SETTLEMENT AND RELEASE AGREEMENT 

This Settlement and Release Agreement (''Agreement") is made by, between, and among 

the tbllowing undersigned parties: 

The Plaintiff Federal Deposit Insurance Corporation as Receiver for Montgomery Bank 

& Trust, Ailey, Georgia ("FDIC·R"), and Rebecca Champion, Larry D. Coleman, Trae Dorough, 

John .Falk} Michael Gunter, Gregory A. Morris, Lloyd E. Moses, Thomas A. Peterson III, Miller 

P. Robinson, John L. Robison, Jr., and John Tyson (collectively the ''Settling Defendants") 

(individually, the FDIC-R and the Settling Defendants may be referred to herein as "Party" and 

collectively a<> the "Parties"). 

Rl~CITALS 

WHEREAS: 

Prior to July 6, 2012, Montgomery Bank & Trust, Ailey, Georgia ("Bank") was a 

depository institution organized and existing under the laws of Georgia; 

On July 69 2012, the Georgia Department of Banking and Finance closed the Bank and 

pursuant to 12 U.S.C. § 182l(c), the Federal Deposit Insurance Corporation was appointed 

Receiver. In accordance with 12 U.S.C. § I S2l(d), the FDIC-R succeeded to all rights, titles, 

powers and privileges of the Bank, including those with respect to its assets. 

Among the assets to which the FDIC-R succeeded were all of the Bank's claims, 

demands, a~d causes of action against its fonner directors, officers, and employees arising from 

the perfonnance, nonperformance, and manner of performance of their respective functions, 

duties and acts as directors, officers, and employees of the Bank; 

On July. I, 2015, the FDIC·R filed a complaint for money damages against the Settling 

Defendants, each of whom served at various times as a director and/or officer of the Bank. 

Those claims for damages arc now pending in the United States District Court for the Southern 

District of Georgia in Federal Deposit Insurance Corporation, as Receiver for .Montgomery 

Bank & Trust v. Champion, et al., Case Number 3:15--cv..00058-DHB-BKE ("D&O Action"). 

· The Settling Defendants have denied liability in the D&O Action. 
fDlC-R MH&T v. Champion, et al. 

Settlement and Release Agrct!ment 

The undersigrwd Parties deem it in their best interest~ to enter into this Agreement to 

avoid the uncertainty and expense of fut1her litigation. 

NOW, THEREFORE, in consideration of the ,promises, undertakings, payments, and 

reJeases stated he.rein, the sufficiency of which consideration is hereby acknowledged, the 

undersigned Parties agree, each with the other, as follows: 

Sft~CflON 1: Payment to FDIC-R 

A. As an essential covenant and condition to this Agreement, on or before thirty (30) 

calendar days following the date the FDIC-R executes this Agreement, the Settling Defendants, 

jointly and severally, agree to pay the FDIC-R the sum of NINE HUNDRED SIXTY-FIVE 

THOUSAND AND 00/100 DOLLARS ($965,000.00) ("the Settlement Payment"). 

B. The Settling .Defendants shall deliver the Settlement Payment in one lump sum 

payment to be made from the trust account of Oliver Maner LLP to the FDIC-R by direct wire 

transfer into the following account: Federal Home Loan Bank. of New York, New York Main 

Office, 101 Park Avenue, New York, NY 10178-0599, Routing No~'----······-········_,JAccountNo, 

(b)(4) ... J...... L for credit to F'DIC National Liquidation Account Montgomery Bank & Trust, Ailey, 

(b)(S) JJeorgia(EIN1044S)Profcssionalbiabilityf·· l DIP Fund. Asset Numberl .. )... .. .. {~)(5) 

(b)(6) Contact-1 .... ·····-·······-· ____ _,IDRR Investigations, (972) 761- 8112. 

In the event that the Settlement l)ayment is not delivered to the 1:-'DIC-R by the date 

detenn.incd in subsection A above, interest shall accrue on all unpaid amounts at the .rate of 5% 

per annum from that date until the date of payment. Howeve1·, if said Settlement Funds are not 

delivered to the FDIC-R by the date determined in subsection A above, as a result of the FDICR's failure to execute this Agreemen4 no interest shall accrue until five days after the FDIC-R 

executes the Agreement. 

