IN THE CIRCUIT COURT OF TENNESSEE FOR THE THIRTIETH JUDICIAL DISTRICT AT MEMPHIS DAVID YOUNG, as father and Personal Representative of the Estate of ELLIE CLAIRE YOUNG, deceased, Plaintiff, v. JACKSON HOPPER and MARTHA. HOPPER Deféndants. VERIFIED COMPLAINT AND FIRST REQUEST FOR INJUNCTIVE AND OTHER EQUITABLE RELIEF COMES NOW Plaintiff David Young, as father and Personal Representative of the Estaté T of Ellie Claire Young, deceased, and files this Verified C ‘omplaint against Defendants Jackson Hopper and Martha Hopper for the wrongful death of Bie Claire Young on October 19, 2024, and for other damages on behalf of all wrongful death| beneficiaries. Plaintiff also seeks the injunctive relief set forth below. In support of this Complaint, Plaintiff and states as follows: 1. INTRODUCTORY STATEMENT, fe This lawsuit arises out of the senseless death of Ellie Claire Young (hereinafter “Ellie”) who was brutally and intentionally killed by her former boyfriend, Jackson Hopper, on or about October 19, 2024. 2 Plaintiff David Young brings this action as|Ellie’s surviving father and the personal representative of her estate on behalf of all wrongful death beneficiaries, namely he and his wife, Kim Young, who are the wrongful death beneficiaries in this matter.3. Plaintiff brings this action pursuant to Tennessee's wrongful death statutes, and any } other applicable statutory and/or common law authority. 4, Although the family is in early stages of grief for the loss of their remarkable daughter, Plaintiff brings this action on behalf of himselfand his wife (and any other wrongful death beneficiaries who may exist) at this time due to copcems that Defendant Jackson Hopper may dissipate, obfuscate, transfer, waste or otherwise conceal assets which may be available to satisfy any wrongful death judgment this family obtains in this matter. Plaintiff is also concerned that Defendant Jackson Hopper may attempt to use funds that he recently inherited to make a bond and flee this country to avoid criminal prosecution for his heinous acts and Plaintiff is before the Court to prevent him from doing anything that will allow him to avoid having to face the charges I that have been brought against him. | | 5. Defendant Jackson Hopper inherited a significant amount of real property in Lake County, Tennessee and perhaps in other counties as well'after his grandfather died and Plaintiff has confirmed that Hopper sold part or all of his interest in this inherited property to his uncle for over $3,000,000 in April of 2024. Plainti is asking this Court to enter an order enjoining Defendant Jackson Hopper from dissipating, obfuscating, transferring, concealing or spending these flinds for anything other than ordinary living expenses and to the extend that Defendant Jackson Hopper has already transferred some or all of the funds he received from the sale of this inherited property or that he had from other sources to pis mother, Defendant Martha Hopper, Plaintiff is asking this Cour to likewise enjoin her frorh dissipating, obfuscating, transfering, concealing or spending these funds for anything other thah ordinary living expenses. 6. Upon information and belief, Defendant Jackson Hopper has already utilized some of these funds to retain Leslie Ballin to represent him with regard to the pending criminal charges 2that have been filed against him and assuming that Hopper paid Ballin a fair and reasonable amount for Ballin’s services, Plaintiff has no objection to Hopper utilizing a portion of these funds to retain Ballin. 7. Plaintisf believes that Defendant Jackson Hopper deposited funds from the sale of the inherited land in an account at Charles Schwab & Co., Inc. and/or another financial institution in Lake County or one of the other counties in Tennessee and Plaintiff is further asking this Court to enjoin any financial institution where Hopper has funds from allowing anyone to transfer or withdraw funds from any such account until further order dems Cour, nm Parties | 8. Plaintiff David Young is an adult resident of Henning, Tennessee, and is before the Court in his capacity as father and Personal Representative of the Estate of Ellie Claire Young, deceased to recover all available damages for the personal injuries and ultimate death of his daughter as a result of the acts of Defendant Jackson Hopper and the acts and/or omissions of Defendant Martha Hopper as set forth herein, Plaintiff brings this action on behalf of all wrongful death beneficiaries of Ellie Claire Young. Ms. Young was unmarried at the time of her death and is survived by her parents and her sister. 9. Defendant Jackson Hopper is an adult resident citizen of Lake County, Tennessee, and may be served at the Shelby County Jail, 201 Poplar Avenue, Memphis, Tennessee 38103 or 975 Lake Drive, Tiptonville, Tennessee 38079. 