IN THE CHANCERY COURT OF SHELBY COUNTY, …galileememorialabuse.com/pdf/Stevens_Complaint.pdf · IN...

IN THE CHANCERY COURT OF SHELBY COUNTY, TENNESSEEFOR THE THIRTIETH JUDICIAL DISTRICT AT MEMPHIS

JIMMIE H. STEVENS, et. al.Individually and on behalf of allsimilarly situated persons,

Plaintiffs,

v.

JM&M SERVICES, INC.; LAMBERTMEMORIAL CO. a/k/a LAMBERTMEMORIALS, INC.; LAMBERT & SONS,INC.; JEMAR LAMBERT, In his IndividualCapacity; MARJE LAMBERT, In her IndividualCapacity; MARY H. LAMBERT, In herIndividual Capacity; GALILEE MEMORIALGARDENS; DURELL ANTOINE WILLIAMSindividually and d/b/a CALVARY MEMORIALFUNERAL HOME; CHRISTIAN FUNERALDIRECTORS, INC.; E.H. FORD MORTUARYSERVICES, INC.; FAMILY MORTUARY,INC.; GOLDEN GATE FUNERAL HOME;SHEILA DAVIS PARRISH; CAROL FORDBEASLEY individually and d/b/a H.C.JETT/H.C. FORD & SON FUNERAL HOME;HARDEMAN COUNTY FUNERALSERVICES, INC.; HARRISON’S FUNERALHOME, INCORPORATED; JAMES E.HERNSON III individually and d/b/a J.E.HERNDON FUNERAL HOME; J.O.PATTERSON FUNERAL HOME a/k/a J.O.PATTERSON MORTUARY; JOSEPH H. IVY;PRESTON JEFFERSON individually and d/b/aJEFFERSON MORTUARY; JOSEPHSAMPSON FORD individually and d/b/a JOEFORD FUNERAL HOME, LLC; M.J.EDWARDS & SONS FUNERAL HOME, INC.;M.J. EDWARDS-WHITEHAVEN FUNERALCHAPEL, INC.; M.J. EDWARDS HILLSIDECHAPEL, INC.; KENNETH GERALD MAYSindividually and d/b/a MAYS FUNERALHOME; VERNAL H. BINS, JR. individually andd/b/a V.H. BINS & SON MID-SOUTHFUNERAL HOME; MILLINGTON FUNERAL

JURY DEMAND

CLASS ACTION

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HOME, INC.; N.H. OWENS & SON FUNERALHOME, INC.; N.J. FORD AND SONSFUNERAL HOME INC.; R.S. LEWISFUNERAL HOME, LLC d/b/a R.S. LEWIS &SONS FUNERAL HOME; SIGNATUREFUNERAL SERVICES, LLC; PETERSHOWERS, JR. individually and d/b/a SNOWFUNERAL HOME; SLS, LLC d/b/a SUPERIORFUNERAL HOME HOLLYWOOD CHAPEL;“DOE” FUNERAL HOMES 1-50,“DOE” FUNERAL DIRECTORS 1-100, andTHE TENNESSEE COMMISSIONER OFCOMMERCE and INSURANCE in her capacityas receiver for the Galilee MemorialGardens and related entities through which itconducts business.

Defendants.

COMPLAINT

The Plaintiffs, by and through counsel, file this Complaint, and would respectfully show

unto the Court the following:

1. This action is related to and includes identical allegations against the same

defendants as Wofford, et al v. M.J. Edwards & Sons Funeral Home, Inc., Case No. CH-14-

0197, a class action complaint pending in this Court. This action, along with the Wofford case,

arises from the mishandling, abuse, desecration, deception, as well as intentional, reckless and

negligent acts of the defendants in the disposition of the remains of the Plaintiffs’ loved ones at

Galilee Memorial Gardens, from January 1, 2011 through January 31, 2014.

2. The Plaintiffs named in this complaint (hereinafter “The Families”) are members

of the proposed class in Wofford. They seek to participate as class members in Wofford, but file

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this action out of an abundance of caution solely to protect against the potential running of the

statute of limitations.

PARTIES

3. Plaintiffs Jimmie H. Stevens, Jr. and Vickie Stevens are adult citizens and

residents of Memphis, Shelby County, TN. They are the surviving children and next of kin of

Jimmie H. Stevens, Sr., who passed away on July 23, 2012. Vickie Stevens contracted for

funeral services, including final disposition of the remains at Galilee Memorial Gardens, with

Christian Funeral Directors, Inc.

4. Plaintiff Charles Branch, is an adult citizen and resident of Atoka, Tipton County,

TN. Plaintiffs Eddie Marshall, Mary Parker and Linda Austin are adult citizens and residents of

Memphis, Shelby County, TN. Plaintiff Edna Marshall is an adult citizen and resident of Como,

Panola County, MS. They are the surviving children of Pearlie M. Marshall, who passed away

on February 10, 2012. Mary Parker contracted for funeral services, including final disposition of

the remains at Galilee Memorial Gardens, with SLS, LLC d/b/a Superior Funeral Home

Hollywood Chapel.

5. Plaintiffs Aaron Bright and Regina Simmons are adult citizens and residents of

Memphis, Shelby County, TN. They are the surviving children of Hattie Mae Simmons, who

passed away on May 19, 2013. Yancie McCruiston is an adult citizen and resident of Memphis,

Shelby County, Tennessee. Mr. McCruiston contracted for funeral services, including final

disposition of the remains at Galilee Memorial Gardens, with Christian Funeral Directors, Inc.

6. Plaintiffs Angela D. Watkins, Marsha Wright, Tunja Whitely, Sonja Marshall,

Phyllis Yancey, Wilson Lee Townsend and Milton Ellis are adult citizens and residents of

Memphis, Shelby County, TN. They are the surviving children and next of kin of Marshall L.

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Howard, who passed away on June 16, 2013. Plaintiff Mary Howard Ellis is an adult citizen and

resident of Memphis, Shelby County, TN. Ms. Mary Howard Ellis contracted for funeral

services for Marshall Howard, including final disposition of the remains at Galilee Memorial

Gardens, with N.H. Owens & Son Funeral Home, Inc.

7. Plaintiff Angela Hudson is an adult citizen and resident of Bartlett, Shelby

County, TN. She is the surviving spouse and next of kin of Billy Glen Hudson, Jr., who passed

away on September 30, 2012. Mrs. Hudson contracted for funeral services, including final

disposition of the remains at Galilee Memorial Gardens, with J.E. Herndon Funeral Home.

8. Plaintiff Effie Crawford is an adult citizen and resident of Cordova, Shelby

County, TN. She is the surviving spouse and next of kin of Hubert Crawford, who passed away

on June 1, 2011. Mrs. Crawford contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with Jefferson Mortuary.

9. Plaintiff Cherrese Jones and Robert Phillips are adult citizens and residents of

Memphis, Shelby County, TN. They are the surviving parents and next of kin of Robert LaMont

Phillips, Jr., who passed away in January, 2011. Ms. Jones contracted for funeral services,

including final disposition of the remains at Galilee Memorial Gardens, with M.J. Edwards &

Sons Funeral Home, Inc.

10. Plaintiff Gracie Bouie, is an adult citizen and resident of Millington, Shelby

County, TN. She is the surviving mother and next of kin of Patrick D. Bouie, who passed away

on September 3, 2011. Plaintiff Debra Stepney is an adult citizen and resident of Millington,

Shelby County, TN. Ms. Stepney contracted for funeral services, including final disposition of

the remains at Galilee Memorial Gardens, with Hardeman County Funeral Services.

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11. Plaintiffs Dewayne Cooper and Vincent Allen are adult citizens and residents of

Memphis, Shelby County, TN. They are the surviving sons and next of kin of Lula P. Allen,

who passed away on April 4, 2011. Mr. Cooper contracted for funeral services, including final

disposition of the remains at Galilee Memorial Gardens, with M.J. Edwards & Sons Funeral

Home, Inc.

12. Plaintiff Pearlie Mae Gatewood is an adult citizen and resident of Lawrenceburg,

Lawrence County, TN. She is the surviving sister of Jessie James Moore, who passed away on

March 15, 2012. Ms. Gatewood contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with M.J. Edwards & Sons Funeral Home, Inc.

13. Plaintiff Floyd Sales, Jr. is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving spouse and next of kin of Lessie P. Sales, who passed away on

January 4, 2012. Mr. Sales contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with N.J. Ford & Sons Funeral Home Inc.

14. Plaintiff Clemmie Freeman, is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving father and next of kin of LaChristian C.E. Freeman, who passed

away April 12, 2012. Mr. Freeman is the beneficiary of the contracts for funeral services,

including final disposition of the remains at Galilee Memorial Gardens, with N.J. Ford & Sons

Funeral Home Inc.

15. Plaintiff Lee Adams is an adult citizen and resident of Memphis, Shelby County,

TN. He is the surviving brother and next of kin of Mose E. Adams, Jr., who passed away on July

10, 2011. Mr. Adams contracted for funeral services, including final disposition of the remains

at Galilee Memorial Gardens, with J.E. Herndon Funeral Home.

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16. Plaintiffs Terrie Williamson and Edward Williamson are adult citizens and

residents of Memphis, Shelby County, TN. They are the surviving siblings and next of kin of

Darryl Jerome Williamson, who passed away on June 3, 2013. Edward Williamson contracted

for funeral services, including final disposition of the remains at Galilee Memorial Gardens, with

N.H. Owens & Son Funeral Home, Inc.

17. Plaintiff Rosie Pruitt is an adult citizen and resident of Memphis, Shelby County,

TN. She is the surviving daughter and next of kin of Florine King Barnes, who passed away on

May 4, 2013. Ms. Pruitt contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with SLS, LLC d/b/a Superior Funeral Home Hollywood

Chapel.

18. Plaintiffs Kathy Carroll, Annette Jones, Lilian Ayers are adult citizens and

residents of Memphis, Shelby County, TN. Plaintiffs Linda Hunter, and Elesha Malone are adult

citizens and residents of Oakland, Fayette County, TN. They are the children and next of kin of

Emma Malone, who passed away on February 27, 2012. Ms. Hunter contracted for funeral

services, including final disposition of the remains at Galilee Memorial Gardens, with H.C.

Jett/H.C. Ford and Son Funeral Home.

19. Plaintiffs Phyllis Boyland, Burnest Rose, Alfred Rose, Carl Rose, Gwendolyn

Rose and Angela Hudson are adult residents and citizens of Shelby County, TN. They are the

surviving children and next of kin of Rosie Lee Hayes, who passed away on August 15, 2013.

Ms. Boyland contracted for funeral services, including final disposition of the remains at Galilee

Memorial Gardens, with E.H. Ford Mortuary Services, Inc.

20. Plaintiff Diane Marie Gaines is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving mother and next of kin of Antonio M. Brown, who passed

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away on June 14, 2013. Ms. Gaines contracted for funeral services, including final disposition of

the remains at Galilee Memorial Gardens, with J.E. Herndon Funeral Home.

21. Plaintiffs Danette Johnson and Carla Mitchell are adult citizens and residents of

Memphis, Shelby County, TN. They are the surviving daughters and next of kin of Joseph C.

Wright, Sr., who was passed away on March 9, 2012. Ms. Mitchell contracted for funeral

services, including final disposition of the remains at Galilee Memorial Gardens, with SLS, LLC

d/b/a Superior Funeral Home Hollywood Chapel.

22. Plaintiff Margarita Glass is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving sister and next of kin of Everett D. Glass, who passed away on

August 4, 2013. Ms. Glass contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with R.S. Lewis Funeral Home, LLC.

23. Plaintiff Otis Davis, Sr. is an adult resident and citizen of Memphis, Shelby

County, TN. He is the surviving brother and next of kin of Katie M. Davis, who passed away on

April 7, 2011. Mr. Davis contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with Christian Funeral Directors, Inc.

24. Plaintiff Frederick Brock is an adult citizen and resident of Hermitage, Davidson

County, TN. He is the surviving son of Nina Brock, who passed away on April 15, 2012. Mr.

Brock contracted for funeral services, including final disposition of the remains at Galilee

Memorial Gardens, with M.J. Edwards & Sons Funeral Home, Inc.

25. Plaintiff Linda Watts-Parker is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving wife and next of kin of Anthony Ray Parker, Sr., who passed

away on September 25, 2012. Mrs. Parker contracted for funeral services, including final

disposition of the remains at Galilee Memorial Gardens, with R.S. Lewis Funeral Home, LLC.

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26. Plaintiff Dorothy Jones is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Carrie Bell Buntyn-Bridges, who

passed away on March 26, 2011. Ms. Jones’ deceased brother, for the benefit of himself and Ms.

Jones, contracted for funeral services, including final disposition of the remains at Galilee

Memorial Gardens, with N.J. Ford & Sons Funeral Home Inc.

27. Plaintiff Tawldra Love is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving mother and next of kin of Duran K. Gales, who passed away in

December, 2012. Ms. Love contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with Millington Funeral Home, Inc.

28. Plaintiff James Carson is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving son of James A. Lucas, who passed away on May 31, 2013.

Mr. Carson contracted for funeral services, including final disposition of the remains at Galilee

Memorial Gardens, with N.H. Owens & Son Funeral Home, Inc.

29. Kenneth E. Thompson, Jr. is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving son of Dorothy T. Bobo, who passed away on February 26,

2011. Mr. Thompson contracted for funeral services, including final disposition of the remains

at Galilee Memorial Gardens, with M.J. Edwards & Sons Funeral Home, Inc.

30. Plaintiff Bobby L. Thompson, is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving brother of Debra D. Johnson-Chambers, who passed away on

June 9, 2012. Mr. Thompson contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with Family Mortuary, Inc.

31. Plaintiff Alice Savage is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving wife and next of kin of Eugene Savage, who passed away on

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August 30, 2012. Plaintiff Ida Strickland is an adult citizen and resident of Memphis, Shelby

County, TN. Ms. Strickland contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with Harrison's Funeral Home, Incorporated.

32. Plaintiff Garland Watkins is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving husband and next of kin of Constance W. Watkins, who passed

away on September 27, 2012. Mr. Watkins contracted for funeral services, including final

disposition of the remains at Galilee Memorial Gardens, with M.J. Edwards Hillside Chapel, Inc.

33. Plaintiff Odis Scullark is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving father and next of kin of Vincent L. Scullark, who passed away

on August 20, 2013. Mr. Skullark contracted for funeral services, including final disposition of

the remains at Galilee Memorial Gardens, with N.H. Owens & Son Funeral Home, Inc.

34. Plaintiff Katictrese Taylor is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Bobby Jackson, Jr., who passed

away on July 25, 2012. Ms. Taylor contracted for funeral services, including final disposition of


Hollywood Chapel.

35. Plaintiff Stanley Crowder is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving brother of Calvin Crowder, who passed away on April 4, 2011.

Mr. Crowder contracted for funeral services, including final disposition of the remains at Galilee

Memorial Gardens, with Christian Funeral Directors, Inc.

36. Plaintiff Eddie R. Schaefer is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving son and next of kin of Estella Schaefer, who passed away on

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September 15, 2011. Mr. Schaefer contracted for funeral services, including final disposition of

the remains at Galilee Memorial Gardens, with E.H. Ford Mortuary Services, Inc.

37. Plaintiff Ruthie A. Nelson is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving wife and next of kin of Jerry O. Nelson, who passed away on

June 23, 2011. Mrs. Nelson contracted for funeral services, including final disposition of the


38. Plaintiff Calvin Glass is an adult citizen and resident of Arlington, Shelby County,

TN. He is the surviving son and next of kin of John T. Glass, who passed away on December 11,

2011. Mr. Glass contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with N.H. Owens & Son Funeral Home, Inc.

39. Plaintiff Michael James is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving son of Lillie Mae Powell, who passed away on July 7, 2013.