C. If the FDIC-R does not receive the Settlement Payment in full on ot before the 

date detennined by subsection A above, then the FDIC-R, in its sole discretion, shall have the 

right at any time prior to receipt of the Settlement Payment in full (including all accrued interest) 

to: 

2 
FDlC·R Mll&T v. Champion. ct al. 

Scttlcmcnl and Release Agreement 

1. Extend the period of time for the Settlement Payment, including interest 

accruing from the date determined by subsection A above, through the date of payment ut a rate 

calculated in accordance with 26 U.S.C. § 6621 (a)(2); or 

2. Enforce this Agreement, in which event the Settling Defendants agree to 

jurisdiction in United States District Court for the Southern District of Georgia and. to pay all of 

the FDIC-R's reasonable attorney's fees and costs expended in enforcing the terms of this 

Agreement; or 

3. Tt.Tlilinate the Agreement, move to vacate any dismissal order, to which 

the Settling Defendants agree to consent, and re-institute an action on the FDIC-R's claims. The 

Settling Defendants further agree to waive any defense based on any statute of limitations that 

would bar any of the FDIC-R's claims and waive all objections, defenses, claims or 

counterclaims, and covenant and agree not to assert any objections, defenses, claims or 

counterclaims that did not exist or were otherwise unavailable as of the date this Agreement was 

fully executed; and/or 

4. Seek any other relief available to it in law or equity. 

Any extension of time under Section I.C.l for delivery of the Settlement Payment or 

acceptance of a portion of the Settlement Payment shall not prejudice the FDIC~R's rights to take 

any of the actions set forth in Section I.C.2 through I.C.4 at any time prior to receipt of 

Settlement Payment (including all accrued interest) in full. 

SECTION II: Stipulation and Dismissal 

Within ten business du:ys after the latter of (1) fuJI execution of this Agreement by all of 

the Parties. and (2) receipt of the Settlement Payment, plus any accrued interest, the FDIC-R 

shall file a stipulation of dismissal with prejudice, executed by the attorneys for all Parties 

hereto, in the form attached hereto as Exhibit A, in the D&O Action. 

SECTION III: Releases 

A. The FDIC-R's Releases. 

Upon receipt of the Settlement Payment in full and except as provided in Section III. C., 

3 
Fl.>IC-R MB&T v. Champion, ct al. 

Settlement and Release Agreement 

the FDlC~R, for itself and its successors and assigns, hereby releases and discharges: 

The Settling Defendants and their respective heirs, executors, trustees, administrators, 

representatives, successors, and assigns, from a11y and all claims, demands, obligations, damagest 

actions, and causes of action~ direct or indirect, known and unknown, in law or in equity, 

belonging to the FDIC-R, that arise from or relate to, the performance, nonperformance, or 

manner of perfonnance of the Settling Defendants' respective functions, duties and actions as 

officers and/or directors ofthe Bank, including without limitation the causes of action alleged in 

the D&O Action. 

B. The Settling Defendants' Release. 

Eficctivc simultaneously with the release granted in Section Ul.A. above, the Settling 

Defendants, on behalf of themselves individually, and their respective heirs, executors, trustees, 

administmtors, agents, representatives, attorneys, successors, and assigns, hereby release and 

discharge the FDIC-R, and its employees, officers, directors, representatives, attorneys, 

successors and assigns, from any and all claims, demands, obligations, damages, actions, and 

causes of action, direct or indirect, known and unknown, in law or in equity, that arise from or 

relate to, the Bank or to the performance, nonperformance, or manner of perfonnance of the 

Settling Defendants' respective functions, duties and actions as officers and/or directors of the 

Bank, including without limitation the causes of action alleged in the D&O Action. 

C. Exceptions from Releases by FDIC-R. 

1. Notwithstanding any other provision of this Agreement, the FDIC-R does 

not release, and expressly preserves fully and to the same extent as if this Agreement had not 

been executed, any claims or causes of action: 

a. Against the Settling Defendants or any other person or entity for 

liability, if any, incurred as the maker, endorser or guarantor of any promissory note or 

indebtedness payable or owed by ib.em to FDIC-R, the Bank, other financial institutions, or any 

other person or entity, including without limitation any such. claims acquired by FDIC-R as 

successor in interest to the Bank or any person or entity other than Bank; and 

4 
FDIC-R MB&T v. Champion, ct aL 

Settlement and Rl}tcasc Agre~mcnt 

b. Against any pcr:'lon or entity not expressly released by the FDlC-R 

in this Agreement. 