10, Defendant Martha Hopper is an adult resident citizen of Lake County, Tennessee, and may be served at 975 Lake Drive, Tiptonville, Tennessee 38079. Defendant Martha Hopper is the mother of Jackson Hopper and upon information and belief, she was aware of his prior violent tendencies and lied to Ellie's family when they expressed concems that Jackson Hopper was 3posing a dangerous threat to Ellie. Defendant Martha Hopper, upon information and belief, knew that her son had engaged in similar dangerous conduct with other girlfriends and failed to share this information with Ellie's family when they told her that they were going to get a restraining order against Jackson Hopper because of his assaultive behavior and because of their fear that he would escalate his violence with Ellie, Defendant Marthal Hopper urged Ellie’s family not to get restraining order and assured them that her son had never hurt anyone and would never hurt Elli. Plaintiff believes tht Defendant Martha Hopper wil asist her son in hiding and/or spending assets at his request and fears that she may have already done $0 and is asking this Court to likewise enjoin her from transferring any assets of her son. Moreover, Defendant Martha Hopper, upon information and belief, also recently inherited property and/or funds and Plaintiff is before the court likewise enjoin her fom dissipating, obfuscating, tansfersing, concealing or spending any funds for anything other than ordinary living expenses. I. JURISDICTION AND VENUE 11. This Court has jurisdiction pursuant to inter alia, T.C.A. § 16-10-101. 12. Venue is proper in this Court pursuant to inter alia, T.C.A. § 20-4-101, because all or part of this cause of action arose within Shelby County! Tennessee. 13. This action is being brought pursuant to Tennessee’s Wrongful Death statutes (including but not limited to T.C.A. §§ 20-5-106—107), and all other applicable laws, both statutory and common law. IV. “FACTS AND ALLEGATIONS 14, Ellie Claire Young gradwated from the University of Tennessee at Martin (UT- Martin) with honors in May of 2024 and was accepted to Start medical school atthe University of Tennessee Center for Health Sciences in Memphis in August of this year. While a student at UT- 4Martin, Ellie dated Defendant Jackson Hopper. | 15, Plaintiff and his family teated Defendant Jackson Hopper as part of their family while he dated Ellie, While the two were dating, Defenddnt Jackson Hopper’s grandfather died and left him a considerable amount of land. Plaintiff knows this information because Defendant Jackson Hopper told Elie and her family about his inheritance. 16. After Ellie graduated from UT-Martin, Defendant Jackson Hopper made it clear that he did not want Ellie to move to Memphis and their feltonship changed. Hopper became aggressive and controlling and engaged in assautive behavior on more than one occasion in April and May of 2024, which led to Ellie breaking up with him! 17. When Ellie's family leamed about the astaultive behavior, they inquired about getting a restraining order against him. Prior to asking a court to enter an order of protection against Hopper, one of Ellie’s family members contacted Defendant Martha Hopper on Ellie’s behalf to tell her about the family’s concerns. Defendani! Martha Hopper advised Ellie’s family member that a restraining order would not be necessary because (a) Jackson had never hurt anyone and would never hurt anyone and (b) Jackson had moved fo middle Tennessee and was getting on with his life, Defendant Martha Hopper assured Ellie’$ family member that her son was not anywhere Ellie and that they did not need to worry about|him hurting her. Plaintiff now believes that Martha Hopper was lying when she made these statements and that she was just trying 10 protect her son from potential criminal charges. Ellie ant her family relied on Martha Hopper’s statements to their detriment and decided not to ask @ judge for an order of protection against Jackson Hopper based on the false assurances of Defendant Martha Hopper. 18. Onorabout Ociober 19,2024, Decedent Elie Claire Young drove to Shelby Farms Park to meet a friend to go for a walk in the park. Afterparking her vehicle, Defendant Jackson 5Hopper, according to court documents, pulled right behind Ellie’s vehicle, got out of his car and started shooting a 9 mm weapon multiple times at Ellie. Defendant Jackson Hopper, according to court documents, then got back in his vehicle and fled the cene of this heinous murder. 19, Billie was found dead on the ground where she fell after being shot multiple times. 