursuant to Federal Rules of Civil

Procedure (“FRCP”) 26 and 30, as made applicable to this contested matter by Federal Rules of

Bankruptcy Procedure (“FRBP”) 7026, 7030, and 9014, and hereby moves this Court to enter an

order quashing the Debtors’ Notice of Deposition of a FRCP 30(b)(6) representative of the

Official Committee of Unsecured Creditors (the “Notice of Deposition”). In support hereof, the

Committee states as follows:

                                           I. INTRODUCTION

         1.      Pursuant to FRCP 26(c)(1), the Committee seeks a protective order on an

expedited basis quashing the Debtors’ Notice of Deposition2 requesting that a designated

representative of the Committee be examined as to the subject matter and certain documents

referenced in the Notice of Deposition. The Committee is made up of individuals who will not

be fact or expert witnesses at the Court’s April 26-27 hearing on the Committee’s Motion to

1
  The Debtors in these cases are Small Loans, Inc., Case No. 11-12254, The Money Tree, Inc., Case No. 11-12255;
The Money Tree of Louisiana, Inc., Case No. 11-12256; The Money Tree of Florida, Inc., Case No. 11-12257; and
The Money Tree of Georgia, Inc. Case No. 11-12258.
2
  A true and correct copy of the Notice of Deposition is attached hereto as Exhibit A.



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Appoint Chapter 11 Trustee [Docket No. 195] (the “Trustee Motion”). Having a representative

of the Committee deposed in Birmingham, Alabama (a location which has no nexus to these

cases other than it happens to be the location of the Debtors’ counsel) regarding subject matter

largely, if not completely, unknown to the Committee members is oppressive and unduly

burdensome, with little chance that it would discover facts relevant to the Trustee Motion.

       2.      Under FRCP 26(b)(2)(c), the deposition of the Committee’s representative would

be unduly burdensome due to a) the physical strain on the Committee’s members, b) the high

cost and expense of the deposition, which would outweigh any likely benefit of said deposition,

as the Committee’s members do not possess any additional information that is not already

available to the Debtors from the Debtors’ public filings with the U.S. Securities and Exchange

Commission (the “SEC”), the Debtors’ representatives’ testimony at the meeting of creditors

pursuant to section 341 of the Bankruptcy Code, and documents produced by the Debtors to the

Committee’s professionals.

       3.      Even if any of the Committee’s members were deposed, pursuant to FRCP

26(b)(1), any additional information of the Committee’s members not already available to the

Debtors would be undiscoverable, as the additional information is privileged information

protected by the Committee’s attorney-client privilege and work-product doctrine.

                                      II. BACKGROUND

       4.      On December 16, 2011 (the “Petition Date”), the Debtors filed voluntary

petitions for relief under chapter 11 of title 11 of the United States Code (the “Code”).

       5.      The Debtors are operating their businesses and managing their financial affairs as

debtors-in-possession pursuant to Sections 1107 and 1108 of the Code.




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       6.      On January 5, 2012, the Court entered the Order for Joint Administration [Docket

No. 62], in which it directed that the Debtors’ bankruptcy case be jointly administered. On

January 9, 2012, the Bankruptcy Administrator for the Middle District of Alabama appointed

separate Official Committees for the bankruptcy estates of The Money Tree, Inc. and the Money

Tree of Georgia, Inc., which were subsequently consolidated into the Committee.

       7.      On February 9, 2012, the Debtors’ section 341 meeting was held. At the meeting,

the Debtors’ CEO, Bradley Bellville, and its CFO, Stephen Morrison, testified on the Debtors’

behalf pursuant to the requirements of the Bankruptcy Code.

       8.      On February 27, 2012, the Committee filed its Motion to Appoint Chapter 11

Trustee (the “Trustee Motion”). The facts supporting the basis for the claims in the Trustee

Motion were determined from the Debtors’ public filings with the SEC, the Debtors’ 341

Meeting, and documents produced by the Debtors to the Committee.

       9.      On April 5, 2012, the Debtors served the undersigned counsel with the Notice of

Deposition seeking the April 19, 2012 deposition of a designated member of the Committee to

provide further information regarding the facts supporting the basis for the claims in the Trustee

Motion. The Debtors served this Notice of Deposition despite having access to the documents

and information used in the Motion to Appoint Trustee, which are either available publicly or

already in the possession of the Debtors.

                       III.   GROUNDS FOR REQUESTED RELIEF

       10.     The Debtors’ Notice of Deposition is outside the scope of discovery provided

under FRCP 26. FRCP 26(b)(2)(C) reads:

       On motion or on its own, the court must limit the frequency or extent of discovery
       otherwise allowed by these rules or by local rule if it determines:




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       (i)    the discovery sought is unreasonably cumulative or duplicative, or can be
       obtained from some other source that is more convenient, less burdensome, or less
       expensive;

       (ii)   the party seeking discovery has had ample opportunity to obtain the
       information by discovery in the action; or

       (iii) the burden or expense of the proposed discovery outweighs its likely
       benefit, considering the needs of the case, the amount in controversy, the parties’
       resources, the importance of the issues at stake in the action, and the importance
       of the discovery in resolving the issues.