2. . Notwithstanding any other provision of this Agreement, nothing in this 

Agreement shall be construed or interpreted as limiting, waiving. releasing, or compromising the 

jurisdiction and authority of the Federal Deposit lnsurance Corporation in the exercise of its 

supervisory or regulatory authority or to diminish its ability to institute administrative 

enforcement or other proceeding~ seeking removal, prohibition, or any other relief it is 

audt.orized to seck pursuant to its supervisory or regulatory authority against any person. 

3. Notwithstanding any other provision of this Agreement, this Agreement 

does not purport to \"'"c:li ve, or intend to waive, any claims that could be brought by the United 

States through the Deprutment of Justice, the United States Attorney's Office tor any federal 

judicial district, or any other department or agency of the United States as defined by 18 U.S.C. § 

6. In addition, the FDIC-R specifically reserves the right to seek court-ordered restitution 

pursuant to the relevant provisions of the Mandatory Victims Restitution Act, 18 U.S.C. §§ 3322 

and 3663 et. ~ if approp.riate. 

D. Express Reservation of Rights of Bond Carrier. 

1. Notwithstanding any other provision of this Agreement, nothing in this 

Agreement shall release or prejudice the rights of St. Paul Mercury Insurance Company or any 

other underwriter of any financial institution bond, fidelity bond, or banker•s blmtket bond on 

which the Bank is an insured, to bring any claims by way of subrogation to the claims of the 

FDIC-R, against (a) any directors, officers, or employees of the Bank, including but not limited 

to the Se~ling Defendants, in their capacities as <lircctors, officers, or employees of the Bank or 

in any other capacity, or (b) any other individual or entity. 

2. Nothing herein shall be construed to admit the existence of, or to establish, 

any claim or cause of action on the part of St. Paul Mercury Insurance Company or any other 

bond underwriter by way of subrogation to claims of the FDIC·R. that would not exist bad this 

Agreement not been executed. 

5 
FDIC·R. MB&T v. Champion, ct al. 

Settlement and Release Agreement. 

SECTION IV: Waive•· of Dividends and Proceeds from Litigation 

To the extent, if any, that Settling Defendant'> are or were shareholders of the Bank or its 

holding company and by virtue thereof arc or may be entitled to a dividend, payment, or other 

distribution upon resolution of the receivership of the Bank or pn1ceeds in any litigation that has 

been or could be brought against the I~cdcral Deposit Insurance Corporation in any capacity or 

against the United States based on or arising out of, in whole or in part, the closing of the Bank, 

or any alleged acts or omissions by the Federal Deposit Insurance Corporation in any capacity, 

the United States government, or any agency or department of the United States government in 

connection with the Bank, its conservatorship, or receivership, Settling Defendants hereby 

knowingly assign to the FDIC~R any and all rights, titles, and interest in and to any and all such 

dividends, payments, or other di~tributions, or proceeds. 

SECTION V: Representations and Acknowledgement.~ 

A. Authorized Signatories. All of the undersigned. persons represent and warrant that 

they are Parties hereto or are authorized to sign this Agreement on behalf of the respective Party, 

and that they have the full power and authority to bind S\lch Party to each and every provision of 

this Agreement. This Agreement shall be binding upon and inure to the benefit of the 

undersigned Parties and their respective heirs, executors, trustees, administrators, representatives, 

successors and assigns. 

B. Advice of CounseJ. Each }>art~ hereby acknowledges that he, she, or it has 

consulted with and obtained the advice of counsel prior to executing this Agreement, and that 

this Agreement has been explained to that Party by his or her counsel. 

C. Financial Disclosure Representation. Each Settling Defendant hat; submitted 

financial infonnation to the FDIC-R including sworn Personal Financial Statements, dated May 

16,2016 from Rebecca Champion; June 26,2013 from Larry D. Coleman; June 17,2013 and 

May 26,2016 from Trae Dorough; May 9, 2016 ftom John Falk; May 13,2016 from Michael 

Gunter; June 25,2014 and May 20,2016 from Gregory A. Monis; May 11,2016 from Lloyd E. 