20. According to court documents, Defendant Jackson Hopper, after fleeing from the scene, was eventuelly caught by Jaw enforcement officers 21. When Defendant Jackson Hopper was arres mm handgun at the scene of his arrest and at the scene of found five 9 mm shell casings near Ellie's body. and charged with first-degree murder. ted, law enforcement officers found a 9 ' the murder, law enforcement officers 22. Plaintiff recognizes that Defendant Jackson Hopper is entitled to a trial by jury to determine his guilt in this matter but asserts that given the ‘above facts, there is a strong likelihood that Plaintiff will be successful on the merits of this civil claim and that all of the factors set forth in Rule 65 of the Tennessee Rules of Ci relief sought in this Complaint. I Procedure support the Court granting the injunctive 23. _ Ellie was a kind, loving, friendly, selfless, and caring person with an incredibly bright future ahead of her. 24. Ellie was the valedictorian of her high sch the university she attended. 25. At the time of her death, Ellie was a 22-y University of Tennessee Health Science Center. 1 class and graduated with honors from old first year medical student at the 26. Approximately, two months earlier, Ellie ad received her “white coat” at a medical school ceremony, at which time she began the fulfillment of her dream to attend medical school and care for patients as a physician,27. Upon information and belief, Defendant Martha Hopper was aware that Defendant Jackson Hopper had been physically abusive with at least three prior girlftiends, and they were in fear for their lives after the relationships ended. 28. Ellie had no knowledge of his violent history with multiple other women. 29. Had Defendant Martha Hopper informed el and her family of her son’s abhorrent history of verbal and physical violence with multiple young women, Ellie would have insisted on seeking an order of protection and taken other measures to protect herself from Defendant Jackson Hopper. 4 30. When Martha Hopper assured Ellie's family member that Jackson Hopper would never harm Ellie, she, upon information and belief, knew about her son’s past behavior and should have known that her son had the propensity to injure Ellie! both mentally and physically. 31. Despite assuring Ellie and her family that they did not need to worry about Jackson Hopper hurting Ellie, Defendant Martha Hopper, upon information and belief, did not take any action to keep Jackson Hopper away from Ellie. | 32. Asa foreseeable result of the wrongful conduct of the Defendants including, but not limited to, the acts and omissions described herein, Ellie experienced extreme pain and suffering, emotional distress, loss of future earnings, loss bf the enjoyment of life and loss of life. 33. Asa foreseeable result of the wrongful conduct of the Defendants including, but not limited to, the acts and omissions described herein, Eilfe’s parents, David and Kim Young have suffered the loss of their beautiful daughter, and the loss of her love, companionship, relationship, and consortium, V. CLAIMS AGAINST DEFENDANT JACKSON HOPPER FOR ASSAULT, BATTERY, INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS AND. WRONGFUL DEATH 734. The allegations set forth in the previous paragraphs are incorporated herein by reference. 35. Defendant Jackson Hopper intentionally and knowingly caused Ellie to fear imminent bodily injury in the months leading up to her death and on the day of her death. 36. Defendant Jackson Hopper intentionally dttempted to do harm to Ellie in the months leading up to her death and on the day of her death 37. Defendant Jackson Hopper intentionally shot and killed Ellie on October 19, 2024, without any provocation and/or justifiable basis to do so. ‘ 38. Defendant Jackson Hopper’s verbal and physical conduct towards Ellie prior to her death was so outrageous that it cannot be tolerated by civilized society and his actions on October 19, 2024, shocked the collective conscious of this community. 39. Defendant Jackson Hopper’s conduct was so outrageous in character and so extreme in degree as to go beyond all bounds of decen 40. Defendant Jackson Hopper's conduct was in all respects atrocious and utterly intoterable. Al. Defendant Jackson Hopper intentionally} caused Ellie to suffer extreme fear, emotional distress and mental harm. 42. EEllie’s death was directly and proximately caused by Defendant Hopper's wrongful, unlawful, tortious, dangerous, and deadly condvct. 43. Inlight of the foregoing, Defendant Jackson Hopper is liable for the following torts and causes of action: a, Assault;b. Battery; c. Intentional infliction of emotional distress; and 4. Wrongful death. 44. All of Ellie’s harms, damages, injuries, a factually, proximately, and foreseeably caused by the wro and generelly described herein. ind ultimately her death was directly, eful acts which have been specifically 45, Defendant Jackson Hopper’s actions warrant an award of both compensatory and punitive damages in this case. IHOPPER FOR NEGLIGENCE, VI. CLAIMS AGAINST DEFENDANT MARTHA \ NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS, INTENTIONAL MISREPRESENTATION, NEGLIGENT MISREPRESENTATION AND WI ATI 46. The allegations set forth in the previous paragraphs are incorporated herein by reference. | 47. Martha Hopper owed a duty of care to Ellie and breached that duty directly and proximately causing great harm. 48. Martha Hopper had a duty to use reasonal Defendant Jackson Hopper. 