       11.    Since the subject matter of the Debtors’ Notice of Deposition is the factual basis

and documents in support of the claims in the Trustee Motion, the discovery sought is

“unreasonably cumulative or duplicative” and can be “obtained from some other source that is

more convenient, less burdensome, or less expensive.” FRCP 26(b)(2)(C)(i). The factual basis

and documents in support of the Debtors’ Motion to Appoint Trustee derives from the Debtors’

public filings with the SEC, testimony of the Debtors at the 341 Meeting, and documents

produced by the Debtors to the Committee and not from any additional information provided by

any of the Committee’s members.

       12.    In American Federation of State, County and Municipal Employees (AFSCME)

Council 79 v. Scott, 277 F.R.D. 474, 478 (S.D. Fla. 2011), the court held that the information

sought was not relevant to the case and indicated the Defendant could obtain the information

requested from other sources. The court pointed out that there was “no need to subpoena these

documents and information from the ACLU as he and his counsel are perfectly capable of

performing their own research . . . [t]o the extent any of this data is relevant to this case,

Defendant has not shown why the ACLU is the most appropriate depository of this information

(at the very least beyond production of publicly available documents or research that the

organization provides to anyone accessing their website).”       Id.   See also (Securities and

Exchange Commission v. Sloan, 369 F. Supp. 994, 996 (S.D.N.Y. 1973) (holding that allowing

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Defendants to obtain public information readily available to them would be unduly burdensome

on the Plaintiff, since the hardship to the Plaintiff was unreasonable compared to the benefits to

the Defendants).

       13.     Similar to the case in Scott, the Debtors seek information from the Committee’s

members that is readily available to the Debtors, as a majority of the documents and testimony

supporting the Committee’s Motion to Appoint Trustee are in possession of, or derived from, the

Debtors. To force any of the Committee’s members to travel to Birmingham, Alabama at the

expense of these bankruptcy estates to rehash information already known to the Debtors is both

unreasonably duplicative and unduly burdensome.          Other than potential intimidation and

embarrassment, and certain harassment, of the Committee’s representative, the Debtors gain

nothing by deposing any of the Committee’s members, as the Committee’s members’ knowledge

of the Debtors’ business, financial affairs, and the grounds for the Trustee Motion is not any

greater than the Debtors’ own knowledge of those topics and all relevant documents are in

possession of, or have been provided by, the Debtors.

       14.     The only potential information not already known to the Debtors would be

privileged communications between the Committee and its counsel, which communications were

not used as a factual basis for the claims in the Trustee Motion. Courts have held that the

underlying facts of privileged communications and work product are discoverable, not the

communications or work product. See Security Ins. Co. of Hartford v. Trustmark Ins. Co., 218

F.R.D. 29, 34 (D. Conn. 2003) (indicating that the defendant was not asked to “disclose its work

product but rather was required to produce a witness capable of providing facts in support of the

allegations within its answer”); Protective Nat’l Ins. Co. v. Commonwealth Ins. Co., 137 F.R.D.




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267, 283 (D. Neb. 1989) (holding that defendant had to provide the factual basis for its

allegations).

           15.      Attorney-client communications and work product prepared in anticipation are

protected materials. As such, the only discoverable information the Debtors can obtain from the

Committee’s representative are facts supporting the Committee’s claims, which, as noted above,

were derived primarily from information in the possession of, or produced by, the Debtors.

Since the Debtors’ Notice of Deposition involves facts already known to the Debtors, cases like

Trustmark and Commonwealth are distinguishable, as the defendants in each case had factual

knowledge unavailable to the plaintiffs. Thus, the Debtors have had “ample opportunity to

obtain information” and the “burden or expense of the proposed discovery outweighs its likely

benefit.” FRCP 26(b)(2)(C)(ii)-(iii).

           16.      Under FRCP 26(c)(1), this Court “may, for good cause, issue an order to protect a

party . . . from annoyance . . . oppression, or undue burden or expense . . .” Forcing any of the

Committee’s members, most of whom are individuals residing in the State of Georgia, to be

deposed in Birmingham is the very definition of undue burden and expense. This Court should

put a stop to the Debtors’ attempt to force the Committee’s members to engage in a meaningless

and duplicative3 deposition at considerable expense to the Debtors’ bankruptcy estates.