Moses; May 3, 2013 from Thomas A. Peterson III; May 16,2016 from Miller P. Robinson; May 

6 
FDIC-R MB&T v. Champion, et al. 

Settlement and Release Agreement 

20,2016 from John L. Robison, Jr.; and May 13, 2016 from John Tyson; and each Settling 

Defendant here.in aftirms that his/her financial information is true and accurate as of the date of 

this agreement. Each Settling Defendant expressly acknowledges that, in detennining to settle 

the claims released herein, the FDIC-R has reasonably and justifiably relied upon the accuracy of 

the financial infonnation submitted by the Settling Defendants. Tho FDIC-R bas no obligation 

to independently verify the completeness or accuracy of that financial infot1nation. lfthe FDlCR establishes via a final adjudication in an appropriate judicial forum that a Settling Defendant 

failed to disclose any material interest, legal, equitable, or beneficial, in any asset, that Settling 

Defendant agrees to cooperate fully with the FDIC-R to provide updated financial intonnation 

and to pay to the f.'DICRR the lesser of ( 1) the value of the Settling Defendant's undisclosed 

material interest in such asset(s); or (2) the amount of unpaid damages alleged against that 

Settling Defendant. 

SECTION VI: Reasonable Coopera~on 

A. The Parties agree to cooperate in good faith to effectuate all the terms and 

conditions of this Agreement, including doing, or causing their agents and attorneys to do, 

whatever is reasonably necessary to eftectuate the signing, delivery, execution, filing,.recording, 

and entry, of any documents necessary to conclude the D&O Action and to otherwise pertonn 

the terms of this Agreement. 

B. The Settling Defendants agree to cooperate fully with the FDIC-R in connection 

with any action required under this Agreement. Such cooperation shall consist of: 

1. Producing all documents requested by the FDIC-R, without the necessity 

of subpoena, as detennincd by the FDlC-R, in its sole discretion, to be relevant to the Bank; 

2. Appearing as requested by the FDIC-R at reasonable times and places for 

interviews regarding facts, as determined by the FDIC-R in its sole discretion, to be relevant to 

the Bank; 

3. Testifying as requested by the FDIC-R, without the necessity of a 

subpoena, in any matter relevant to the Bank, as dctennined by the FDIC-R; 

7 
(b)(6) 

FJ)IC-l{ MR&T v. Chatnp ion, \ll al. 

Settlement and Release Agreement 

4. Signing truthful affidavits, regarding any matter, as determined by the 

FDIC-R in its sole discrcti.on, to be relevant to the Barik. 

SECTION VII: Other Matters 

A. No Admissio.rt9fl.J.@ili!x. The undersigned Parties each acknowledge and agree 

that the matters set forth in this Agreement constitute the settlement and conxpromisc of disputed 

claims and defenses, thatthis Agreement is not an admission or evidence of liability or infim1ity 

by any ofthcm regarding any claim or defense, and that the Agreement shall not be offered or 

received in evidence by or against any Party except to enforce its terms. 

B. Execution in Counterparts. This Agreement may be executed in counterparts by 

one or more of the Parties and all such counterparts when so executed shall together constitute 

the fmal Agreement, as if one document had been signed by all Parties; and each such 

counterpart, upon execution and delivery, shall be deemed a complete original, binding the 

Parties subscribed thereto upon the execution by all Parties to this Agreement. 

C. Choice of Law. This Agreement shall be interpreted, construed and enforced 

according to applicable federal law, or in its absence, the laws of the State of Georgia. 

D. Notices. Any notices required hereunder shall be sent by registered mail, tirst 

class, return receipt requested, and by email, to the following: 

............................. " ...................... . 

If to the FDIC·R: 

Barbar& Slott Pegg 

Counsel, Federal Deposit Insurance Corporation 

3501 Fairfax Dr., # B-7062 

Arlington, VA 22226 

·········· ········· ····-····· ., .. -l-·--- I 

and 

Alan Curley 

Robinson Curley & Clayton, P.C. 

300 South Wacker Drive, Suite 1700 

Chicago, Illinois 60606 

(b)(6) ------lt======---_j 

8 
(b)(6) 

FDJC-R MB&T v. Champion, ct al. 