49. Atall applicable times, Martha Hopper st le care to protect Ellie from her son, din a special relationship with her son, 50. tall applicable times, Martha Hopper likewise stood in a special relationship with Ellie Claire Young. 51. Atall applicable times, Martha Hopper Had the authority, means and ability to control the actions of her son, Defendant Jackson Hopper! 52. Atal applicable times, Defendant Jacksdn Hopper was dependent upon MarthaHopper for financial, emotional, and residential support des ite the fact that he had just inherited millions of dollars in property prior to engaging in the conduct that is the subject of this complaint. 53. Atal applicable times, Martha Hopper, ugon information and belief, was aware that Defendant Jackson Hopper had a violent past, particularly towards young women with whom he had relationships. Moreover, upon information and belief, she knew he had access to a firearm. 54, Atell applicable times Martha Hopper, upor information and belief, was aware that Defendant Jackson Hopper was unwilling to accept the breakup between him and Ellie and that he continued to pose a threat to her in the weeks and months leading up to her murder. 35. Martha Hopper undertook and assumed tig responsibility, in exchange for Ellie's agreement not to take legal action against her son, to takelreasonable steps to ensure that her son would not harm Ellie. | 56. By way of altematve pleading, Mathg Hopper gratuitously undertook and assumed the responsibility to take reasonable actions to protect Ellie from her son. 57. Atthe time she stated to Ellie and her family that there was “no way” her son would harm Ellie, or words to that effect, Martha Hopper knew of should have known that statement was false in light of her knowledge of violent past towards young women and considering her knowledge about his unwillingness to accept that his relatjonship with Ellie was over. 58. Martha Hopper was in a superior position to know and understand the extent to which her son was violent and how enraged he was over the breakup of his relationship with Ellie. 59. Martha Hopper failed to take reasonable measures to protect Billie from her son. 60. Martha Hopper was aware of should have been aware that Ellie was facing danger at the hands of Defendant Jackson Hopper, yet Ms. Hopper failed to wam Ellie of such danger. 61. The representations made by Martha Hopper to Ellie and her family: 10a. Related to existing and/or past facts; | b. Related to one or more material facts; c. Were made knowingly or without beliefjin their truth; and/or 4d. Were made recklessly. 62. By way of altemative pleading, the representations made by Martha Hopper were made negligently in violation of a duty of care owed to Ellje and her family. 63. Ellie and her family reasonably relied upon the assurances and representations of Martha Hopper. | 64, Ellie and her family have suffered immensely by the misrepresenttions of Martha Hopper and their reliance thereon. 65, It was reasonably foreseeable that Ellie would endure all of the harms and damages she suffered including but not limited to significant pain ahd suffering, severe emotional distress, and loss of life, asa result of this Defendant’s intentional, circles, and reckless acts and omissions. 66. _Inlight of the foregoing, Defendant Marths Hopper is lable for the following tots and causes of action: a. Common law negligence; b. Gross negligence; | c. Negligent infliction of emotional distress; 4. Intentional misrepresentation; e. Negligent misrepresentation; and £ Wrongful death. 67. All of Ellie’s harms, damages, injuries, and ultimately her death was directly, factually, proximately, and foreseeably caused by the wrongful acts which have been specifically uland generally described herein. As with her son, Defendant Martha Hopper’s actions inthis ease likewise warrant an award of both compensatory damages and punitive damages. Vil. DAMAGES 68. The allegations set forth in the previous paragraphs are incorporated herein by reference. 69. Asadirect and proximate result of the wrongful and tortious conduct on the part of the Defendants, Plaintiff seeks all available damages ie renee ca a any other applicable law, including those available under the Temes wrongful death statutes. Plaintiff seeks damages for Ellie’s harms and losses including, but not limited to the following: a, Pain and suffering; | b. Emotional distress and mental anguish;! ©. Loss of fiture earnings; 4. Loss ofthe pecuniary value of her lifes ©. Medical and ambulance expenses; f Funeral expenses 8. Loss ofthe enjoyment of lifes h. Loss of lifes i. Loss of consortium; and js Punitive damages. 70. Plaintiff is secking all pecuniary damageslallowable under Tennessee’s Wrongful Death Statues, Tennessee common law, Tennessee statubry law and all other applicable laws for Ellie Claire Young’s harms, damages and losses as well as her parents’ hacms, damages and losses for the loss of consortium. 