           IV.      THE COMMITTEE’S COUNSEL CONFERRED WITH DEBTORS’
                    COUNSEL

           17.      The Committee has complied with FRCP 26(c)(1) as their counsel have in good

faith conferred with Debtors’ counsel on the matters presented herein.

           18.      Attorneys for the Committee and Debtors have communicated by telephone

regarding the Committee’s objections to the Notice of Deposition. The Committee and the


3
    The Debtors have also served a notice of deposition on the Committee’s financial advisor, HGH Associates.

                                                          6

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Debtors are in disagreement because the Debtors are asking the Committee to do that which

FRCP 26 explicitly absolves them of doing.

       WHEREFORE, the Committee respectfully requests the entry of a protective order

providing that:

       (i)        the Debtors’ Notice of Deposition be quashed; and

       (ii)       such further and additional relief as the Court deems just and proper.

Dated: April 9, 2012                                   GREENBERG TRAURIG, LLP


                                                       /s/ John D. Elrod
                                                       R. Kyle Woods
                                                       John D. Elrod
                                                       Greenberg Traurig, LLP
                                                       3290 Northside Parkway, Suite 400
                                                       Atlanta, Georgia 30327
                                                       (678) 553-2259
                                                       (678) 553-2269 Facsimile
                                                       woodsk@gtlaw.com
                                                       elrodj@gtlaw.com
                                                       Counsel to the Official Committee of
                                                       Unsecured Creditors




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                               CERTIFICATE OF SERVICE

       I hereby certify that I served a copy of the foregoing pleading on all parties receiving
Notices of Electronic Filing in this case, including the following:

Bankruptcy Administrator
ba@almb.uscourts.gov

Bill D Bensinger on behalf of Debtor Small Loans, Inc.
bbensinger@bakerdonelson.com, syoung@bakerdonelson.com;msellers@bakerdonelson.com

Steven K. Brackin on behalf of Creditor Phyllis Brackin
marthah@lbfjlaw.com, sbrackin@lbfjlaw.com

William M. Brakefield on behalf of Creditor James Stephens
BANKRUPTCY@hsmbb.com

Heather D. Brown on behalf of Creditor Kolb, Wheeler & Walter @ Brunswick, LLC
hbrown@kkgpc.com, jwest@kkgpc.com

Jay H. Clark on behalf of Creditor Alvy Devon Smith Scholarship Fund
jc@wallacejordan.com, aa@wallacejordan.com

Frank W. DeBorde on behalf of Creditor LOTSolutions, Inc., formerly known as Life of the
South Service Co., as agent for Life of the South Insurance Co., Insurance Co. of the South,
Bankers Life of Louisiana, and Lyndon Southern Ins. Co.
fwd@mmmlaw.com

Andrew H. Dekle on behalf of Creditor Margaret Knox
ahdekle@bouhan.com

David A Garland on behalf of Creditor Howard Barfknecht
dgarland@mcdr-law.com, wduskin@mcdr-law.com

Janie Salmon Gilliland on behalf of Creditor Mary Ann Campbell
janiegilliland@knology.net, jlengill@yahoo.com


                                               8

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Jan M Hayden on behalf of Debtor Small Loans, Inc.
jhayden@bakerdonelson.com, lhunter@bakerdonelson.com;kpinkston@bakerdonelson.com

Douglas L Henry on behalf of Creditor Greg Morrow
hanklaw@windstream.net

Max A. Moseley on behalf of Debtor Small Loans, Inc.
mmoseley@bakerdonelson.com, lisbell@bakerdonelson.com;towen@bakerdonelson.com

R. Randolph Neeley on behalf of Creditor United States, Internal Revenue Service
rand.neeley@usdoj.gov, carol.brensing@usdoj.gov

Charles N. Parnell on behalf of Creditor Bernard Randy Miller
bkrp@parnellcrum.com

Bobby L Scott on behalf of Creditor Henry McEachern
BLS@daycrowley.com

Harmon T. Smith on behalf of Creditor Helen Spedale
htsmith@bellsouth.net

Christopher W Terry on behalf of Creditor Ruby Altman
cterry@stoneandbaxter.com

Cater C. Thompson on behalf of Creditor FTC of Onaga
cater.thompson@jonescork.com, andrea.harris@jonescork.com

Lisa Wolgast on behalf of Creditor LOTSolutions, Inc., formerly known as Life of the South
Service Co., as agent for Life of the South Insurance Co., Insurance Co. of the South, Bankers
Life of Louisiana, and Lyndon Southern Ins. Co.
lwolgast@mmmlaw.com


       Dated this 9th day of April, 2012.



                                            /s/ John D. Elrod___________
                                            John D. Elrod
Greenberg Traurig, LLP
The Forum, Suite 400
3290 Northside Parkway, N.W
Atlanta, Georgia 30327
(678) 553-2259
(678) 553-2269 Facsimile
elrodj@gtlaw.com


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