Settlement and Release Agreement 

If to the Settling Defendant<:: 

Patrick T. O'Connor 

Oliver Maner, LLP 

P.O. Box 10186 

Snvannah, GA 31412 

and 

Danjel B. Snipes 

Taulbee, Rushing, Snipes, Marsh & Hodgin 

P.O. Box 327 

Statesboro, GA 30458 

E. E..ntire Agreement and Amendments. This Agreement constitutes the entire 

agreement and understanding between and among the undersigned Parties concerning the matters 

set forth herein and supersedes any prior agreements or understandings. This Agreement may 

not be amended or modified, nor may any of its provisions be waived, except in writing signed 

by the Parties bound thereby, or by their respective authorized attomey(s), or other 

representative( s ). 

F. Titles and Captions. All section titles and captions contained in this Agreement 

are for convenience only and s.ball not affect the interpretation of this Agreement. · 

G. No. Confidentiality. The undersigned Parties acknowledge that this Agreement 

shall not be confidential and will be disclosed pursuant to the Federal Deposit Insurance 

Corporation's applicable poJicies, procedures, and other legal requirements. 

IN WI1NESS WHEREOF, the Parties hereto have caused this Agrt.-emcnt to be executed 

by each ofthem or their duly authorized representatives on the dates hereinafter subscribed. 

FEDERAL DEPOSIT INSURANCE CORPORATION AS 

RECEIVER FOR MONTGOMERY BANK & TRUST, 

AILEY GEORGIA 

9 
(b)(6) 

FDIC-R MB&T v. Chmnpion, et al. 

Settlement and Release Agreement 

SED'LING DEFENDANTS 

{c, - /3_::_j_{~· ·. REBECCA CHAMJ>JQN 

•• f...____ ~~ ---nDate: 

PRlNT NAME: Rc-6 e cc:.& C ~v. 01fl.4 ~--

Date: LARRY D. COLEMAN 

- -------······---------

PRTNTNAME: - ----------

Date: TRAE DOROUGH 

PRINT NAME: - --- ------

Date: JOHNFALK 

PRINT NAME: ----- - --·-· 

Date: MICHAEL GUNTER 

10 
(b)(6) 

FDIC-!{ MB& Tv. Ch;unpillll, d al. 

Scnknwnl and Rl~lcas~- t\grc:cmt:nt 

I )ate: 

Date: 

Date: 

Dat~: 

Date: 

SETTLING Dfo:FF~J>t\NTS 

REBLCCA CliAMP!Ot\ 

PHII\T NAME: 

I.1\KRY D. COLEMAf\ 

PRf\'T NA;vll·:: __ _ 

TR/\E IJOROUCil I 

PRINT NA:vlE: 

iVIICI-l/\EI, CHIN I 1-:R 

PRINT NAME: 

(;RFUORY /\. tv!Ol<RIS 

PRINT Nt\l'v!E: __ _ ---------

IO 
FDIC-R MB&T v. Champion, et aL 

Settlement and Release Agreement 

Date: 

Date: G-13-lb 

SETILING DEFENDANTS 

REBECCA CHAMPION 

PRINT NAME: --------------------

(b)(6) .......................................................................................................................................................................................... 1 .......................................................................................................................................................... 

Date: TRAE DOROUGH 

PruNTNAME: _____________ ·------

Date: JOHNFALK 

PRINTNAME: --------

Date: MICHAEL GUNTER 

PRJNTNAME: ---------------------

Date: GREGORY A. MORRIS 

PRlliTNAME: _________________ __ 

10 
(b)(6) 

FDIC-R MB&T v. Champion, et al. 

Settlement and Release Agreement 

Date: 

Date: 

Date: 

Date: 

Date: 

c-1 ... ··-,. :<0 /~1 

............................................................................................................................... 

Date: 

SETTLING DEFENDANTS 

REBECCA CHAMPION 

PruNTNAME: __________________ _ 

LARRY D. COLEMAN 

PRINT NAME: --------------- ___ _ 

TRAEDOROUGH 

PRINT NAME: __________________ __ 

JOHNFALK 

PruNTNAMffi: ______________ . ___ __ 

PRINT NAME: j/1; t. f? /} e 

GREGORY A. MORRIS 

PRINT NAME: 

--------------------

10 
FDlC-lt MB&T v. Champion, et nl. 

Settlem~nt nnd Release Agreement 

Date: 

Date: 

Date: 

SETI'LING DEFENDANTS 

- ----------·---·-····-· 

PR!NT NAME: ·····-··--··--·--------- ... ... .. . 