Mr. James contracted for funeral services, including final disposition of the remains at Galilee


40. Marva Whitten is an adult citizen and resident of Memphis, Shelby County, TN.

She is the surviving mother and next of kin of Terika R. Whitten, who passed away on February

7, 2011. Ms. Whitten contracted for funeral services, including final disposition of the remains

at Galilee Memorial Gardens, with Snow Funeral Home.

41. Plaintiff Yolanda Robinson is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving mother and next of kin of Dareus J. McKnuckles, who passed

away in September, 2012. Ms. Robinson contracted for funeral services, including final

disposition of the remains at Galilee Memorial Gardens, with Golden Gate Funeral Home.

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42. Plaintiff Rebecca Williams is a resident of Memphis, Shelby County, TN. She is

the surviving wife and next of kin of Ira E. Williams, II, who passed away on October 12, 2012.

Plaintiff Joyce Williams is an adult citizen and resident of St. Louis, MO. She is the surviving

mother of Ira E. Williams, III. Ms. Joyce Williams contracted for funeral services, including

final disposition of the remains at Galilee Memorial Gardens, with Christian Funeral Directors,

Inc.

43. Plaintiff Rebecca Williams is also the surviving daughter and next of kin of

Maude D. Horton, who passed away on October 26, 2012. Ms. Williams contracted for funeral

services, including final disposition of the remains at Galilee Memorial Gardens, with Christian

Funeral Directors, Inc.

44. Plaintiff Charisse Noble is the surviving daughter and next of kin of Dennie

Noble, who passed away in February, 2013. Ms. Noble contracted for funeral services, including

final disposition of the remains at Galilee Memorial Gardens, with Mays Funeral Home.

45. Plaintiffs Cynthia Taliaferro-Fultez and Anita Harris are adult citizens and

residents of Memphis, Shelby County, TN. They are the surviving daughters and next of kin of

Dorothy M. Worles, who passed away on November 9, 2011. Anita Harris contracted for funeral

services, including final disposition of the remains at Galilee Memorial Gardens, with M.J.

Edwards Hillside Chapel, Inc.

46. Plaintiffs Ricky Johnson and Charles Donaldson are adult citizens and residents

of Memphis, Shelby County, TN. Plaintiff Melvin Jean Johnson-Pryor is an adult citizen and

resident of Bartlett, Shelby County, TN. They are the surviving children and next of kin of

Bessie M. Johnson-Allen, who passed away on was November 1, 2012. Ms. Johnson-Allen’s

children contracted for and were the beneficiaries of contracts for funeral services, including

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final disposition of the remains at Galilee Memorial Gardens, with J.O. Patterson Funeral Home

a/k/a J.O. Patterson Mortuary, Inc.

47. Plaintiffs Shelia Hobson, Patricia Stevenson, DeAngela Greene, Anthony Hobson,

Monique Hobson, Sandra Hobson and Marlo Polk are adult citizens and residents of Memphis,

Shelby County, TN. Plaintiff Myra Greene is an adult citizen and resident of Fayetteville,

Fayette County, GA. Plaintiff Kevin Scott is an adult citizen and resident of Drexel Hill,

Delaware County, PA. They are the surviving children and next of kin of Marshall L. Hobson,

who passed away on June 16, 2013. Ms. Stevenson contracted for funeral services, including

final disposition of the remains at Galilee Memorial Gardens, with N.J. Ford & Sons Funeral

Home Inc.

48. Plaintiff Clementine Brown is an adult citizen and resident of Memphis, Shelby

County, TN and is the surviving spouse and next of kin of Willie F. Brown. Plaintiff Kerri

Brown is an adult citizen and resident of Nashville, Davidson County, TN. She is the surviving

daughter of Willie F. Brown, who passed away on January 26, 2012. Ms. Kerri Brown

contracted for funeral services, including final disposition of the remains at Galilee Memorial

Gardens, with Millington Funeral Home, Inc.

49. Plaintiff Renee Cross is an adult citizen and resident of Memphis, Shelby County,

TN. She is the surviving sister and next of kin of Myra J. Chambers, who passed away on

December 18, 2011. Ms. Cross contracted for funeral services, including final disposition of the


Chapel.

50. Plaintiff Diana Martin is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving wife and next of kin of Thomas D. Martin, who passed away

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on May 11, 2011. Ms. Martin contracted for funeral services, including final disposition of the


Chapel.

51. Plaintiff John Spencer is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving spouse and next of kin of Precious L. Spencer, who passed

away on June 17, 2011. Mr. Spencer contracted for funeral services, including final disposition

of the remains at Galilee Memorial Gardens, with N. H. Owens and Sons Funeral Home, Inc.

52. Plaintiff Audrey Talbert is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter of Geneva Brackens, who passed away on May 5,

2011. Ms. Talbert contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with J. E. Herndon Funeral Home.

53. Plaintiff Clifton Parker is an adult citizen and resident of Memphis, Shelby

County, TN. Plaintiff Janet Marie Covington is an adult citizen and resident of West Memphis,

Crittenden County, AR. They are the surviving parents and next of kin of Terrance M.

Covington, who passed away on July 5, 2013. Mr. Parker contracted for funeral services,

including final disposition of the remains at Galilee Memorial Gardens, with R. S. Lewis & Sons

Funeral Home.

54. Plaintiffs Priscilla Mayfield Willie Laury and Tazie Laury are adult citizens and


Ruthie Mae Laury, who passed away on November 16, 2011. Ms. Mayfield contracted for


M.J. Edwards Hillside Chapel, Inc.

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55. Plaintiff Willine Finley, is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving niece of Barbara Mobley, who passed away on July 20, 2013.

Ms. Finley contracted for funeral services, including final disposition of the remains at Galilee


56. Plaintiff Janice Lewis is an adult citizen and resident of Memphis, Shelby County,

TN. She is the surviving daughter and next of kin of Willie J. Lewis, who passed away on

September 15, 2012. Ms. Lewis contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with Superior Funeral Home.

57. Plaintiffs Joseph Hayes and Sandra Wright are adult citizens and residents of

Memphis, Shelby County, TN. They are the surviving children and next of kin of Emma Hayes,

who passed away on April 25, 2011. Mr. Hayes contracted for funeral services, including final


58. Plaintiff Myrtle Sims Morton is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving mother and next of kin of Tierria L. Sims, who passed away on

October 31, 2013. Ms. Sims Morton contracted for funeral services, including final disposition

of the remains at Galilee Memorial Gardens, with N.H. Owens & Son Funeral Home, Inc.

59. Plaintiff Calvin T. Blakley, Sr. is an adult citizen and resident of Memphis,

Shelby County, TN. He is the surviving father and next of kin of Calvin T. Blakley, Jr., who

passed away on October 20, 2013. Mr. Blakley, Sr. contracted for funeral services, including


Home Inc.

60. Plaintiffs Jason and Andrea Rowe are adult citizens and residents of Bartlett,

Shelby County, TN. They are the surviving parents and next of kin of Jazlyn Rowe, who passed

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away on August 16, 2013. Jason Rowe contracted for funeral services, including final


61. Plaintiffs Etta Rickman and James Allen, Jr. are adult citizens and residents of

Memphis, Shelby County, TN. Plaintiff Eric Allen is an adult citizen and resident of San

Francisco, San Francisco County, CA. They are the surviving children and next of kin of James

Allen, Sr., who passed away on December 25, 2012. Ms. Rickman contracted for funeral



62. Plaintiff Ronica Matthews is an adult citizen and resident of Memphis, Shelby

County, TN. Plaintiff Andrea Logan is an adult citizen and resident of Southaven, DeSoto

County, MS. They are the surviving children and next of kin of Earnestine W. Matthews, who

passed away on June 17, 2013. Ms. Matthews contracted for funeral services, including final

disposition of the remains at Galilee Memorial Gardens, with M. J. Edwards Hillside Chapel,

Inc.

63. Plaintiff Samuel Christian is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving father and next of kin of Cynthia Denise Christian, who passed

away on August 2, 2012. Plaintiff Tomika Christian is the surviving sister of Cynthia Denise

Christian. Ms. Christian contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with E. H. Ford Funeral Home.

64. Plaintiff Mattie Loyde is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving mother and next of kin of Charlene Erikia Parks, who passed

away on May 16, 2012. Vincent Martin is an adult citizen and resident of Cordova, Shelby

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County, TN. Mr. Martin contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with E. H. Ford Funeral Home.

65. Plaintiffs Lajanis Wilson, Sadie Featherson, Mary Wilson, and Evelyn Wilson are

adult citizens and residents of Memphis, Shelby County, TN. They are the surviving children and

next of kin of Earsular Boyd Wilson, who passed away on March 31, 2013. Mrs. Wilson’s

children contracted for and were the beneficiaries of contracts for funeral services, including

final disposition of the remains at Galilee Memorial Gardens, SLS, LLC d/b/a Superior Funeral

Home Hollywood Chapel.

66. Plaintiffs Tamarera Kelly-Malone and Nita Foreman are adult citizens and

residents of Memphis, Shelby County, TN. They are surviving children of Juanita Scott, who

passed away on December 14, 2012. Plaintiff Irma Butler is an adult citizen and resident of

Memphis, Shelby County, TN. She is the surviving sister of Juanita Scott. Ms. Butler


Gardens, with Christian Funeral Directors, Inc.

67. Plaintiff Cortez Dodson is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving son and next of kin of Jeffery Dodson, who passed away March

23, 2013. Plaintiff Deloris Curry is an adult citizen and resident of Memphis, Shelby County,

TN. Ms. Curry contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with M.J. Edwards & Sons Funeral Home, Inc.

68. Plaintiff Shelita Sesley is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Yumika Dodson, who passed away

on May 18, 2012. Ms. Sesley contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with J.E. Herndon Funeral Home.

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69. Plaintiff Jacqueline Brown is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving sister of Bobby Smith, who passed away on April 6, 2013.

Ms. Brown contracted for funeral services, including final disposition of the remains at Galilee

Memorial Gardens, with Millington Funeral Home, Inc.

70. Plaintiff Eva McQueen is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving sister and next of kin of Celeste McQueen, who passed away

on March 23, 2013. Ms. McQueen was the beneficiary of the contracts for funeral services

including final disposition of the remains at Galilee Memorial Gardens, with Snow Funeral

Home.

71. Plaintiff D'Angelo Suggs is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving son and next of kin of Eddie Rodgers, who passed away on

August 3, 2011. Mr. Suggs contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with E.H. Ford Mortuary Services, Inc.

72. Plaintiff Patricia Washington is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Mildred Hubbard, who passed

away on February 5, 2013. Ms. Washington contracted for funeral services, including final

disposition of the remains at Galilee Memorial Gardens, with N.H. Owens & Son Funeral Home,

Inc.

73. Plaintiff Carolyn Lane is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Lizzie Mae Bryant, who passed

away on July 15, 2011. Ms. Lane contracted for funeral services, including final disposition of

the remains at Galilee Memorial Gardens, with Millington Funeral Home, Inc.

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74. Plaintiff Alene Henderson is and adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving mother and next of kin of Latrise A. Brown. Plaintiff Keisha

James is an adult citizen and resident of Memphis, Shelby County, TN. She is the surviving

sister of Latrise A. Brown, who passed away on April 30, 2012. Ms. James contracted for


SLS, LLC d/b/a Superior Funeral Home Hollywood Chapel.

75. Plaintiff Robert E. Galison is an adult citizen and resident of Cordova, Shelby

County, TN. He is the surviving son and next of kin of Doll L. Galison, who passed away on

May 12, 2012. Mr. Galison contracted for funeral services, including final disposition of the


76. Plaintiff Leroy Cribbs is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving spouse and next of kin of Wanda Cribbs, who passed away on

February 17, 2012. Mr. Cribbs contracted for funeral services, including final disposition of the


77. Plaintiffs Tanya Robinson and Linda Sargent are adult citizens and residents of

Memphis, Shelby County, TN. They are the surviving daughters and next of kin of Jerry

Robinson, who passed away on July 12, 2012. Ms. Sargent contracted for funeral services,

including final disposition of the remains at Galilee Memorial Gardens, with Christian Funeral

Directors, Inc.

78. Plaintiff Marian P. Tuggle is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving sister of Sylvester Tuggle, who passed away on August 29,

2011. Ms. Tuggle contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with SLS, LLC d/b/a Superior Funeral Home Hollywood Chapel.

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79. Plaintiff Patricia Golden is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving wife and next of kin of George Golden, who passed away on

April 5, 2013. Mrs. Golden contracted for funeral services, including final disposition of the


Chapel.

80. Plaintiff Loretta Graham is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving mother and next of kin of LeShune L. Graham, who passed

away on February 15, 2013. Ms. Graham contracted for funeral services, including final


81. Plaintiff Norma Wilkins is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving mother and next of kin of Keith Seymoure Dotson, who

passed away on November 18, 2012. Norma Wilkins contracted for funeral services, including

final disposition of the remains at Galilee Memorial Gardens, with M.J. Edwards Hillside

Chapel, Inc.

82. Plaintiff Carolyn Lacy-Williams is also the surviving daughter and next of kin of

Lottie Rhodes, who passed away on January 25, 2011. Ms. Lacy-Williams contracted for funeral

services, including final disposition of the remains at Galilee Memorial Gardens, with Millington

Funeral Home, Inc.

83. Plaintiff Georgia A. Perkins is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving mother of John Allen Perkins, who passed away on January

29, 2011. Ms. Perkins contracted for funeral services, including final disposition of the remains

at Galilee Memorial Gardens with R.S. Lewis Funeral Home, LLC.

20

84. Plaintiff Jacqueline Hughes is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving sister of Tawana R. Hillard, who passed away on October 13,

2012. Ms. Hughes contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with Joe Ford Funeral Home, LLC.

85. Plaintiff Ivezeen Jackson Crawford is an adult citizen and resident of Memphis,

Shelby County, TN. She is the surviving mother and next of kin of Samuel E. Jackson. Plaintiff

Helen Young is an adult citizen and resident of Memphis, Shelby County, TN. She is the

surviving sister of Samuel E. Jackson who passed away on May 18, 2013. Ms. Young contracted



86. Plaintiff Melvin Travis is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving son and next of kin of Dorothy Ann Travis Valentine, who

passed away on August 8, 2012. Mr. Travis is the beneficiary of the contracts for funeral

services, including final disposition of the remains at Galilee Memorial Gardens, with R.S.

Lewis Funeral Home, LLC.

87. Plaintiff Delois Scott is an adult citizen and resident of Memphis, Shelby County,

TN. She is the surviving wife and next of kin of Thurman Arthur Scott, who passed away on

November 7, 2012. Ms. Scott contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with Family Mortuary, Inc.

88. Plaintiff Earnest Taylor, Jr. is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving son and next of kin of Earnest Edward Taylor, who passed

away on June 30, 2013. Mr. Taylor is the beneficiary of the contracts for funeral services,

21


Directors, Inc.

89. Plaintiff Kashif McCracken is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Tyrone Alexander McCracken,

who passed away on February 2, 2012. Ms. McCracken is the beneficiary of the contracts for



90. Plaintiff Roland Epps is an adult citizen and resident of Memphis, Shelby County,

Tennessee. He is the surviving husband and next of kin of Pauletta Epps, who passed away on

October 24, 2011. Mr. Epps contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with M.J. Edwards-Whitehaven Funeral Chapel, Inc.

91. Plaintiff Tierra Robinson is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving mother and next of kin of De’Tira Harwell, who passed away

in March, 2013. Ms. Robinson contracted for funeral services, including final disposition of the


Chapel.

92. Plaintiffs Melisa Swearngen and Carelesa Harris are adult citizens and residents

of Memphis, Shelby County, TN. They are the surviving daughters and next of kin of Ethel Lee

Harris, who passed on December 25, 2011. Ms. Swearngen contracted for funeral services,

including final disposition of the remains at Galilee Memorial Gardens, with SLS, LLC d/b/a

Superior Funeral Home Hollywood Chapel.