12VII. LOSS OF CONSORTIUM 71. The allegations set forth in the previous paragraphs are incorporated herein by reference. 72. Asa direct and proximate result of the actions and inactions leading to Ellie's senseless and violent death, her parents, sister, and other family members have suffered the loss of the love, affection, guidance, services, and companionship! 'they had and would have continued to have with Ellie. Accordingly, Plaintiff sccks all available damages under Tennessee law for their loss of consortium. IX. PUNITIVE DAMAGE! 73. The allegations set forth in the previous paragraphs are incorporated herein by reference. 74. Defendant Jackson Hopper acted intentionally, maliciously, recklessly, criminally, reprehensibly, and egregiously. Defendant Jackson Hopps's ‘gross and wanton conduet shows he intended the result he obtained, The facts and circumstantes of this case mandate the imposition of punitive damages in an amount to be determined by. the jury in this case. Further, exemplary committing such atrocious acts in the future. For the reas Gamages are necessary to deter and hopefully prevent Defendant Jackson Hopper and others from mas set forth in this Complaint, Plaintiff also seeks punitive damages against Defendant Martha Hopper in an amount to be determined by the jury in this case. X. GROUNDS FOR EQUITABLE RELIER 75, The allegations set forth in the previous|paragraphs are incorporated herein by reference. 76. — Pursuant to T.C. A. §§ 29- 26-101 et seq.,/66-3-301 et seq. and Rules 64 and 65 of 13the Tennessee Rule of Civil Procedure, Plaintiff is entitled to a temporary restraining order, temporary injunction and other equitable relief for numerous reasons including, but not limited to, the following swom information and allegations. 77. As set forth above, Defendant Jackson Hopper brutally and intentionally killed Plaintiff's 22-year-old daughter, Ellie Claire Young. | 78. Inthe months leading up to and shortly following the separation and breakup of the relationship between ie and Defendant Jackson Hopper, Defendant Jeckson Hopper frequently discussed with Ellie and her family the fact that his grandfather left him millions of dollars worth of property upon his grandfather's passing and Plantiffhas been able to confirm that Defendant Jackson Hopper sold this inherited property to his uncle for over $3,000,000 in April of 2024 79. Upon information and belief, Defendant Jackson Hopper has substantial cash in one or more financial institutions including but not limited to an account with Charles Schwab Company, Inc. 80. Because of Defendant Hopper’s current| incarceration which could be for a prolonged period of time, the ability to secure satisfaction of a judgment from Defendant Hopper’s future earnings alone is extremely unlikely. 81. Upon information and belief, Defendant Hopper has already transferred large sums ‘of money to his criminal defense attomeys for the purpose of paying them for their services in the criminal matter pending in Shelby County and Plaintiff is\not seeking to set aside that payment as a fraudulent transfer at this time, assuming that the funds paid were reasonable in light of the charges filed in this matter, . 82, If Defendant Hopper is permitted to make additional transfers, however, or is 14permitted to dissipate, deplete, reduce or encumber his current assets, it will likely be impossible for Plaintiff to satisfy any judgment that is ultimately ae against him. 83. Based upon his behavior set forth above in this Complaint, including his extraordinary effets to avoid ames, it is clear that Defeniant Jackson Hopper will do virtually anything to avoid accountability in this matter and Plaintiff is fearful that Hopper will attempt to use the funds he inherited to make bond and flee this countty to avoid riminal prosecution for his heinous acts, which is another reason Plaintiff is secking the requested injunctive relief. 84, Plaintiff, on behalf of the wrongful death beneficiaries of his deceased daughter will suer immediate and ireparable injury ifa restraining order is not granted upon the filing of this Complaint. 85. Plaintiff respectfully submits that notice ojthe Defendants should not be required because if either of them is given advance notice, there is 4 strong likelihood that Defendants will transfer assets or otherwise render their assets unavailable|for a future execution of judgment, 86. Following the issuance of restraining ord, Plaintiff respectfully submits that his rights and the rights of all wrongful death beneficiaries will be violated by Defendant Hopper should a temporary injunction not issue upon notice to the| opposing parties. 