LARRY D. COLEMAN 

PRINT NAME: 

TRAE DOROUGH --:: .. , 

(~~) ~-----~--~~ -~~~~~~~~~---~~~~~J _ ~~ ~r._~•. -.=~---- PRJNT NAME: /;-c.."-- v .:L -; . ~-" ""-

' 

Date: ----..... -- - -- JOHNFALK 

PRINT NAME: __ ......... ~-··-·--·---. 

Date: MICHAEL GUNTER 

----- ....... ............. ·-····---·-·-·------

PRINT NAMb: 

Date: GREGORY A. MORRIS 

PJUN'.l' NAME: ------· .. ···--·---·------.. -·-- .. -·. 

]() 
FDIC-R. MB&T v. Champion, et al. 

Settlement and Release Agreement 

Date: 

Date: 

LLOYD E. MOSES 

PRINT NAME: -----------------------

1HOMAS A. PETERSON III 

PRlliiTNAME: __________________ __ 

(b)(6

) Date: ~-t..fl. /3, 7.J:J /{; 

-------- -------- ---------

Date: JOI-IN L. ROBISON, JR. 

PRINT NAME: -----------------------

Date: JOHN TYSON 

PruNTNAME: __________________ __ 

11 

. 
(b)(6) 

(b)(6) 

FDIC-R MB&T v. Champion, et al. 

Sctllcrncnt and Re lt ~c t\gmemcnl 

Date: rsj /~ 

........... ............................................................ L ............................ LLOYD E. MOSES 

Date: b -3 -2.~ /" THOMAS A. PETERSON Ill C'J 

-- - 1-- I 

PRINT NAME: Tht>lff/f-S fl, p~~~.t.!., ~ 

Date: - --- ---· . .... MILLER P. ROBINSON 

PRlNT NAME: - ---- --- - -

(b)(6) - n:_~ ~=~~ I !OHN L. ROBISON, JR. l 

-. ~~==-JP~L.? Iai~~ J;--6 

(b)(6) 

Date: -·-- -· ~ .. ~ \ L1 \ JOHN TYSOl)T 

..................... lr--- - -----,t 

., ..-.-. PRINTNAME: j;~ \N }i_i~~ .::... f ___ _ 

I I 
FDIC-R M13&T v. Champion, et al. 

Settlement and Release Agreement 

IN THE UNITED STATES DISTRICT COURT 

FOR THE SOUTHERN DISTRICT o-..· GEORGIA 

DUBLIN DIVISION 

FEDERAl, DEPOSIT INSURANCE 

CORI). as Receiver for Montgomery 

Hank & Trust, Ailey, Georgia, 

Plaintiff, 

v. 

REBECCA CHAMPION, et al., 

Defendants. 

) 

) 

) 

) 

) Civil Action No. 3:15-eV-58-.IRH-BKE 

) 

) 

) 

) 

) 

) 

STIPULATION OF DISMISSAL WITH PRE;JUDICE 

Plaintiff Federal Deposit Insurance Corporation, as Receiver for Montgomery Bank & 

Trust, Ailey, Georgia, ("FDIC-R)'), and Defendants Rebecca Champion, Larry D. Coleman, Trae 

Dorough, John .Falk, Michael Gunter, G1·egory A. Morris, Lloyd E. Moses, Thomas A. Peterson 

lll, Miller P. Robinson, John L. Robison. Jr., John Tyson (collectively with FDIC-R, the 

"Parties"), by and through their respective undersigned attorneys, and pursuant to Fed. R. Civ. P. 

41(a)(l)(A)(ii), hereby stipulate to the dismissal of this action with prejudice) with the Parties to 

each bear their own attorney's tees, costs, and expenses incurred in this action. 

Dated this ___ day of __ , 2016 

EXHIBIT A 

12 
(b)(6) 

(b)(6) 

FDlC-R MB&T v. Champion, ct at. 

Settlement und Rclt:a~c Agreement 

ROBINSON CURLEY & CLAYTON, P.C. TAULBEE, RUSHING, SNIPES, MARSH & 

HODGIN, LLC 

Alan F. Curley (Pro Hac Vice) 

Illinois Bar No. 6190685 

300 South Wacker Drive, Suite 1700 

Chicago, Illinois 60606 

(312) 663M3l 00-telephone 

....................... (3.J .. 2}6.§.3.:0303:::J:a.csi.mile 

l--·········· ................ . 