93. Plaintiff Sheneitha McNutt is an adult citizen and resident of Cordova, Shelby

County, TN. She is the surviving daughter and next of kin of Andrew Lee McNutt, who passed

22

away on June 7, 2013. Ms. McNutt contracted for funeral services, including final disposition of


94. Plaintiffs Linda Valentine Benson, Lester Valentine, Jr., Freddie Valentine,

Lavitta Valentine, Leslie Valentine Smith, Rickie Valentine, Walter Valentine, Gregory

Valentine, Belinda Merriweather, Tavis Jones and Brenda Valentine are adult citizens and

residents of Memphis, Shelby County, TN. Plaintiff Lawanda Boswell is an adult citizen and

resident of Norfolk, VA. Plaintiff Mack Valentine is an adult citizen and resident of Horn Lake,

DeSoto County, MS. They are the surviving children of Lester Valentine, Sr., who passed away

on March 25, 2011. They are the beneficiaries of the contracts for funeral services, including


Inc.

95. Plaintiff Lisa Smith is an adult citizen and resident of Memphis, Shelby County,

TN. She is the surviving daughter and next of kin of Ida Mae Hughes, who passed away in

December, 2011. Ms. Smith contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with by Christian Funeral Directors, Inc.

96. Plaintiff Stacy Carter is an adult citizen and resident of Memphis, Shelby County,

TN. She is the surviving mother and next of kin of Detario Maquill Carter, who passed away on

December 29, 2011. Ms. Carter is the beneficiary of the contracts for funeral services, including


Home Inc.

97. Plaintiffs Andre Alexander, Trena Bolton and Dwight Alexander are adult

citizens and residents of Memphis, Shelby County, TN. They are the surviving children and next

of kin of Dorothy Thompson, who passed away on March 8, 2012. The children contracted for

23

and are the beneficiaries of the contracts for funeral services, including final disposition of the


98. Plaintiffs Tisha Childs, John Childs, Jarvis A. Lewis and Nikkon Childs are adult


of kin of Rosie Mae Childs, who passed away in January 29, 2011. The children of Rosie Mae

Childs contracted for and were the beneficiaries of contracts for funeral services, including final


99. Plaintiffs Bryan Wilson and Calvin Bell are adult citizens and residents of

Memphis, Shelby County, TN. They are the surviving sons and next of kin of Gladys Wilson,

who passed away on May 18, 2013. Mr. Bell contracted for funeral services, including final


100. Plaintiff Johnny Boyce is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving son and next of kin of Ruthie Boyce, who passed away on May

6, 2011. Mr. Boyce contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with R.S. Lewis Funeral Home, LLC.

101. Plaintiffs Demarcus Daniels and Carron Stanton-Daniels are adult citizens and

residents of Memphis, Shelby County, TN. They are the surviving parents and next of kin of

Divinity Daniels, who passed away on June 6, 2012. Mr. Daniels contracted for funeral services,

including final disposition of the remains at Galilee Memorial Gardens, with M.J. Edwards

Hillside Chapel, Inc.

102. Plaintiff Caroletta Williams-Hudson is an adult citizen and resident of Olive

Branch, Desoto County, MS. She is the surviving daughter and next of kin of David Williams

who passed away on March 29, 2013. Ms. Williams-Hudson contracted for funeral services,

24



103. Plaintiff Genevia Franklin is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving wife and next of kin of Willie Franklin, who passed away on

September 24, 2011. Mrs. Franklin contracted for funeral services, including final disposition of

the remains at Galilee Memorial Gardens, with M.J. Edwards Hillside Chapel, Inc.

104. Plaintiff Coleetha Smith is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Albert Winters, who passed away

on July 11, 2011. Ms. Smith contracted for funeral services, including final disposition of the


105. Plaintiff Mary Barnes is an adult citizen and resident of Memphis, Shelby County,

TN. She is the surviving sister and next of kin of Crofton Posey, Jr., who passed away on

February 22, 2011. Ms. Barnes contracted for funeral services, including final disposition of the


Chapel.

106. Plaintiff Eronica King is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Henry King, who passed away on

February 17, 2011. Ms. King contracted for funeral services, including final disposition of the


107. Plaintiff Willie Mae Henry is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving wife and next of kin of Andrew Henry, who passed away on

January 27, 2013. Mrs. Henry contracted for funeral services, including final disposition of the


25

108. Plaintiffs Shelia Tate, Melody Tate and Antoine Brown are adult citizens and


Lena Jeans-Brown, who passed away on February 6, 2013. Melody Tate contracted for funeral



109. Plaintiff LaTonya Halliburton is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Juanita Fisher, who passed away

on October 11, 2011. Ms. Halliburton contracted for funeral services, including final disposition

of the remains at Galilee Memorial Gardens, with SLS, LLC d/b/a Superior Funeral Home

Hollywood Chapel.

110. Plaintiffs Ronald Carroll and Edgar Williams are adult citizens and residents of

Memphis, Shelby County, TN. They are surviving sons and next of kin of Gloria Lewis, who

passed away on September 16, 2012. They are the beneficiaries of the contracts for funeral

services, including final disposition of the remains at Galilee Memorial Gardens, with by

Harrison’s Funeral Home, Incorporated.

111. Plaintiff John E. Hampton is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving brother and next of kin of Rogene Lee Hampton, who passed

away on September 4, 2011. Mr. Hampton contracted for funeral services, including final


112. Plaintiff Joe Morrow is an adult citizen and resident of Memphis, Shelby County,

TN. He is the surviving son and next of kin of Willie Morrow, who passed away on April 28,

2013. Plaintiff Bernice Morrow is an adult citizen and resident of Memphis, Shelby County, TN.

26

Mr. Morrow & Ms. Morrow contracted for funeral services, including final disposition of the


113. Plaintiff Ernestine Braden is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Virginia Washington, who passed

away on August 24, 2011. Ms. Braden contracted for funeral services, including final

disposition of the remains at Galilee Memorial Gardens, with N.J. Ford & Sons Funeral Home

Inc.

114. Plaintiff Janice Wallace is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving mother and next of kin of Quinton Wallace, who passed away

on June 29, 2013. Ms. Wallace contracted for funeral services, including final disposition of the


Chapel.

115. Plaintiff Anita Parker is an adult citizen and resident of Memphis, Shelby County,

TN. She is the surviving daughter and next of kin of Ann Chambers, who passed away on April

17, 2013. Ms. Parker contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with Christian Funeral Directors, Inc.

116. Plaintiff Tory Shepherd is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving son of Debra Shepherd, who passed away in October, 2012.

Mr. Shepherd contracted for funeral services, including final disposition of the remains at


117. Plaintiff Nicole Logan is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Ralph Wallace, who passed away

on January 9, 2012. Plaintiff Lucille Lawrence is an adult citizen and resident of Memphis,

27

Shelby County, TN and the surviving sister of Ralph Wallace. Ms. Lawrence and Ms. Logan


Gardens with M.J. Edwards-Whitehaven Funeral Chapel, Inc.

118. Plaintiff Clarence Edwards is an adult citizen and resident of Bartlett, Shelby

County, TN. He is the surviving son and next of kin of Clorine Edwards, who passed away on

September 10, 2011. Mr. Edwards is the beneficiary of the contracts for funeral services,

including final disposition of the remains at Galilee Memorial Gardens, with Jefferson Mortuary.

119. Plaintiff Arthur Howard is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving son and next of kin of Katherine Howard, who was buried at

Galilee Memorial Gardens on August 8, 2012. Mr. Howard contracted for funeral services,

including final disposition of the remains at Galilee Memorial Gardens, with E.H. Ford Mortuary

Services, Inc.

120. Plaintiff Donna Dyson is an adult citizen and resident of Fort Washington, Prince

Georges County, MD. Plaintiff Benjamin Harvey is an adult citizen and resident of Arlington,

Arlington County, VA. They are the surviving children and next of kin of Jean Harvey, who

passed away on February 19, 2012. Mr. Harvey contracted for funeral services, including final

disposition of the remains at Galilee Memorial Gardens, with N.J. Ford and Sons Funeral Home

Inc.

121. Plaintiffs Willie Brooks and Gary Brooks are adult citizens and residents of

Memphis, Shelby County, TN. They are the surviving children and next of kin of Mary Ann

Reed Brooks, who passed away on April 2, 2013. Willie Brooks contracted for funeral services,


Directors, Inc.

28

122. Plaintiff Deborah Campbell is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving mother and next of kin of Kalvin Petties, who passed away on

August 12, 2012. Plaintiff Thelma Harris is an adult citizen and resident of Memphis, Shelby

County, TN. Ms. Harris contracted for funeral services, including final disposition of the


123. Plaintiffs Kerry Pigram and Shontiva Pigram are adult citizens and residents of

Memphis, Shelby County, TN. They are the surviving children and next of kin of Wardell

Pigram, who passed away on January 16, 2013. Mr. Pigram contracted for funeral services,

including final disposition of the remains at Galilee Memorial Gardens, with Millington Funeral

Home, Inc.

124. Plaintiff Terrance Sales and Jamila Branch-Sales are adult citizens and residents

of Memphis, Shelby County, TN. They are the surviving parents and next of kin of Jasmine

Angelena Sales, who passed away on November 5, 2013. Mrs. Sales contracted for funeral

services, including final disposition of the remains at Galilee Memorial Gardens, with N.J. Ford

& Sons Funeral Home Inc.

125. Plaintiff Jason Branch is an adult citizen and resident of Arlington, Shelby

County, TN. He is the surviving brother and next of kin of Inez Branch, who passed away on

November 23, 2011. Mr. Branch contracted for funeral services, including final disposition of

the remains at Galilee Memorial Gardens, with by SLS, LLC d/b/a Superior Funeral Home

Hollywood Chapel.

126. Plaintiff Jacqueline Finnie is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving sister and next of kin of Patricia Carlock, who passed away on

29

October 12, 2012. Ms. Finnie contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with M.J. Edwards Hillside Chapel, Inc.

127. Plaintiff Tony Manuel, is a resident of Collierville, Shelby County, TN. He is the

surviving brother and next of kin of Jacob Manuel, who passed away on July 11, 2011. Mr.

Manuel is the beneficiary of the contracts for funeral services, including final disposition of the


128. Plaintiff Dorothy James is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Vera Mae Godwin, who passed

away on February 15, 2011. Ms. James contracted for funeral services, including final


129. Plaintiff Johnny Porter is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving husband and next of kin of Chevelle Y. Carr, who passed away

on March 13, 2013. Plaintiff Sherika Carr is an adult citizen and resident of Memphis, Shelby

County, TN. Ms. Carr contracted for funeral services, including final disposition of the remains

at Galilee Memorial Gardens, with R.S. Lewis Funeral Home, LLC.

130. Plaintiff Ronald Williams is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving son and next of kin of Minnie Williams, who passed away on

November 20, 2012. Mr. Williams is the beneficiary of the contracts for funeral services,



131. Plaintiff Janet Stevenson is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Queenie Stevenson, who passed

away on October 19, 2013. Janet Stevenson contracted for funeral services, including final

30


Home, Inc.

132. Plaintiff Anita Holloway is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving mother and next of kin of Christopher M. Holloway, who

passed away on June 15, 2013. Mrs. Holloway contracted for funeral services, including final


133. Plaintiff Vickie M. Jackson is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving mother of Voner Matlock, who passed away on June 22, 2011.

Ms. Jackson contracted for funeral services, including final disposition of the remains at Galilee

Memorial Gardens, with SLS, LLC d/b/a Superior Funeral Home Hollywood Chapel.

134. Plaintiffs Michael E. King and Michelle D. King-Turner are adult citizens and


Julius E. Tuggle, who passed away on September 16, 2011. Mr. King contracted for funeral


& Sons Funeral Home Inc.

135. Plaintiffs Bobby Holley and Billy Holley are adult citizens and residents of

Memphis, Shelby County, TN. They are the surviving brothers of James A. Holley, who passed

away on January 16, 2013. Billy Holley contracted for funeral services, including final

disposition of the remains at Galilee Memorial Gardens, with SLS, LLC d/b/a Superior Funeral


136. Plaintiff Tomeke Mickens is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Linda D. Smith, who passed away

31

on April 11, 2013. Ms. Mickens contracted for funeral services, including final disposition of

the remains at Galilee Memorial Gardens, with Christian Funeral Directors, Inc.

137. Plaintiff Anitra Taylor is an adult citizen and resident of Arlington, Shelby

County, TN. She is the surviving wife and next of kin of Joe Melvin Taylor, Jr., who passed

away on January 4, 2012. Mrs. Taylor contracted for funeral services, including final disposition

of the remains at Galilee Memorial Gardens, with Joe Ford Funeral Home, LLC.

138. Plaintiff Earl Foster is an adult citizen and resident of Memphis, Shelby County,

TN. He is the surviving brother and next of kin of Christine Spencer, who passed away on

February 27, 2012. Mr. Foster contracted for funeral services, including final disposition of the


139. Plaintiffs Tamara Merriweather, Teidre Sugars and TaJuana Sugars are adult

citizens and residents of Memphis, Shelby County, TN. Taurus Merriweather is an adult citizen

and resident of Henning, Lauderdale County, TN. They are the surviving children and next of

kin of Barbara Merriweather Rawlings, who passed away on July 19, 2013. Ms. Tajuana Sugars


Gardens, with Family Mortuary, Inc.

140. Plaintiff Kevin Voss is an adult citizen and resident of Memphis, Shelby County,

TN. He is the surviving father and next of kin of Toni Voss, who passed away on May 20, 2012.

Mr. Voss is the beneficiary of the contracts for funeral services, including final disposition of the


141. Plaintiff Barbara Whitten is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Katie Johnson, who passed away

32

on April 19, 2013. Ms. Whitten contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with J.E. Herndon Funeral Home.

142. Plaintiff Debra Cooper is an adult citizen and resident of Brighton, Shelby

County, TN. She is the surviving mother and next of kin of Markeith Jackson, who passed away

on June 2, 2013. Ms. Cooper was the beneficiary of contracts for funeral services, including

final disposition of the remains at Galilee Memorial Gardens, with N. J. Ford & Sons Funeral

Home, Inc.

143. Plaintiff Lynn Perry is an adult citizen and resident of Memphis, Shelby County,

TN. She is the surviving mother and next of kin of Gregory Perry, who passed away on June 15,

2013. Ms. Perry contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with R.S. Lewis Funeral Home, LLC.

144. Plaintiff James Alexander, Jr. is an adult citizen and resident of Millington,

Shelby County, TN. He is the surviving son and next of kin of Ora Lee Alexander, who passed

away on January 19, 2011. Mr. Alexander contracted for funeral services, including final

disposition of the remains at Galilee Memorial Gardens, with Jefferson Mortuary.

145. Plaintiff Faith Evans is an adult citizen and resident of Fort Worth, Tarrant

County, TX. She is the surviving daughter and next of kin of Georgia Mae Tatum, who passed

away on January 4, 2013. Ms. Evans contracted for funeral services, including final disposition

of the remains at Galilee Memorial Gardens, with Christian Funeral Directors, Inc.

146. Plaintiff James Sullivan is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving spouse and next of kin of Renay Sullivan, who passed away on

June 24, 2012. Mr. Sullivan contracted for funeral services, including final disposition of the

33


Chapel.

147. Plaintiff Kevin Harper is an adult citizen and resident of Dallas, Dallas County,

TX. Plaintiff Jason Tucker is an adult citizen and resident of Memphis, Shelby County, TN.

They are the surviving children and next of kin of Sylvester Tucker, Jr., who passed away on

January 20, 2012. Plaintiff Vernada Tucker is an adult citizen and resident of Fresno, Fort Bend

County, TX. Vernada Tucker contracted for funeral services, including final disposition of the


148. Plaintiffs Shunterri Jones, Kilyus Patterson, Starnitra Patterson and Kenyatta

Patterson are adult citizens and residents of Memphis, Shelby County, TN. They are the

surviving children and next of kin of Mary Patterson, who passed away on September 15, 2011.