87. Plaintiff’ seeks to limit Defendant Hopper’s use of his personal assets or any assets to which he has a beneficial interest to his normal and reasonable living expenses, Currently Defendant Hopper is incarcerated and no bond has been Set for his release so such expenditures should be minimal at this time. 88. Defendants should be prohibited, by way bf a restraining order and injunction, to the fullest extent possible, from taking any action which) would prevent or hinder Plaintiff from executing on a judgment he may obtain in this case. 1589. This is the first application for relief of this nature or any equitable relief in this cause. XI. PRAYER FOR RELIEF 90. The allegations set forth in the previous paragraphs are incorporated herein by reference. | 91. Plaintiff’ prays for relief including, but not limited to, the following: a, That proper process issue and be pul upon the Defendants and that they be required to appear and answer this Complaint wthin the time required by law; b. That Plaintiff David Young, in his representative capacity as Personal Representative ofthe estate of Elie Claire Young by awarded compensatory damages from Defendants in the amount of $10,000,000 for the wrongful death of Ellie Claire Young: ©. That Plaintiff David Young, on betilf of all wrongful death beneficiaries, be further awarded punitive damages in an appropriate amount to be determined by a jury in this cause. d. ‘That and when Plaintidf learns of personal and/or real property owned by Defendants or to which Defendants have a beneficiary interest, Plaintiff be entitled to place an attachment, lien, seizure or other restriction on Such property e. That this Honorable Court grant a temporary restraining order and temporary injunction as follows: i, Defendant Jackson Hopper is prohibited from dissipating, absconding, selling, pledging, transferring,|encumbering, or spending any money and any asset he owns or to which he has a beneficial interest, with the exception of reasonable and ordinary living expenses and is prohibited 16£ ii, iii, iv. from allowing others to do so on his behalf, Defendant Jackson Hopper is prohibited from spending any additional funds from assets he owns or to}which he has a beneficial interest for his criminal defense without seeking authorization and an Order of this Court permitting him to do so. Financial institutions that are holding funds for the benefit of Defendant Jackson Hopper shall also be rohibited from allowing withdrawals and/or transfers of funds from any such account; and financial institutions that are holding funds for the benefit of Defendant Martha Hopper for any funds deposed into such account after Defendant Jackson Hopper sold his interest in inherited land on April 8, 2024, shall also be prohibited from alloxting any funds to be withdrawn or transferred from such account. | Defendant Martha Hopper is likewise prohibited ffom dissipating, absconding, selling, pledging, transferring, encumbering, or spending any money and any asset she Owns or to which she has a beneficial interest, with the exception of reasonable and ordinary living expenses. To the extent that Defendant Martha Hopper is holding funds that she received from Defendant Jackson Hopper in the last 12 months, Defendant Martha Hopper is also prohibited from dissipating, absconding, selling, pledging, transferring, encumbering, or spending such funds or assets. ‘That at the conclusion of this matter, the temporary injunction be converted 7i to a permanent injunction until such time as any judgment entered in this matter is fully satisfied or when the case is dismissed if Defendants prevail in this matter. 8. This is the first application for equitable relief in this case. h. That under the unique circumstances of this case, bond be waived at this time for the requested equitable relief; or if not waived bond be set at a nominal amount. ‘That Plaintiff be awarded such further relief to which he and Ellie’s estate may be entitled. PLAINTIFF HEREBY DEMANDS A JURY FOR THOSE CAUSES OF ACTION WHERE THE LAW PERMITS A TRIAL BY JURY. Matth te Nay, #25547 ROSENBLUM & REISMAN, P.C. ‘Triad Centre II 6070 Poplar Ave., Suite 550 Memphis, TN 38119 Tele (901) 527-9600 Fax (901) S275 9620 [email protected] [email protected] Mark MeDaniel, Jr, #36288 ‘The MeDaniel Law Firm 243 Exchange Avenue Memphis, TN 38105 Tele (901) 527-6518 Fax (901) 527-4600 markj 18VERIFICATION STATE OF TENNESSEE COUNTY OF SHELBY 1, DAVID YOUNG, make oath and hereby state that the facts set forth in the foregoing | document ate true to the best of my knowledge and belie. Xgod David Young BEFORE ME, a Notary Public, in and for said County and State, duly commissioned and qualified, personally appeared David Young known to me to be tHe person who executed the foregoing instrument and who acknowledges that he executed the same for the purposes and consideration therein expressed. 7 i GIVEN UNDER MY HAND AND SEAL OF OFFICE this sm day of November, 2024.FIAT Issue the temporary restraining order prayed for if this Complain upon Bond being given an amount of $ and issue notice setting this matter for hearing on the day of +2024, at__o’elock_. m. 20