Daniel B. Snipes 

12 Siebald Street 

Statesboro~ Georgia 30458 

(912) 764-9055- telephone 

(912) 764-8687 - iasc.imile 

·····························IL--------------------_-----------_-----------_------___ __. 

Atlorneysfor Defendant Dorough 

BOUHANFALLIGANTLLP Q 

Todd M. Baiad -/) .. 

Georgia Bar No. 031605 ~~L,.;=:l....,V~E~M~A~N:;..:;·.v; =··R~ .. ,..~...:.b=.=±r:a:/"--..:;..;...,'-.......,------. 

(b)(6) L~a.,~R-~Ilr~<:ll~y ·1--------

Georgia Bar No. 672136 _ P.O. Box 2139 L::P=-a-tn":"'".c":""k-=T=-. -=o":"")c=-o-nn-or--------...1--

Savannah, Georgia 31402-2139 Paul H. Threlkeld 

(912) 232-7000- telephone 218 West State Street 

(912) 233-0811- facsimile' Savannah, Georgia 31401 

(b)(6) ··l HOH 1 c~g) ;~~:~~~~ =}~~:~: (b)(6) 

(b)(6) 

SHINGLER LEWIS, LLC 

George Shingler 

Georgia Bar No. 642850 

1230 l'eachtree Street, Suite 1075 

Atlanta, Georgia 30309 

( 404) 907-1999 -telephone 

.............. 1 .............................. 

Attorneys for Plaintijj; l'DIC-R 

d.tJ..Qrneys for Defendants Rebecca Champion, 

Larry D. Coleman, John Falk, Michael Gunter, 

Gregory A. Morris, Lloyd R Moses, Thomas A. 

Peterson Ill, Miller P. Robinson, John L. Robison, 

Jr., John Tyson 

l3 
(b )(6) 

(b)(6) 

(b)(6) 

!l[)}C-K .MB &T v. Champion, cl al. 

Settlement und Rcle.-ue Aereement 

ROl3lNSON COlZLEY & CLAYTON, P.C. TAULHEE, RUSHfNG, ~NII' S, MARSH & 

Alan F. Curley (Pro Hac Vice) 

Illinoi~ l3nr No. 6190685 

300 South Wacker Drive, Suite 1700 

Chicl\go, Illinois 60606 

(312) 663-3 100 · telephone 

·········r: l::?::~ ~~ ~~ -· ··facsi mile m ...................... 

BOUHAN FA LLIOANT LLP 

Todtl M . .Baiad 

Georgia Bur No. 031605 

Lucas D. l3radlcy 

H DG LLC 

td B. Snipe~ 

·12 Siebald Streel 

Statesboro, Georgia 30458 

(912) 764-9055- telephone 

(912) 764-8687 - fascimile 

1-······· 

~--------------------~ 

Attorneys for nejendant Domugh 

OLIVER MANER, LLP 

Georgia Bar No. 6721 36 _ .. . ·--,----

P.O. Dox. 2139 Pedrick T. O'Com1or 

Savannah, Georgia 31402-2139 Paul H. Threlkeld 

(912) 232-7000·- telephone 118 West Stare Street 

(9 I 2) ?.3 3-0811 · facsimile' Savannah, Georgia 3140 I 

;:~;:~ -1- ~~m ~~~:~~~; = ~~~E~~: .................................................................................................................... I I 

(b)(6) 

······················································································································ ....................................................................... . 

SHINGLER LEWI~. LLC _ .. 

George Shingler 

Georgia nar No. 64?,850 

1130 Pcadttrcc Street, S·uitc l 075 

ALhtHin, Georgia 3()309 

f404 907-1999- telephone 

Attvmeys for Plaintiff. FDIC-R 

Atroroeys fur fd.r; ndants Rebecca Champion, 

Larry D. Coleman, .fohn Falk, Michael Gunter. 

Gregory A. Morris, /,loyd E. Moses, Thomas A. 

Peterson Ill, Miller P. Robinson, John L. Robison, 

Jr., .John 'J'yson 

13