Plaintiff Diann Crite is an adult citizen and resident of Houston, Harris County, TX. Ms. Crite



149. Plaintiff Debra Pendleton is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving mother and next of kin of Felisa Wilkins, who was passed

away on September 30, 2012. Ms. Pendelton contracted for funeral services, including final


150. Plaintiff Connie Stevenson is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving mother and next of kin of Kenneth Stevenson, who passed

away on March 16, 2013. Ms. Stevenson contracted for funeral services, including final

disposition of the remains at Galilee Memorial Gardens, with N.J. Ford & Sons Funeral Home

Inc.

34

151. Plaintiff Wilbert Smith, Sr. is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving spouse and next of kin of Linda Smith, who passed away on

November 15, 2012. Plaintiff Wilbert Smith, Jr. is an adult citizen and resident of Memphis,

Shelby County, TN. He is the surviving son of Linda Smith. Wilbert Smith, Jr. contracted for


SLS, LLC d/b/a Superior Funeral Home Hollywood Chapel.

152. Plaintiff Tabatha Turner is an adult citizen and resident of Bartlett, Shelby

County, TN. She is the surviving mother and next of kin of Quenisha Turner, who passed away

on July 5, 2012. Ms. Turner contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with by SLS, LLC d/b/a Superior Funeral Home

Hollywood Chapel.

153. Plaintiff Geraldine Collins and John K. Evans are adult residents and citizens of

Memphis, Shelby County, TN. They are the surviving children and next of kin of Edna Cole

Riley, who passed away on April 8, 2011. Mrs. Collins contracted for funeral services, including

final disposition of the remains at Galilee Memorial Gardens, with by Christian Funeral

Directors, Inc.

154. Plaintiff Christine Williams is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving mother and next of kin of Demetria Scott Whittington, who

passed away on August 12, 2011. Ms. Williams contracted for and/or was the beneficiary of

contracts for funeral services, including final disposition of the remains at Galilee Memorial

Gardens, with M. J. Edwards & Sons Funeral Home, Inc.

155. Plaintiff Willie Mae Jones Long is an adult citizen and resident of Memphis,

Shelby County TN. She is the surviving spouse and next of kin of Louis Long, who passed away

35

on January 6, 2011. Plaintiff Louis Long, Jr. is an adult citizen and resident of Thornton, Adams

County, CO. Mr. Long contracted for funeral services, including final disposition of the remains

at Galilee Memorial Gardens, with Christian Funeral Directors, Inc.

156. Plaintiff Lisa McCarley is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving mother and next of kin of LaDarius Wilson, who passed away

on October 24, 2012. Ms. McCarley contracted for funeral services, including final disposition

of the remains at Galilee Memorial Gardens, with N.J. Ford & Sons Funeral Home Inc.

157. Plaintiff Dorothy Obie is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving mother and next of kin of Sandra Denise Obie, who passed

away on April 14, 2011. Ms. Obie contracted for funeral services, including final disposition of


Hollywood Chapel.

158. Plaintiffs Ivory Sharrod and Shirley Williams are adult citizens and residents of

Memphis, Shelby County, TN. Mr. Sharrod is the surviving son and next of kin of Ivory

Williams, who was passed away on June 8, 2013. Ms. Williams contracted for funeral services,


Directors, Inc.

159. Plaintiff Shirley Williams is also the surviving daughter and next of kin of Julia

Williams, who passed away on January 6, 2013. Ms. Williams contracted for funeral services,


Directors, Inc.

160. Plaintiff Allen Fitzgerald White, Jr. is an adult citizen and resident of Memphis,

Shelby County, TN. He is the surviving son and next of kin of Allen Fitzgerald White, Sr., who

36

passed away on October 29, 2012. Plaintiff Dolly Wright is an adult citizen and resident of

Memphis, Shelby County, TN. She is the surviving sister of Allen Fitzgerald White, Sr. Ms.

Wright contracted for funeral services, including final disposition of the remains at Galilee


161. Plaintiff Geraldine Williams is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving wife and next of kin of Elijah Williams, Jr., who passed away

on July 13, 2013. Mrs. Williams contracted for funeral services, including final disposition of

the remains at Galilee Memorial Gardens, with N.J. Ford & Sons Funeral Home Inc.

162. Plaintiff Charlotte Douglass is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving mother and next of kin of Terrell A. Washington, who passed

away on April 24, 2011. Ms. Douglass contracted for funeral services, including final

disposition of the remains at Galilee Memorial Gardens, with Harrison's Funeral Home,

Incorporated.

163. Plaintiff Lenora Jones is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving wife and next of kin of Dorothy L. Jones, who passed away on

September 29, 2011. Ms. Jones contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with N. H. Owens and Sons Funeral Home, Inc.

164. Plaintiff De’Errica Virgous is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Brenda Lee Isaac, who passed

away on November 7, 2012. Ms. Virgous contracted for funeral services, including final

disposition of the remains at Galilee Memorial Gardens, with Family Mortuary, Inc.

165. Plaintiff Sylvia Orr is an adult citizen and resident of Memphis, Shelby County

TN. She is the surviving sister and next of kin of Alfreida Looney, who passed away on August

37

7, 2012. Ms. Orr contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with J.E. Herndon Funeral Home.

166. Plaintiff Martha Davis is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Louis Eddie McFadden, who

passed away on August 22, 2012. Ms. Davis contracted for funeral services, including final



167. Plaintiff Martha Davis is also the surviving daughter and next of kin of Cora Lee

Anderson-McFadden, who passed away in June, 2013. Ms. Davis contracted for funeral



168. Plaintiffs Audrey Clarke and Janice Lowe are adult citizens and residents of

Memphis, Shelby County, TN. They are the surviving daughters and next of kin of Cassie J.

Brown, who passed away on December 19, 2012. Ms. Lowe contracted for funeral services,


Directors, Inc.

169. Plaintiffs Rosie and John Moore are citizens and residents of Memphis, Shelby

County, TN. They are the surviving parents and next of kin of Erika M. Denton who passed

away February 13, 2013. Mrs. Moore contracted for funeral services, including final disposition

of the remains at Galilee Memorial Gardens, with Harrison's Funeral Home, Incorporated.

170. Plaintiff Latisha Yates, is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Martha J. Yates, who passed away

38

on December 12, 2011. Ms. Yates contracted for funeral services, including final disposition of


171. Plaintiff Evelyn Sewell, is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving sister and next of kin Herman Liggans, who passed away July

13, 2013. Ms. Sewell contracted for funeral services, including final disposition of the remains

at Galilee Memorial Gardens, with N.J. Ford & Sons Funeral Home Inc.

172. Plaintiff Demetrious Borner, is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving mother and next of kin of De'Andrae Borner, who passed away

November 2, 2011. Ms. Borner contracted for funeral services, including final disposition of the


173. Plaintiffs Fredrick Walker and Janel Williams are adult citizens and residents of

Memphis, Shelby County, TN. They are the surviving children and next of kin of Dorothy

Bowles who passed away April 14, 2012. Ms. Williams contracted for funeral services,


Directors, Inc.

174. Plaintiff, Jessie Williams, is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving father and next of kin of Jerrica Williams who passed away

July 5, 2013. Mr. Williams contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with R.S. Lewis Funeral Home, LLC.

175. Plaintiff, Jane Henderson, is an adult citizen and resident of Memphis, Shelby

County. She is the surviving daughter of Walter Henderson who passed away April 12, 2013.

Plaintiff Rosie Henderson is the surviving spouse and next of kin of Walter Henderson. Ms. Jane

39

Henderson contracted for funeral services, including final disposition of the remains at Galilee


176. Plaintiff Rubesta Taylor, is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving mother of L.C. Taylor, Jr. who passed away in August, 2012.

Ms. Taylor contracted for funeral services, including final disposition of the remains at Galilee


177. Plaintiff Robert Wills and Betty Mae Buggs are adult citizens and residents of

Memphis, Shelby County, TN. They are the surviving parents and next of kin of April Wills who

passed away January 2, 2013. Ms. Buggs contracted for funeral services, including final


178. Plaintiff James E. Fowler, is an adult citizen and resident of Olive Branch, Desoto

County, MS. He is the surviving son and next of kin of Alberta Adams, who passed away May

25, 2013. Mr. Fowler was the beneficiary of the contracts for funeral services, including final

disposition of the remains at Galilee Memorial Gardens, with J.O. Patterson Funeral Home a/k/a

J.O. Patterson Mortuary, Inc.

179. Plaintiff Cantrice Richard, is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving spouse and next of kin of Walter Richard, Sr., who passed

away August 10, 2013. Mrs. Richard contracted for funeral services, including final disposition

of the remains at Galilee Memorial Gardens, with Millington Funeral Home, Inc.

180. Plaintiff Archoketa McGregor, is an adult citizen and resident of Memphis,

Shelby County, TN. She is the surviving daughter and next of kin of Janice Clements who

passed away August 12, 2013. Ms. McGregor contracted for funeral services, including final


40

181. Plaintiff Eddie Fullove is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving father and next of kin of Travis Montell Harris who passed

away April 4, 2012. Plaintiff Lotty Barlow, is an adult citizen and resident of Memphis, Shelby

County, TN and the surviving sister of Travis Montell Harris. Ms. Barlow contracted for funeral

services, including final disposition of the remains at Galilee Memorial Gardens, with Family

Mortuary, Inc.

182. Plaintiff Lamar Thomas, is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving father and next of kin of Nero Thomas who passed away July 9,

2013. Mr. Thomas contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with Mays Funeral Home.

183. Plaintiff Gladys Malone, is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving mother and next of kin of Donald Holmes, Jr., who passed

away in June, 2013. Ms. Malone contracted for funeral services, including final disposition of

the remains at Galilee Memorial Gardens, R.S. Lewis Funeral Home, LLC.

184. Plaintiffs Zachary Jones and Fredia Jones are adult citizens and residents of

Memphis, Shelby County, TN. Plaintiff Keith Jones is an adult citizen and resident of Marion,

Crittenden County, AR. They are the surviving children of Annie Mae Jones, who passed away

in November, 2011. Zachary Jones contracted for funeral services, including final disposition of

the remains at Galilee Memorial Gardens with Harrison’s Funeral Home, Incorporated.

185. Plaintiff Rosemary Mitchell, is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving mother and next of kin of Tamarcus Mitchell, who passed

away September 8, 2013. Ms. Mitchell contracted for funeral services, including final

disposition of the remains at Galilee Memorial Gardens, with Family Mortuary, Inc.

41

186. Plaintiff Cheryl Austin, is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Dora Wilson who passed away

September 22, 2013. Ms. Austin contracted for funeral services, including final disposition of

the remains at Galilee Memorial Gardens, with Jefferson Mortuary.

187. Plaintiff Kimberly Rubin Lacy, is an adult citizen and resident of Memphis,

Shelby County, TN. She is the surviving daughter of Doris Jean Williams who passed away

January 11, 2012. Ms. Lacy is the beneficiary of contracts for funeral services, including final


Home, Inc.

188. Plaintiff Ronald Lewis, is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving spouse and next of kin of Lisa Lewis, who passed away July

17, 2012. Mr. Lewis contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with Family Mortuary, Inc.

189. Plaintiff Ebony Cook is an adult citizen and resident of Memphis, Shelby County,

TN. Plaintiff Rosemary Denton is an adult citizen and resident of Memphis, Shelby County, TN.

Ms. Cook is the surviving daughter and next of kin of Daniel Bridges who passed away October

17, 2011. Ms. Denton contracted for funeral services, including final disposition of the remains

at Galilee Memorial Gardens, with Christian Funeral Directors, Inc..

190. Plaintiff Montritia Short, is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving mother and next of kin of Cortney Gordon, who passed away

September 29, 2011. Ms. Short contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with N.J. Ford & Sons Funeral Home, Inc.

42

191. Plaintiff, Tranell Gipson is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving mother and next of kin of Alfreddie Gipson, who passed away

December 25, 2012. Ms. Gipson contracted for funeral services, including final disposition of


192. Plaintiffs Shirley Henderson and Barbara Young are adult citizens and residents

of Memphis, Shelby County, TN. They are the surviving daughters and next of kin of Maggie

Smith, who passed away September 19, 2012. Ms. Young contracted for funeral services,

including final disposition of the remains at Galilee Memorial Gardens, with N.H. Owens & Son

Funeral Home, Inc.

193. Plaintiff Willie Mae Butts, is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving spouse and next of kin of Tommy Lee Butts who passed away

June 23, 2013. Ms. Butts contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with Christian Funeral Directors, Inc..

194. Plaintiff William Myers is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving brother of Albert Myers, who passed away February 7, 2012.

Mr. Myers contracted for funeral services, including final disposition of the remains at Galilee

Memorial Gardens, with SLS, LLC d/b/a Superior Funeral Home Hollywood Chapel.

195. Plaintiff Eunice Phillips, is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Priscilla Phillips, who passed away

October 29, 2011. Ms. Phillips is the beneficiary of the contracts for funeral services, including


Inc.

43

196. Plaintiff Castina Kunkel, is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Bernice Hill, who passed away

January 7, 2012. Ms. Kunkel contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with E.H. Ford Mortuary Services, Inc..

197. Plaintiff Jacqueline Fondren, is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving sister of William Davis, who passed away March 1, 2013. Ms.

Fondren contracted for funeral services, including final disposition of the remains at Galilee

Memorial Gardens, with M.J. Edwards & Sons Funeral Home, Inc.

198. Plaintiffs Valerie Lily, Tara Martin, Troy McClatchey Evie Winkfield and Helen

Futrell are adult citizens and residents of Memphis, Shelby County, TN. They are the surviving

children and next of kin of Estell Person-Bell, who passed away in August 2011. Ms. Martin


Gardens, with N.H. Owens & Son Funeral Home, Inc.

199. Plaintiffs James Bryant and Deborah Bryant are adult citizens and residents of

Memphis, Shelby County, TN. They are the surviving children and next of kin of Joan

Kuykendall, who passed away September 23, 2013. Ms. Bryant contracted for funeral services,

including final disposition of the remains at Galilee Memorial Gardens, with Family Mortuary,

Inc.

200. Plaintiff Annette Mickens is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving sister and next of kin of Herbert Anderson, who passed away

January 3, 2013. Ms. Mickens is the beneficiary of the contracts for funeral services, including

final disposition of the remains at Galilee Memorial Gardens, with M.J. Edwards –Whitehaven

Funeral Chapel, Inc.

44

201. Plaintiff Christopher Arnold is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving son and next of kin of Christopher Phillips, who passed away

December 26, 2010. Mr. Arnold contracted for funeral services, including final disposition of


202. Plaintiff Belinda Grandy, is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Christine Grandy, who passed

away June 27, 2013. Ms. Grandy contracted for funeral services, including final disposition of


203. Plaintiffs Marquel Downey and Charles Sanders are adult citizens and residents of

Cordova, Shelby County, TN. They are the surviving children and next of kin of Chantel

Sanders, who passed away May 14, 2013. Plaintiff Linda Carr, is an adult citizen and resident of

Cordova, Shelby County, TN. Ms. Carr contracted for funeral services, including final



204. Plaintiff Thelain Taylor, is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving mother and next of kin of Delrico Fernando Taylor, who

passed away on October 20, 2011. Ms. Taylor contracted for and/or was the intended

beneficiary of contracts for funeral services, including final disposition of the remains at Galilee

Memorial Gardens with Millington Funeral Home, Inc.

205. Plaintiffs Rhonda Pollard and Trence Pollard, Sr. are adult citizens and residents

of Bartlett, Shelby County, TN. They are the surviving parents and next of kin of Trence Pollard

who passed away August 5, 2013. Ms. Pollard contracted for funeral services, including final

45

disposition of the remains at Galilee Memorial Gardens, with N.H. Owens & Son Funeral Home,

Inc.

206. Plaintiff Genevieve Prince is an adult citizen and resident of Olive Branch,

Desoto County, MS. Plaintiff Valerie Herron is an adult citizen and resident of Memphis, TN.

They are the surviving daughters and next of kin of Paralee Parrott, who passed away February

15, 2013. The children of Paralee Parrott are the beneficiaries of the contracts for funeral

services, including final disposition of the remains at Galilee Memorial Gardens, with N.H.

Owens & Son Funeral Home, Inc.

207. Plaintiff Cynthia Hines King, is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Cynthia Mattie Hines who passed

away August 23, 2013. Ms. King contracted for funeral services, including final disposition of

the remains at Galilee Memorial Gardens, with R.S. Lewis Funeral Home, LLC.

208. Plaintiff Sherita Broome, is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Miles Broome, Jr., who passed

away October 21, 2013. Ms. Broome contracted for funeral services, including final disposition

of the remains at Galilee Memorial Gardens, with Millington Funeral Home, Inc.

209. Plaintiff Sylvia Garner is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Mary Garner, who passed away

October 14, 201. Ms. Garner is the beneficiary of the contracts for funeral services, including


Inc.

210. Plaintiff Sherica Bonner is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Randy Bonner who passed away

46

May 4, 2012. Ms. Bonner contracted for funeral services, including final disposition of the


211. Plaintiff Nina Williams is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter of Ida Mae Griffin who passed away September 19,

2013. Ms. Williams contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with N. J. Ford & Sons Funeral Home, Inc.

212. Plaintiff Milton Jones, Jr. is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving son and next of kin of Dollie Jones, who passed away

September 5, 2012. Mr. Jones is the beneficiary of the contracts for funeral services, including

final disposition of the remains at Galilee Memorial Gardens, with N. J. Ford & Sons Funeral

Home.

213. Plaintiffs Willie Wells and Betty Smith are adult citizens and residents of

Memphis, Shelby County, TN. They are the surviving children and next of kin of Mary Alice

Wells who passed away August 22, 2012. Ms. Smith contracted for funeral services, including


Inc.

214. Plaintiff Marvin Davis is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving father and next of kin of Marvika Davis, who passed away

February 9, 2013. Mr. Davis contracted for funeral services, including final disposition of the


215. Plaintiff Charlesetta Owens is an adult citizen and resident of Olive Branch,

Desoto County, MS. She is the surviving spouse and next of kin of Charles Edward Owens who

passed away October 23, 2012. Ms. Owens contracted for funeral services, including final

47



216. Plaintiff Rosie Miller is an adult citizen and resident of Memphis, Shelby County,

TN. She is the surviving spouse and next of kin of Robert Miller, who passed away January 17,

2013. Ms. Miller contracted for funeral services, including final disposition of the remains at


217. Plaintiff Pamela Dyer, is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Mary Virginia Dyer who passed

away June 30, 2013. Ms. Dyer contracted for funeral services, including final disposition of the


Chapel.

218. Plaintiff William Cobbs, is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving brother of Carrie Triplett, who passed away September 25,

2011. Mr. Cobbs contracted for funeral services, including final disposition of the remains at


219. Plaintiff Trina Wallace is an adult citizen and resident of Cordova, Shelby

County, TN. She is the surviving daughter of James Carter, Jr. who passed away in September

2012. Ms. Wallace contracted for funeral services including final disposition of the remains at


220. Plaintiff Jerome Peters is an adult citizen and resident of Cordova, Shelby County,

TN. He is the surviving brother of Houston Peters, Jr., who passed away September 30, 2012.

Mr. Peters contracted for funeral services, including final disposition of the remains at Galilee

Memorial Gardens, with E.H. Ford Mortuary Services, Inc.

48

221. Plaintiffs Ulysses Hall, Sr. Annette Stewart and Earline Daniels are adult citizens

and residents of Memphis, Shelby County, TN. They are the surviving children and next of kin

Dora Birk, who passed away June 22, 2011. Ms. Daniels contracted for funeral services,

including final disposition of the remains at Galilee Memorial Gardens, with Jefferson Mortuary.

222. Plaintiff Loistine Malone is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving sister and next of kin of Betty Moody who passed away May

13, 2011. Ms. Malone contracted for funeral services, including final disposition of the remains

at Galilee Memorial Gardens, with M.J. Edwards & Sons Funeral Home, Inc.

223. Plaintiff Frederick Nelson is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving spouse and next of kin of JoAnn Nelson who passed away

November 11, 2011. Mr. Nelson contracted for funeral services, including final disposition of

the remains at Galilee Memorial Gardens, with M.J. Edwards & Sons Funeral Home, Inc.

224. Plaintiff Carolyn Macklin is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Mary Macklin, who passed away

May 8, 2011. Ms. Macklin contracted for funeral services, including final disposition of the


Chapel.

225. Plaintiffs Carolyn Fields and Tammy Taylor are adult citizens and residents of

Memphis, Shelby County, TN. They are the surviving daughters and next of kin of Ossie

Thomas, who passed away January 18, 2012. Ms. Fields contracted for funeral services,



49

226. Plaintiff Frances Whitehead is an adult citizen and resident of Burlison, Tipton

County, TN. She is the surviving daughter and next of kin of Annie L. Dickens who passed

away April 28, 2013. Mrs. Whitehead contracted for funeral services, including final disposition

of the remains at Galilee Memorial Gardens, with M.J. Edwards & Sons Funeral Home, Inc.

227. Plaintiff Waydean Cooper is an adult citizen and resident of Tupelo, Lee County,

MS. She is the surviving spouse and next of kin of Reginald Cooper, who passed away October

17, 2011. Mrs. Cooper contracted for funeral services, including final disposition of the remains

at Galilee Memorial Gardens, with N.J. Ford & Sons Funeral Home Inc.

228. Plaintiff Annette Franklin, is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving mother and next of kin of Quadro Franklin, who passed away

January 23, 2012. Ms. Franklin is the beneficiary of the contracts for funeral services, including


Inc.

229. Plaintiffs Chelsea Shields and Shanetta Shields are adult citizens and residents of

Memphis, Shelby County, TN. They are the surviving daughters and next of kin of Donnell

Carter, Sr., who passed away January 29, 2011. Shanetta Shields contracted for funeral services,

including final disposition of the remains at Galilee Memorial Gardens, with N.H. Owens & Son

Funeral Home, Inc.

230. Plaintiff Rufus Burnett is an adult citizen and resident of Moscow, Fayette

County, TN. He is the surviving nephew of Sallie Dodson, who passed away June 21, 2013. Mr.

Burnett contracted for funeral services, including final disposition of the remains at Galilee

Memorial Gardens, with Snow Funeral Home.

50

231. Plaintiff Imogene Leavy is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Freddie Hampton who passed

away January 8, 2012. Ms. Leavy contracted for funeral services, including final disposition of


232. Plaintiffs Angenette Mukes, Antonio M. Holmes and Paul Crutcher are adult


of kin of James Holmes who passed away September 9, 2012. Mr. Holmes contracted for


M.J. Edwards & Sons Funeral Home, Inc.

233. Plaintiff Judith Cain, is an adult citizen and resident of Arlington, Shelby County,

TN. She is the surviving spouse and next of kin of Calvin Cain, who passed away June 4, 2012.

Mrs. Cain contracted for funeral services, including final disposition of the remains at Galilee

Memorial Gardens, with Millington Funeral Home, Inc.

234. Plaintiff Alsie Reed is an adult citizen and resident of Memphis, Shelby County,

TN. She is the surviving daughter and next of kin of Emma Mitchell who passed away June 2,

2011. Ms. Reed is the beneficiary of the contracts for funeral services, including final

disposition of the remains at Galilee Memorial Gardens, with Snow Funeral Home.

235. Plaintiff Linda Davis is an adult citizen and resident of Memphis, Shelby County,

TN. She is the surviving sister of Thomas Suggs, passed away on April 24, 2013. Ms. Davis



236. Plaintiff Marcus Person is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving brother of Brandon Person, who passed away on April 30,

51

2013. Marcus Person contracted for funeral services, including final disposition of the remains

at Galilee Memorial Gardens, with R.S. Lewis Funeral Home, LLC.

237. Plaintiff Mary Jackson is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving wife and next of kin of Michael Neal, who passed away on

January 1, 2011. Ms. Jackson contracted for funeral services, including final disposition of the


238. Plaintiff Lashun Williams is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Diane Bernal, who passed away on

November 26, 2012. Ms. Williams is the beneficiary of the contracts for funeral services,



239. Plaintiffs Paul Crutcher and Gloria Chandler are adult citizens and residents of

Memphis, Shelby County, TN. Mr. Crutcher is the surviving son and next of kin of Loutricia

Williams, who passed away on July 31, 2012. Ms. Chander contracted for funeral services,



240. Plaintiff Donna Jordan is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving mother and next of kin of Terrell Antonio Jordan, who passed

away on March 6, 2013. Ms. Jordan contracted for funeral services, including final disposition

of the remains at Galilee Memorial Gardens, with SLS, LLC d/b/a Superior Funeral Home

Hollywood Chapel.

241. Plaintiff Girlee Johnson is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving sister and next of kin of Joyce Marie Johnson, who passed

52

away on June 19, 2013. Ms. Johnson is the beneficiary of the contracts for funeral services,

including final disposition of the remains at Galilee Memorial Gardens, with M.J. Edwards

Hillside Chapel, Inc.

242. Plaintiffs Mary Walton and Pamela Jones are adult citizens and residents of

Memphis, Shelby County, TN. Tommy James Dent is an adult citizen and resident of Louisville,

Jefferson County, KY. They are the surviving children and next of kin of Reola Dent, who was

buried at Galilee Memorial Gardens on January 26, 2013. Mrs. Dent’s children contracted for

and were the beneficiaries of contracts for funeral services, including final disposition of the


243. Plaintiff James Jeans is an adult citizen and resident of Memphis, Shelby County,

TN. He is the surviving spouse and next of kin of Robin Jeans, who passed away on June 29,

2013. Plaintiff Lillian Smith is an adult citizen and resident of Memphis, Shelby County, TN.

Ms. Smith contracted for funeral services, including final disposition of the remains at Galilee


244. Plaintiff Sureka Smith is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Dwayne Smith, who passed away

on March 8, 2011. Plaintiff Lillian Smith is an adult citizen and resident of Memphis, Shelby

County, TN. Lillian Smith contracted for funeral services, including final disposition of the


245. Plaintiff Phyllis Burrow is an adult citizen and resident of Obion City, Obion

County, TN. She is the surviving mother and next of kin of Michael Burrow, who passed away

on January 10, 2012. Ms. Burrow contracted for funeral services, including final disposition of

53


Hollywood Chapel.

246. Plaintiff Juaquita Grady is an adult citizen and resident of Westland, Wayne

County, MI. She is the surviving daughter and next of kin of Jacqueline Johnson, who passed

away on March 4, 2013. Ms. Grady contracted for funeral services, including final disposition of

the remains at Galilee Memorial Gardens, with N.H. Owens & Son Funeral Home, Inc.

247. Plaintiff Debra Portwood Allbritton is an adult citizen and resident of Robbins,

Cook County, IL. She is the surviving mother of Taneka Portwood, who passed away on August

18, 2013. Ms. Portwood Allbritton contracted for funeral services, including final disposition of

the remains at Galilee Memorial Gardens, with Calvary Memorial Funeral Home.

248. Plaintiff James Brandon Jones is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving son and next of kin of Marie Whitfield, who passed away on

April 28, 2012. Mr. Jones contracted for funeral services, including final disposition of the


249. Plaintiff Lacedric Woodall is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Anika Starks, who passed away on

August 6, 2013. Ms. Woodall is the beneficiary of the contracts for funeral services, including

final disposition of the remains at Galilee Memorial Gardens, with N.H. Owens & Son Funeral

Home, Inc.

250. Plaintiff Kelvin Jones is an adult citizen and resident of Memphis, Shelby County,

TN. He is the surviving son of Mary Jones, who passed away on August 24, 2011. Kelvin Jones


Gardens, with M.J. Edwards & Sons Funeral Home, Inc.

54

251. Plaintiff Betty Gilmore is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving sister of Paula Gilmore, who passed away on July 30, 2013.

Ms. Gilmore contracted for funeral services, including final disposition of the remains at Galilee

Memorial Gardens, with Joe Ford Funeral Home, LLC.

252. Plaintiffs Telisha Caldwell and Mary Caldwell are adult citizens and residents of

Memphis, Shelby County, TN. Mary Caldwell is the surviving wife and next of kin of Bernie

Caldwell, who passed away on January 6, 2013. Telisha Caldwell contracted for funeral

services, including final disposition of the remains at Galilee Memorial Gardens, with E.H. Ford

Mortuary Services, Inc.

253. Plaintiff Andrea Jones, is an adult citizen and resident of Texarkana, Bowie

County, TX. She is the surviving daughter and next of kin of Dwight McNeil, Sr., who passed

away on March 28, 2011. Ms. Jones contracted for funeral services, including final disposition

of the remains at Galilee Memorial Gardens, with M.J. Edwards Hillside Chapel, Inc.

254. Plaintiff Madelene Chatmon is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Maggie Chatmon, who passed

away on August 24, 2012. Ms. Chatmon is the beneficiary of the contracts for funeral services,



255. Plaintiff Patricia Kennedy is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Betty Williams, who passed away

on November 24, 2011. Ms. Kennedy contracted for funeral services, including final disposition

of the remains at Galilee Memorial Gardens, M.J. Edwards-Whitehaven Funeral Chapel, Inc.

55

256. Plaintiff George Longmire is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving son of Marie Deberry, who passed away on November 5, 2012.

Mr. Longmire contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with SLS, LLC d/b/a Superior Funeral Home Hollywood Chapel.

257. Plaintiff Devin Brook is an adult citizen and resident of Memphis, Shelby County,

TN. He is the surviving son and next of kin of Robert Stevenson, who passed away on

December 11, 2012. Mr. Brook is the beneficiary of contracts for funeral services, including


Inc.

258. Plaintiff Linda Perkins is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Pauline Perkins, who passed away

on September 20, 2012. Ms. Perkins is the beneficiary of the contracts for funeral services,

including final disposition of the remains at Galilee Memorial Gardens, with N.J. Ford & Sons

Funeral Home Inc.

259. Plaintiff Murphy Jamison is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving mother of Bossie Jamison, who passed away on May 28, 2013.

Ms. Jamison contracted for funeral services, including final disposition of the remains at Galilee


260. Plaintiffs Mark Love, Aretta Love and Ruth Love are adult citizens and residents

of Memphis, Shelby County, TN. They are the surviving siblings and next of kin of Gary Love,

who passed away on October 25, 2012. Mark and Ruth Love contracted for funeral services,

including final disposition of the remains at Galilee Memorial Gardens, with Millington Funeral

Home, Inc.

56

261. Plaintiff Gwen Gary is an adult citizen and resident of Arlington, Shelby County,

TN. Plaintiff Denise Edwards is an adult citizen and resident of Memphis, Shelby County, TN.

They are the surviving daughters and next of kin of Dorothy Ivra-Edwards, who passed away on

August 14, 2011. Ms. Gary is the beneficiary of the contracts for funeral services, including


Chapel, Inc.

262. Plaintiff Melvin Easley is an adult citizen and resident of Oakland, Fayette

County, TN. He is the surviving son and next of kin of Peggy Culbreath, who passed away on

May 7, 2012. Mr. Easley contracted for funeral services, including final disposition of the


263. Plaintiff Mamie Holloway is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving mother and next of kin of Leslie Lashae Holloway, who passed

away on February 18, 2013. Ms. Mamie Holloway contracted for funeral services, including


Chapel, Inc.

264. Plaintiffs Janet Brown and Teresa Jones are adult citizens and residents of

Holcomb, Grenada County, MS. Plaintiff Roland Jones III is an adult citizen and resident of San

Diego, San Diego County, CA. They are the surviving children and next of kin of Roland Jones,

Jr., who passed away on December 13, 2012. Plaintiff Bessie Futrell is an adult citizen and

resident of Bartlett, Shelby County, TN. Ms. Futrell contracted for funeral services, including

final disposition of the remains at Galilee Memorial Gardens, with N.H. Owens and Son Funeral

Home, Inc.

57

265. Plaintiff Lakiesha Rodgers is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving wife and next of kin of Carlo Montas Rodgers, who was buried

at Galilee Memorial Gardens on November 12, 2011. Mrs. Rodgers is the beneficiary of

contracts for funeral services, including final disposition of the remains at Galilee Memorial

Gardens, with Harrison's Funeral Home, Incorporated.

266. Plaintiff Patricia Perry is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving wife and next of kin of Frank Perry, Jr., who passed away on

February 2, 2011. Plaintiff Jennifer Perry is an adult citizen and resident of Memphis, Shelby

County, TN. Patricia Perry and Jennifer Perry contracted for funeral services, including final

disposition of the remains at Galilee Memorial Gardens, with M.J. Edwards-Whitehaven Funeral

Chapel, Inc.

267. Plaintiffs A.D. Lanier and Vernese Williams are adult residents and citizens of

Memphis, Shelby County TN. They are the surviving children and next of kin of Sarah Mitchell,

who passed away on July 20, 2013. They contracted for funeral services, including final


Home, Inc.

268. Plaintiff Willie Green is an adult citizen and resident of Memphis, Shelby County,

TN. He is the surviving son and next of kin of Willie H. Green, Jr., who was buried at Galilee

Memorial Gardens on July 13, 2013. Mr. Green is the beneficiary of the contracts for funeral

services, including final disposition of the remains at Galilee Memorial Gardens, with V.H. Bins

& Son Mid-South Funeral Home.

269. Plaintiff Cora Allen is an adult citizen and resident of Memphis, Shelby County,

TN. She is the surviving wife and next of kin of James C. Allen, Jr., who passed away on

58

October 22, 2011. She was the beneficiary of contracts for funeral services, including final

disposition of the remains at Galilee Memorial Gardens, with N. H. Owens and Sons Funeral

Home.

270. Plaintiffs Dana Franklin, Alicia Grandberry, are adult citizens and residents of

Memphis, Shelby County, TN. They are the surviving children and next of kin of Alice

Franklin, who passed away on June 4, 2011. Dana Franklin contracted for funeral services,



271. Plaintiff Martharene McMullen is an adult citizen and resident of Memphis,

Shelby County, TN. She is the surviving wife and next of kin of James McMullen, who passed

away on June 24, 2013. Mrs. McMullen is the beneficiary of the contracts for funeral services,

including final disposition of the remains at Galilee Memorial Gardens, with N. H. Owens and


272. Plaintiff Toni Taylor is an adult citizen and resident of Memphis, Shelby County,

TN. She is the surviving daughter and next of kin of Joseph Bland Taylor, Jr., who passed away

on October 3, 2011. Ms. Taylor is the beneficiary of the contracts for funeral services, including


Inc.

273. Plaintiff Conqualla Lee is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving wife and next of kin of Frank M. Lee, Sr., who passed away on

November 15, 2012. Ms. Lee contracted for funeral services, including final disposition of the


59

274. Plaintiff Arneka Branch is an adult citizen and resident of Chicago, Cook County,

IL. She is the surviving daughter and next of kin of Mary Victoria Baker, who passed away on

May 11, 2012. Arneka Branch contracted for funeral services, including final disposition of the


275. Plaintiff Shirley Taylor is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving mother and next of kin of Crystal Hill, who passed away on

December 24, 2011. Ms. Taylor contracted for funeral services, including final disposition of the


276. Plaintiff Nikesha Gordon is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Carolyn A. Brown, who passed

away on January 13, 2012. Ms. Gordon contracted for funeral services, including final


277. Plaintiff Geneva V. Storey is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Lois McGlaun, who passed away

on March 6, 2012. Plaintiff Beverly Prye is an adult resident and citizen of Memphis, Shelby

County, TN. Ms. Storey and Ms. Prye contracted for funeral services, including final disposition

of the remains at Galilee Memorial Gardens, with M.J. Edwards-Whitehaven Funeral Chapel,

Inc.

278. Plaintiffs Terrance Williams, Toya Williams are adult citizens and residents of

Memphis, Shelby County, TN. They are the surviving children and next of kin of Betty

Williams, who was buried at Galilee Memorial Gardens on June 10, 2013. Toya Williams


Gardens, with M.J. Edwards-Whitehaven Funeral Chapel, Inc.

60

279. Plaintiff Jermaine Moore, Sr. is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving father and next of kin of Jermaine D. Moore, Jr., who passed

away on June 14, 2011. Mr. Moore contracted for funeral services, including final disposition of


280. Plaintiff Jovan Douglas is a resident of Memphis, Shelby County, TN. She is the

surviving wife and next of kin of Ray Anthony Douglas, Jr., who passed away on September 2,

2011. Ms. Douglas is the beneficiary of the contracts for funeral services, including final



281. Plaintiff Delores Moss and Patrick Payne are adult citizens and residents of

Memphis, Shelby County, TN. They are the surviving siblings and next of kin of Charlene

Haymon, who passed away on April 6, 2012. Ms. Moss and Mr. Payne contracted for funeral



282. Plaintiff Janet Alexander is a citizen and resident of Memphis, Shelby County,

TN. She is the surviving spouse and next of kin of Marshall Earl Alexander. Plaintiff Glenn

Alexander is a citizen and resident of Memphis, Shelby County, TN. He is the surviving brother

of Marshall Earl Alexander, who passed away on December 8, 2012. Mr. Alexander contracted



283. Plaintiff Eula Jackson is an adult citizen and resident of Memphis, Shelby County,

TN. She is the surviving sister and next of kin of Marjorie Pruitt, who passed away on January

61

22, 2012. Ms. Jackson is the beneficiary of the contracts for funeral services, including final


284. Plaintiff George Sims is an adult citizen and resident of Memphis, Shelby County,

TN. He is the surviving husband and next of kin of Peggy Sims, who passed away on March 28,

2012. Mr. Sims is the beneficiary of the contracts for funeral services, including final disposition

of the remains at Galilee Memorial Gardens, with Jefferson Mortuary.

285. Plaintiff Jasmine N. Joiner is a citizen and resident of Memphis, Shelby County,

TN. She is the surviving daughter and next of kin of Peggy Joiner, who passed away on October

4, 2013. Plaintiffs Robert and Martha Joiner are citizens and residents of Memphis, Shelby

County, TN. Mr. & Mrs. Joiner contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with N.H. Owens & Son Funeral Home, Inc.

286. Plaintiff Tiwana McNeal is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter of Renita Brown Richardson, who was buried at

Galilee Memorial Gardens on November 24, 2012. Ms. McNeal contracted for funeral services,



287. Plaintiffs Tracey Holmes, Yolanda M. Herring and Robert Herring, Jr. are adult


of kin of Josephine Herring, who passed away on March 5, 2012. Ms. Holmes contracted for



288. Plaintiff Roberta Spicer is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving wife and next of kin of Alvin Spicer, who passed away on

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December 29, 2010. Mrs. Spicer Holmes contracted for funeral services, including final



289. Plaintiffs Jamie Bell, Marcus Bell and Shenika Bell are adult citizens and

residents of Memphis, Shelby County, TN. Plaintiff Maurice Anderson is an adult citizen and

resident of Jacksonville, Duval County, FL. They are the surviving children of Doris Bell, who

passed away on July 18, 2011. Mr. Anderson Holmes contracted for funeral services, including

final disposition of the remains at Galilee Memorial Gardens, with Millington Funeral Home,

Inc.

290. Plaintiff Julia Banks is an adult citizen and resident of Memphis, Shelby County,

TN. She is the surviving wife and next of kin of Freddie Banks, who passed away on April 12,

2011. Mrs. Banks contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with E.H. Ford Mortuary Services, Inc.

291. Plaintiff Bobbie Jean Johnson is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving sister and next of kin of Robbie Anderson, who passed away

on June 14, 2012. Ms. Johnson was the beneficiary of the contracts for funeral services,


Directors, Inc.

292. Plaintiff Rodney Williams is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving son and next of kin of Harold Williams, who passed away on

December 21, 2010. Mr. Williams contracted for funeral services, including final disposition of

the remains at Galilee Memorial Gardens to take place on January 5, 2011, with E.H. Ford

Mortuary Services, Inc.

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293. Plaintiff Betty Reed is an adult citizen and resident of Memphis, Shelby County,

TN. She is the surviving sister and next of kin of Rickey Dancy, who passed away on June 25,

2011. Ms. Reed is the beneficiary of the contracts for funeral services, including final


294. Plaintiff Katrina Livingston is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Maurice Wolfe, who passed away

on April 10, 2012. Ms. Livingston is the beneficiary of the contracts for funeral services,

including final disposition of the remains at Galilee Memorial Gardens, with Joe Ford Funeral

Home, LLC.

295. Plaintiff William Bowman is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving brother and next of kin of Isiah Bowman, who passed away on

October 13, 2012. Mr. Bowman contracted for funeral services, including final disposition of the


296. Plaintiff Shaquille Echols is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Melandie Tuggle, who passed

away on July 1, 2012. Ms. Echols is the beneficiary of the contracts for funeral services,



297. Plaintiffs April Rodgers and Nakiesha Powell are adult citizens and residents of

Memphis, Shelby County, TN. Plaintiff NaQuasha Rodgers is an adult citizen and resident of

Nashville, Davidson County, Tennessee. Plaintiff Randy Powell is an adult citizen and resident

of Jackson, Madison County, TN. They are the surviving children and next of kin of Nina

Powell, who passed away November 23, 2011. Plaintiff Jesse William Powell is a citizen and

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resident of Memphis, Shelby County, Tennessee. Jesse Powell contracted for funeral services,

including final disposition of the remains at Galilee Memorial Gardens, with SLS, LLC aka


298. Plaintiff Michelle Walton is an adult citizen and resident of Cordova, Shelby

County, TN. She is the surviving mother and next of kin of Curtis Ross, Jr., who passed away on

February 22, 2013. Ms. Walton contracted for funeral services, including final disposition of the


299. Plaintiff Jarvis Brown is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving father and next of kin of Jocquarius Brown, who passed away

on February 3, 2012. Mr. Brown contracted for funeral services, including final disposition of


300. Plaintiff Gladys Dorsey is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving wife and next of kin of Joe Dorsey, Jr., who passed away on

November 17, 2013. Mrs. Dorsey contracted for funeral services, including final disposition of

the remains at Galilee Memorial Gardens, with Millington Funeral Home, Inc.

301. Plaintiff Tyrone Miles is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving son and next of kin of William Campbell, who passed away on

September 4, 2012. Tyrone Miles contracted for funeral services, including final disposition of


302. Plaintiff Oretha Humphrey is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving wife and next of kin of Robert Humphrey, who passed away

on April 27, 2013. Mrs. Humphrey contracted for funeral services, including final disposition of


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303. Plaintiff Edward Bradley is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving son and next of kin of Earnestine Everhart, who passed away

on October 5, 2013. Mr. Bradley contracted for funeral services, including final disposition of


304. Plaintiff Cedric Kearney is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving son and next of kin of Jimmy Kearney, who passed away on

February 14, 2012. Mr. Kearney contracted for funeral services, including final disposition of


305. Plaintiff Alrenzo Robinson is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving son and next of kin of Cathy Robinson, who passed away on

May 23, 2012. Alrenzo Robinson contracted for funeral services, including final disposition of


306. Plaintiff Vinton Barnes is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving husband and next of kin of Patti Barnes, who passed away on

October 6, 2011. Plaintiff Quinnie Burks is an adult citizen and resident of Memphis, Shelby

County, TN. Ms. Burks contracted for funeral services, including final disposition of the


307. Plaintiff Shadia Rice is an adult citizen and resident of Memphis, Shelby County,

TN. She is the surviving daughter and next of kin of Ella Ward, who passed away on November

8, 2011. Ms. Rice contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with N.J. Ford & Sons Funeral Home Inc.

308. Plaintiff Barbara Jones is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving mother of Jameel Galloway, who passed away in August,

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2012. Ms. Jones contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with M.J. Edwards Hillside Chapel, Inc.

309. Plaintiff Penina Sims-Granville is an adult citizen and resident of Memphis,

Shelby County, TN. She is the surviving wife and next of kin of Carl Granville, who passed

away on December 6, 2012. Mrs. Sims-Granville contracted for funeral services, including final

disposition of the remains at Galilee Memorial Gardens, with SLS, LLC aka Superior Funeral


310. Plaintiff Carlester Harris is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving son of Rosetta Jordan, who passed away in February, 2012.

Mr. Harris contracted for funeral services, including final disposition of the remains at Galilee

Memorial Gardens, with M.J. Edwards-Whitehaven Funeral Chapel, Inc.

311. Plaintiffs Antwaun Williams and Antonio McDaniel are adult citizens and


Juanita Malone, who passed away on October 25, 2012. Ms. Malone’s children contracted for

and were the beneficiaries of contracts for funeral services, including final disposition of the

remains at Galilee Memorial Gardens with Joe Ford Funeral Home, LLC.

312. Plaintiff Larry Whitelow is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving brother and next of kin of Gloria J. Whitelow, who passed away

on March 18, 2011. Mr. Whitelow contracted for funeral services, including final disposition of

the remains at Galilee Memorial Gardens with Christian Funeral Directors, Inc.

313. Plaintiff Sabrina Bruce is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Sadie Avant, who passed away on

July 13, 2013. Ms. Bruce contracted for funeral services, including final disposition of the

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remains at Galilee Memorial Gardens with SLS, LLC d/b/a Superior Funeral Home Hollywood

Chapel.

314. Plaintiff Bryon Stokes is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving son of Freeman Russell, who passed away on December 30,

2010. Mr. Stokes contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens to take place on January 8, 2011 with Golden Gate Funeral Home.

315. Plaintiffs Desmond McNutt and Arisha McNutt are adult citizens and residents of

Memphis, Shelby County, TN. They are the surviving children and next of kin of Naketh

McNutt, who passed away on September 23, 2011. The children of Naketh McNutt are the

beneficiaries of the contracts for funeral services, including final disposition of the remains at

Galilee Memorial Gardens with E.H. Ford Mortuary Services, Inc.

316. Plaintiffs Gregory Johnson, Lawanda Alexander, Monroe Alexander and Everette

Alexander are adult citizens and residents of Memphis, Shelby County, TN. They are the

surviving children and next of kin of Katherine Alexander, who passed away on August 27,

2011. Monroe Alexander contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens with Christian Funeral Directors, Inc.

317. Plaintiffs Gregory Johnson, Lawanda Alexander, Monroe Alexander and Everette

Alexander are also the surviving siblings and next of kin of Kathleen Alexander, who passed

away on September 9, 2011. Mr. Johnson contracted for funeral services, including final

disposition of the remains at Galilee Memorial Gardens with Christian Funeral Directors, Inc.

318. Plaintiff Angela Davis is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Gloria Anderson, who passed away

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on December 7, 2012. Ms. Davis contracted for funeral services, including final disposition of

the remains at Galilee Memorial Gardens with M.J. Edwards Hillside Chapel, Inc.

319. Plaintiff Myra Jenkins is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Roy C. Britton, who passed away

on July 15, 2011. Ms. Jenkins contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens with N.J. Ford & Sons Funeral Home Inc.

320. Plaintiff Baby Ruth Sanders is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Clide Chapman, who passed away

on December 29, 2010. Ms. Sanders contracted for funeral services, including final disposition

of the remains at Galilee Memorial Gardens to take place on January 8, 2011, with M.J. Edwards

& Sons Funeral Home, Inc.

321. Plaintiff JoAnn Ireland is an adult citizen and resident of Southaven, Desoto

County, MS. She is the surviving daughter and next of kin of Joe Epps, who passed away on

September 7, 2012. Ms. Ireland contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens with SLS, LLC d/b/a Superior Funeral Home Hollywood

Chapel.

322. Plaintiff Jundis Noble is an adult citizen and resident of Memphis, Shelby County,

TN. He is the surviving son and next of kin of Morris C. Fisher, who passed away on June 24,

2013. Mr. Noble contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens with M.J. Edwards Hillside Chapel, Inc.

323. Plaintiff Shirley H. Johnson is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving wife and next of kin of Gentry Johnson, Sr., who passed away

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on December 16, 2012. Mrs. Johnson contracted for funeral services, including final disposition

of the remains at Galilee Memorial Gardens with N.J. Ford & Sons Funeral Home Inc.

324. Plaintiff John Lane is an adult citizen and resident of Memphis, Shelby County,

TN. He is the surviving spouse and next of kin of Ruth Lane, who was passed away on

September 29, 2011. Mr. Lane contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens with Christian Funeral Directors, Inc.

325. Plaintiff Toya Malone is an adult citizen and resident of Summerville, SC. She is

the surviving daughter and next of kin of Gwendolyn Malone, who passed away on September 8,

2013. Ms. Malone contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens with N.J. Ford & Sons Funeral Home Inc.

326. Plaintiff Sunny McGhee is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter and next of kin of Carol Matthews, who passed away

on August 19, 2011. Plaintiff Judy Johnson is an adult citizen and resident of Memphis, Shelby

County, TN. Ms. Johnson contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens with E.H. Ford Mortuary Services, Inc.

327. Plaintiff Jonathan McKay is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving son and next of kin of Quincy McKay, who passed away on

November 21, 2012. Mr. McKay is the beneficiary of the contracts for funeral services,

including final disposition of the remains at Galilee Memorial Gardens with SLS, LLC d/b/a


328. Plaintiffs Patsy McKinley and Earl Johnson, Sr. are adult citizens and residents of

Memphis, Shelby County, TN. They are the surviving parents and next of kin of Dennis

McKinley, who passed away on October 13, 2011. Ms. McKinley contracted for funeral

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services, including final disposition of the remains at Galilee Memorial Gardens with SLS, LLC


329. Plaintiff Sadie King is an adult citizen and resident of Memphis, Shelby County,

TN. She is the surviving daughter of Ressie Perry, who passed away on May 8, 2012. Ms. King


Gardens with M.J. Edwards Hillside Chapel, Inc.

330. Plaintiff Connie Wilburn is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving wife and next of kin of Roy Wilburn, Sr., who passed away on

March 18, 2011. Mrs. Wilburn contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens with M.J. Edwards & Sons Funeral Home, Inc.

331. Plaintiff Evelyn Payne is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving mother and next of kin of Robert Simmons, who passed away

on August 29, 2013. Ms. Payne contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens with Family Mortuary, Inc.

332. Plaintiff Lillian Smith is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving mother and next of kin of Dwayne Smith, who passed away on

March 8, 2011. Ms. Smith is the beneficiary of the contracts for funeral services, including final

disposition of the remains at Galilee Memorial Gardens with Christian Funeral Directors, Inc.

333. Plaintiff Gwenda Tate is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving sister of Larry Tate, who passed away on June 25, 2011. Ms.

Tate contracted for funeral services, including final disposition of the remains at Galilee

Memorial Gardens with SLS, LLC d/b/a Superior Funeral Home Hollywood Chapel.

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334. Plaintiff Gwenda Tate is also the surviving daughter and next of kin of Mildred

Tate, who passed away on January 23, 2011. Ms. Tate contracted for funeral services, including

final disposition of the remains at Galilee Memorial Gardens with SLS, LLC d/b/a Superior

Funeral Home Hollywood Chapel.

335. Plaintiff Rafiel Wilkins is an adult citizen and resident of Memphis, Shelby

County, TN. He is the surviving son and next of kin of Shirley Wilkins, who passed away on

July 21, 2013. Mr. Wilkins is the beneficiary of the contracts for funeral services, including final

disposition of the remains at Galilee Memorial Gardens with M.J. Edwards & Sons Funeral

Home, Inc.

336. Plaintiff Tiffany Armstrong is an adult citizen and resident of Memphis, Shelby

County, TN. She is the surviving daughter of Hazel Williams, who passed away on December

21, 2012. Ms. Armstrong contracted for funeral services, including final disposition of the


337. Plaintiffs Willie Wells, Jr. and Betty Smith are adult citizens and residents of

Memphis, Shelby County, TN. They are the surviving children of Mary Wells, who passed away

on August 22, 2012. The children of Mary Wells are the beneficiaries of the contracts for

funeral services, including final disposition of the remains at Galilee Memorial Gardens with


338. Plaintiffs Carl Black and Risonia Black are adult citizens and residents of

Memphis, Shelby County, TN. They are the surviving children and next of kin of Matthew

Black, who passed away on June 6, 2013. Risonia Black contracted for funeral services,

including final disposition of the remains at Galilee Memorial Gardens with Christian Funeral

Directors, Inc.

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339. Plaintiffs Keynan Banks, Larry Page, Tevin Banks Kendra Banks and Kiomotti T.

Banks are citizens and residents of Memphis, Shelby County, TN. They are the surviving

children and next of kin of Jacqueline Banks, who passed away on January 1, 2013. Kendra

Banks contracted for funeral services, including final disposition of the remains at Galilee

Memorial Gardens with M.J. Edwards & Sons Funeral Home, Inc.

340. Plaintiff Barbara Smith is a citizen and resident of Memphis, Shelby County, TN.

She is the surviving spouse and next of kin of Calvin James Smith, who passed away on August

5, 2013. Plaintiff Nellie Smith-Brown is a citizen and resident of Orange Park, Clay County,

FL. Ms. Smith-Brown contracted for funeral services, including final disposition of the remains

at Galilee Memorial Gardens with N.J. Ford & Sons Funeral Home Inc.

341. Plaintiff John Glass is a citizen and resident of Memphis, Shelby County, TN. He

is the surviving spouse and next of kin of Delinda Michelle Glass, who passed away on

November 2, 2013. Mr. Glass contracted for funeral services, including final disposition of the


342. Plaintiff Johnella Gant is a citizen and resident of Memphis, Shelby County, TN.

She is the surviving daughter and next of kin of Mary Suell who passed away on August 12,

2013. Ms. Gant was the beneficiary of the contracts for funeral services including final

disposition of the remains at Galilee Memorial Gardens with Joe Ford Funeral Home, LLC.

343. Plaintiff Bennie Williams is a citizen and resident of Memphis, Shelby County,

TN. He is the surviving husband and next of kin of Peggy Cobbins, who passed away on

November 13, 2012. Mr. Williams is the beneficiary of the contracts for funeral services,

including final disposition of the remains at Galilee Memorial Gardens with SLS, LLC d/b/a


73

344. Plaintiff Helen Green is a citizen and resident of Memphis, Shelby County, TN.

She is the surviving sister of Lloyd Dale Anderson, who passed away on November 7, 2013.

Ms. Green contracted for funeral services, including final disposition of the remains at Galilee

Memorial Gardens with SLS, LLC d/b/a Superior Funeral Home Hollywood Chapel.

345. Plaintiff Debra Allen is citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving daughter and next of kin of Tommie Lee Allen, Sr., who died on

June 23, 2013. Ms. Allen contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with Christian Funeral Directors, Inc., in Memphis,

Tennessee.

346. Plaintiff Alisha Bell is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving daughter and next of kin of David Bell, who died on September

1, 2011. Ms. Allen contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with Christian Funeral Directors, Inc., in Memphis, Tennessee.

347. Plaintiffs Teresa Robinson and Farlisha Bratcher are citizens and residents of

Memphis, Shelby County, Tennessee. Teresa Robinson and Farlisha Bratcher are the surviving

daughters of Elizabeth Bratcher, who died October 30, 2012. Ms. Robinson contracted for


Christian Funeral Directors, Inc., in Memphis, Tennessee.

348. Plaintiff Marquita Brownlee is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving daughter and next of kin of Louis C. McCoy, Jr., who died on

April 3, 2012. Ms. Brownlee contracted for funeral services, including final disposition of the


Tennessee.

74

349. Plaintiffs Linder Cain and Lantreke T. Chambers are citizens and residents of

Memphis, Shelby County, Tennessee. Ms. Cain is the surviving wife and next of kin of Tharon

Cain, who died on May 7, 2013. Mr. Lantreke is the surviving son of Tharon Cain. Ms. Cain and

Mr. Chambers contracted for funeral services, including final disposition of the remains at


350. Plaintiff L.C. Cannon is a citizen and resident of Memphis, Shelby County,

Tennessee. He is the surviving Father and next of kin of Ruby Jean Cannon, who died on August

25, 2011. Mr. Cannon contracted for funeral services, including final disposition of the remains

at Galilee Memorial Gardens, with Christian Funeral Directors, Inc., in Memphis, Tennessee.

351. Plaintiffs Ralph Ray Cross and Cheryl Cross are citizens and residents of

Memphis, Shelby County, Tennessee. They are the surviving parents of Christopher R. Cross,

who died on June 2, 2012. Mr. & Ms. Cross contracted for funeral services, including final

disposition of the remains at Galilee Memorial Gardens, with Christian Funeral Directors, Inc.,

in Memphis, Tennessee.

352. Plaintiff Tajuana Davison is a citizen and resident of Memphis, Shelby County,

Tennessee. Plaintiff Johnnie L. Davis is a citizen and resident of Memphis, Shelby County,

Tennessee. Ms. Davison is the surviving daughter of Yolanda Davison, who died on November

27, 2012. Mr. Davis is the surviving spouse and next of kin of Yolanda Davison. Ms. Davison

contracted for funeral services, including the final disposition of the remains at Galilee Memorial

Gardens, with Christian Funeral Directors, Inc., in Memphis, Tennessee.

353. Plaintiffs Devornia Flynn and Willie Hailey are citizens and residents of

Memphis, Shelby County, Tennessee. They are the surviving siblings of L.Q. Hailey, who died

on January 17, 2012. Plaintiffs DeAndre Haley, Aisha Higgins and Monisha Higgins are the

75

surviving children and next of kin of L.Q. Hailey. Plaintiffs Ms. Flynn and Mr. Hailey



354. Plaintiff Bessie L. Franklin and Melissa King Lesure are citizens and resident of

Memphis, Shelby County, Tennessee. Ms. Franklin is the surviving mother and next of kin of

Sidney Franklin, who died on January 9, 2013. Melissa King Lesure, sister of the deceased,



355. Plaintiff Sylvia Harris is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving mother and next of kin of Shanna Harris Garrett, who died on

July 28, 2012. Ms. Harris contracted for funeral services, including final disposition of the


Tennessee.

356. Plaintiff Cynthia Hill is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving wife and next of kin of William Hill, who died on August 22,

2013. Ms. Hill contracted for funeral services with, including final disposition of the remains at

Galilee Memorial Gardens, Christian Funeral Directors, Inc., in Memphis, Tennessee.

357. Plaintiff Roosevelt Hodge is a citizen and resident of Memphis, Shelby County,

Tennessee. He is the surviving brother and next of kin of Bernice Hickman, who died on March

17, 2011. Mr. Hodge contracted for funeral services, including final disposition of the remains at


358. Plaintiff Angelique Johnson is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving granddaughter of Peatron Lee O’Neal, who died on December 3,

76

2012. Ms. Johnson contracted for funeral services, including the final disposition of the remains


359. Plaintiff Angelique Johnson, Plaintiff Rodney Carpenter and Plaintiff Yull

Carpenter are citizen and resident of Memphis, Shelby County, Tennessee. They are surviving

children and next of kin of Barbara Carpenter, who died on June 3, 2013. Ms. Johnson contracted


Christian Funeral Directors, Inc., in Memphis, Tennessee.

360. Plaintiff Izelia King is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving sister of Tommie L. Temple, who died on July 12, 2011. Ms.

King contracted for funeral services, including final disposition of the remains at Galilee

Memorial Gardens, with Christian Funeral Directors, Inc., in Memphis, Tennessee.

361. Plaintiff Etheal Lewis is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving mother and next of kin of Caldricka Banks, who died on July 13,

2013. Ms. Lewis contracted for funeral services, including final disposition of the remains at


362. Plaintiff Janice Lowe is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving daughter and next of kin of Cassie Jean Brown, who died on

December 19, 2012. Ms. Lowe contracted for funeral services, including final disposition of the


Tennessee.

363. Plaintiff Wesley Moore and Cindy Rector are citizens and residents of Memphis,

Shelby County, Tennessee. Mr. Moore is the surviving fiancé of Lori Taylor, who died on

November 11, 2011. Ms. Rector is the surviving mother and next of kin of Lori Taylor. Mr.

77

Moore and Ms. Rector contracted for funeral services, including final disposition of the remains


364. Plaintiff Carla Moten is a citizen and resident of Memphis, Shelby County,

Tennessee. Plaintiffs Annette Reed and Ronrico Reed are citizens and residents of Memphis,

Shelby County, Tennessee and the surviving children and next of kin of Antoinette Reed, who

died on February 18, 2013. Ms. Moten and Ms. Reed contracted for funeral services, including


Inc., in Memphis, Tennessee.

365. Plaintiffs Annette Reed and Ronrico Reed are a citizens and residents of

Memphis, Shelby County, Tennessee. They are the surviving grandchildren and next of kin of

Jessie Reed, who died on November 18, 2011. They are also the surviving children and next of

kin of Antoinette Reed who was the daughter of the deceased. Ms. Antoinette Reed, prior to her

death, contracted for funeral services, including final disposition of the remains at Galilee

Memorial Gardens, with Christian Funeral Directors, Inc., in Memphis, Tennessee.

366. Plaintiff Annie Remble is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving sister and next of kin of Willie Boxson Lee, who died on July 19,

2013. Ms. Remble contracted for funeral services, including final disposition of the remains at


367. Plaintiffs Donald Starks, Jacqueline Garrett, Glenn Starks, Eddie Starks are

citizens and residents of Memphis, Shelby County, Tennessee. They are the surviving siblings

and next of kin of Tony Starks, who died in December, 2013. Mr. Eddie Stark and Ms.

Jacqueline Garrett contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with Christian Funeral Director, Inc., in Memphis, Tennessee.

78

368. Plaintiffs Brandi Neely Stevenson and Brieanna Neely are citizens and residents

of Memphis, Shelby County, Tennessee. Ms. Brieanna Neely is the surviving daughter and next

of kin of Richard Neely, who died on April 22, 2011. Ms. Neely and Ms. Stevenson contracted


Christian Funeral Director, Inc., in Memphis, Tennessee.

369. Plaintiff Linda Wallace, Daniel Wallace, Terry Wallace and Margaret Dowell are

citizens and resident of Arlington, Shelby County, Tennessee. They are the surviving sisters and

brothers and next of kin of Percy Wallace, who died on January 18, 2012. Linda Wallace


Garden, with Christian Funeral Director, Inc., in Memphis, Tennessee.

370. Plaintiffs Ciara Young and Lue Birdia Young are citizens and residents of

Memphis, Shelby County, Tennessee. Ms. Ciara Young is the surviving niece of Curtis Lee

Bonds. Ms. Lue Birdia Young is the surviving mother and next of kin of Curtis Lee Bonds, who

died on June 10, 2013. Ms. Ciara Young contracted for funeral services, including final

disposition of the remains at Galilee Memorial Gardens, with Christian Funeral Director, Inc., in

Memphis, Tennessee.

371. Plaintiff James Beans is a citizen and resident of Cordova, Shelby County,

Tennessee. Plaintiff Ora Wheeler, Marie Kennon, Joyce Beans, Terry Beans and Rose Beans are

citizens and residents of Memphis, Shelby County, Tennessee. They are the surviving children

and next of kin of Ozella Beans, who died on July 8, 2011. Mr. James Beans, Ms. Ora Wheeler

and Ms. Marie Kennon contracted for funeral services, including the final disposition of the

remains at Galilee Memorial Gardens, with E.H. Ford Mortuary Services, in Memphis,

Tennessee.

79

372. Plaintiff Danielle Conner is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving daughter and next of kin of Barbara J. Conner, who died on April

25, 2012. Ms. Conner contracted for funeral services, including final disposition of the remains

at Galilee Memorial Gardens, with E.H. Ford Mortuary Services, in Memphis, Tennessee.

373. Plaintiff Barbara Day is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving Daughter and next of kin of Georgia Mitchell, who died May 19,

2012. Ms. Day contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with E.H. Ford Mortuary Services, in Memphis, Tennessee.

374. Plaintiff Ernest Love is a citizen and resident of Memphis, Shelby County,

Tennessee. He is the surviving father of Anitra Love, who died on June 22, 2013. Ms. Tamica

Moscato is a citizen and resident of Olive Branch, Mississippi. Ms. Tamaria Richardson is a

citizen and resident of Atlanta, Georgia. Ms. Moscato and Ms. Richardson are surviving

daughters and next of kin of Anitra Love. Mr. Ernest Love contracted for funeral services,


Services, in Memphis, Tennessee.

375. Plaintiff Evelyn Gilmore is a citizen and resident of Memphis, Shelby County,

Tennessee. Plaintiff Veronica Gilmore is a citizen and resident of Memphis, Shelby County,

Tennessee. Ms. Veronica Gilmore is the surviving spouse and next of kin of Joseph Gilmore,

who died on July 7, 2011. Ms. Evelyn Gilmore contracted with funeral services, including final

disposition of the remains at Galilee Memorial Gardens, with E.H. Ford Mortuary Services, in

Memphis, Tennessee.

376. Plaintiff Marie Kennon is a citizen and resident of Cordova, Shelby County,

Tennessee. Plaintiff Frenchie Kennon is a citizen and resident of Memphis, Shelby County,

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Tennessee. Plaintiff Frenchie Kennon is the surviving mother and next of kin of Derrick White,

who died February 18, 2011. Ms. Marie Kennon contracted for funeral services, including the

final disposition of the remains at Galilee Memorial Gardens, with E.H. Ford Mortuary Services,


377. Plaintiff Samantha Mitchell-Rhodes and Plaintiff, Sonya King are citizens and

residents of Memphis, Shelby County, Tennessee. They are the surviving daughters of Martha

Jones, who died January 5, 2013. Ms. Mitchell-Rhodes contracted for funeral services, including

the final disposition of the remains at Galilee Memorial Gardens, with E.H. Ford Mortuary


378. Plaintiff Verkisserous Smith is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving daughter and next of kin of Geraldine Harris, who died on

October 16, 2011. Ms. Smith contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with E.H. Ford Mortuary Services, in Memphis,

Tennessee.

379. Plaintiff Kalisa Williams is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving wife and next of kin of Earl Williams, who died on October 10,

2012. Ms. Williams contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with E.H. Ford Mortuary Services, in Memphis, Tennessee.

380. Plaintiffs Yolanda Williams and Kaneshia Liddell are citizens and residents of

Memphis, Shelby County, Tennessee. They are surviving daughters and next of kin of Sharon

Williams, who died on January 13, 2013. Ms. Yolanda Williams contracted for funeral services,



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381. Plaintiff Michelle Blaine is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving sister and next of kin of Shirley Rogers, who died on August 14,

2013. Ms. Blaine contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with Family Mortuary, Inc. in Memphis, Tennessee.

382. Plaintiffs Betty Jean Brown and Coca Ivy are citizens and residents of Memphis,

Shelby County, Tennessee. Ms. Ivy is the surviving daughter and next of kin of James Ivy Jr.,

who died on September 19, 2012. Ms. Brown is the surviving sister of James Ivy Jr. Ms. Brown

and Ms. Ivy contracted for funeral services, including final disposition of the remains at Galilee

Memorial Gardens, with Family Mortuary, Inc. in Memphis, Tennessee.

383. Plaintiffs Willie Harris Jr. and Mary Joe Harris are citizens and residents of

Memphis, Shelby County, Tennessee. Mr. Harris is the surviving son of Willie James Harris,

who died November 3, 2012. Ms. Harris is the surviving wife and next of kin of Willie James

Harris. Mr. Harris contracted for funeral services, including the final disposition of the remains

at Galilee Memorial Gardens, with Family Mortuary, Inc. in Memphis, Tennessee.

384. Plaintiff Charlyce Williams is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving sister and next of kin of Erika Lester, who died in October 2011.

Ms. Williams contracted for funeral services, including final disposition of the remains at Galilee

Memorial Gardens, with Family Mortuary, Inc. in Memphis, Tennessee.

385. Plaintiff Shanti Harris is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving niece of Dianne Sims, who died July 23, 2011. Ms. Harris


Gardens, with Harrison’s Memorial Chapel Inc., in Memphis, Tennessee.

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386. Plaintiff Lillie Smith is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving mother and next of kin of Willie Reed, who died on November

20, 2011. Ms. Smith contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with J. E. Herndon Funeral Home, in Memphis, Tennessee.

387. Plaintiff Annie Haynes is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving wife and next of kin of Laurence Haynes, who died October 14,

2011. Ms. Haynes contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with Jefferson Mortuary, in Millington, Tennessee.

388. Plaintiff Tacara Bledsoe is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving daughter and next of kin of Florence Williams, who died on

August 10, 2013. Ms. Bledsoe contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with Joe Ford Funeral Home, in Memphis, Tennessee.

389. Plaintiffs Tracie D. Carter and Kirk A. Martin are citizens and residents of

Memphis, Shelby County, Tennessee. They are the surviving children and next of kin of Edith

Jean Thompson, who died on January 10, 2013. Ms. Carter contracted for funeral services,

including final disposition of the remains at Galilee Memorial Gardens, with Joe Ford Funeral

Home, in Memphis, Tennessee.

390. Plaintiff Eddie Poindexter is a citizen and resident of Memphis, Shelby County,

Tennessee. He is the surviving husband and next of kin of Bertha Ann Poindexter, who died on

February 12, 2012. Mr. Poindexter contracted for funeral services, including final disposition of

the remains at Galilee Memorial Gardens, with Joe Ford Funeral Home, in Memphis, Tennessee.

391. Plaintiff Barbra Porter is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving sister of Larry Porter, who died on November 14, 2013. Ms.

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Porter contracted for funeral services, including final disposition of the remains at Galilee

Memorial Gardens, with Joe Ford Funeral Home, in Memphis, Tennessee.

392. Plaintiff Eva Reynolds is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving sister and next of kin of Edward Reynolds, who died on March

24, 2013. Ms. Reynolds contracted for funeral services, including the final disposition of the

remains at Galilee Memorial Gardens, with Joe Ford Funeral Home, in Memphis, Tennessee.

393. Plaintiff Teresa Rose and Sheila Lockhart are citizens and resident of Memphis,

Shelby County, Tennessee. They are the surviving nieces and next of kin of Rosetta Dixon, who

died on June 16, 2011. Ms. Rose and Ms. Lockhart contracted for funeral services, including the

final disposition of the remains at Galilee Memorial Gardens with Joe Ford Funeral Home, in

Memphis, Tennessee.

394. Plaintiff Fannie Scott-Wesson is a citizen and resident of Memphis, Shelby

County, Tennessee. She is the surviving daughter and next of kin of Ruthie Cornelia Farmer,

who died on September 24, 2011. Ms. Scott-Wesson contracted for funeral services, including

final disposition of the remains at Galilee Memorial Gardens, with Joe Ford Funeral Home, in

Memphis, Tennessee.

395. Plaintiff Demetria Watson is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving sister of Jerome Watson, who died on June 28, 2012. She


Gardens, with Joe Ford Funeral Home, in Memphis, Tennessee.

396. Plaintiffs Angela Beason, Nicholas Patterson and Lashon Beason are citizens and

residents of Memphis, Shelby County, Tennessee. They are the surviving children and next of

kin of Mary Beason, who died on February 15, 2011. Ms. Angela Beason contracted for funeral

84


Edwards & Sons Funeral Home Stage Road Chapel, in Memphis, Tennessee.

397. Plaintiffs Thomas Boyd and Stacy Williams are citizens and residents of

Memphis, Shelby County, Tennessee. Ms. Williams is the surviving daughter and next of kin of

Mary Lue Gray, who died on January 22, 2011. Mr. Boyd contracted for funeral services,

including the final disposition of the remains at Galilee Memorial Gardens, with M.J. Edwards &

Sons Funeral Home Stage Road Chapel, in Memphis, Tennessee.

398. Plaintiff Angela Cathey is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving wife and next of kin of William H. Cathey, who died on

February 4, 2012. Ms. Cathey contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with M.J. Edwards & Sons Funeral Home, in Memphis,

Tennessee.

399. Plaintiff Sara Cotton is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving daughter and next of kin of Betty Lee Strowder-Peterson, who

died on April 26, 2012. She contracted for funeral services, including final disposition of the


Tennessee.

400. Plaintiff Katherine L. Crutchfield is a citizen and resident of Memphis, Shelby

County, Tennessee. She is the surviving daughter and next of kin of Maggie L. Crutchfield, who

died on January 13, 2013. She contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with M.J. Edwards & Sons Funeral Home Stage Road

Chapel, in Memphis, Tennessee.

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401. Plaintiffs Carolyn Davis, Shelia F. Jackson, Sylvester Jackson, Robert Jackson,

Janice Ransfer, Milton Jackson, Ruth Cartwright, Calvin Johnson are citizens and residents of

Memphis, Shelby County, Tennessee. Plaintiff Remell Johnson is a citizen and resident of Ranch

Cucamonga, San Bernardino County, California. They are surviving children and next of kin of

Pernell Jackson, Jr., who died on September 3, 2013. Ms. Davis contracted for funeral services,


Sons Funeral Home Stage Road Chapel, in Memphis, Tennessee.

402. Plaintiff Yvette Davis is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving daughter and next of Kin of Earnestine Bowles, who died on

June 18, 2012. Ms. Davis contracted for funeral services, including final disposition of the


Tennessee.

403. Plaintiffs Dunyale D. Douglas and Keinard D. Smith are citizens and residents of

Memphis, Shelby County, Tennessee. They are the surviving children and next of kin of Shirley

Y. Smith, who died on March 9, 2011. Mr. Douglas contracted for funeral services, including the

final disposition of the remains at Galilee Memorial Gardens, with M.J. Edwards & Sons Funeral

Home Stage Road Chapel, in Memphis, Tennessee.

404. Plaintiffs Herman C. Eddings, Calvin D. Conner and Lillian Blackwell are

citizens and residents of Memphis, Shelby County, Tennessee. Mr. Herman C. Eddings is the

surviving cousin of Ernest Blackwell, Jr. Mr. Calvin D. Connor and Ms. Lillian Blackwell are

the surviving children and next of kin of Ernest Blackwell, Jr., who died on April 12, 2012. Mr.

Eddings contracted for funeral services, including the final disposition of the remains at Galilee

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Memorial Gardens, with M.J. Edwards & Sons Funeral Home Stage Road Chapel, in Memphis,

Tennessee.

405. Plaintiffs Cathy Green and Linda F. Pullen are citizens and residents of Memphis,

Shelby County, Tennessee. Ms. Green is the surviving sister of Odis Green, who died on August

18, 2012. Ms. Green and Ms. Pullen contracted for funeral services, including the final

disposition of the remains at Galilee Memorial Gardens, with M.J. Edwards Whitehaven Funeral


406. Plaintiff Princella Hunt is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving daughter and next of kin of Florence Barnes, who died on

December 3, 2011. Ms. Hunt contracted for funeral services, including final disposition of the



407. Plaintiffs Sarita Renee Jones and Cynthia Strickland are citizens and residents of

Memphis, Shelby County, Tennessee. They are the surviving daughters and next of kin of

Carolyn R. Jones, who died on October 16, 2011. Sarita Jones contracted for funeral services,


Sons Funeral Home, in Memphis, Tennessee.

408. Plaintiffs Elaine Knox and Wilma Martin are citizens and residents of Memphis,

Shelby County, Tennessee. They are the surviving children of Odessa Henderson, who died on

March 1, 2011. Ms. Knox contracted for funeral services, including final disposition of the


Chapel in Memphis, Tennessee.

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409. Plaintiff Earnestine Lewis is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving wife and next of kin of Robert Lee Lewis, who died on August 6,

2011. Ms. Lewis contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with M.J. Edwards & Sons Funeral Home Stage Road Chapel, in

Memphis, Tennessee.

410. Plaintiff Kimberly Malone and Kendra Woods are citizens and residents of


Michelle Woods, who died on May 4, 2012. Ms. Kimberly Malone contracted for funeral


Edwards & Sons Funeral Home, in Memphis, Tennessee.

411. Plaintiffs Mable Moody, Shirley White, Leila J. Smith and Helen Bolden are

citizens and residents of Memphis, Shelby County, Tennessee. They are the surviving daughters

and next of kin of Leila Houston, who died on January 5, 2011. Ms. Moody contracted for

funeral services, including the final disposition of the remains at Galilee Memorial Gardens, with

M.J. Edwards & Sons Funeral Home, in Memphis, Tennessee.

412. Plaintiff Bonnie Morrison is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving daughter and next of kin of Ora Lee Morrison, who died on July

8, 2012. Ms. Morrison contracted for funeral services, including final disposition of the remains

at Galilee Memorial Gardens, with M.J. Edwards & Sons Funeral Home, in Memphis,

Tennessee.

413. Plaintiff Eva Moss is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving wife and next of kin of Charlie Moss, who died on July 20, 2011.

Ms. Moss contracted for funeral services, including final disposition of the remains at Galilee

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Tennessee.

414. Plaintiff Angela Marie Pettis is a citizen and resident of Memphis, Shelby County,

Tennessee. Plaintiff Michelle Herron is a citizen and resident of Chicago, IL. Ms. Pettis is the

surviving sister of Michael Andrew Green, who died on October 2, 2012. Ms. Herron is the

surviving daughter and next of kin of Michael Andrew Green. Ms. Pettis contracted for funeral

services, including the final disposition of the remains at Galilee Memorial Gardens, with M.J.

Edwards & Sons Funeral Home, in Memphis, Tennessee.

415. Plaintiff Earnestine Poindexter is a citizen and resident of Memphis, Shelby

County, Tennessee. She is the surviving mother and next of kin of Jeffrey Marshall Mitchell,

who died on November 18, 2011. Mrs. Poindexter contracted for funeral services, including final



416. Plaintiff Vanessa Presley is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving niece of Armeta Nixon Lawson, who died on December 14,

2011. Ms. Presley contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with M.J. Edwards & Sons Funeral Home, in Memphis, Tennessee.

417. Plaintiff Johnnie Mae Rainer is a citizen and resident of Memphis, Shelby

County, Tennessee. She is the surviving mother and next of kin of Antwan Rainer, who died on

February 13, 2011. Ms. Rainer contracted for funeral services, including final disposition of the


Tennessee.

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418. Plaintiff Juanita Renfroe is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving mother of Sidney Edward Renfroe III, who died on June 11,

2013. Plaintiff Brenda Renfroe is the surviving spouse and next of kin of Sidney Edward Renfroe

III. Ms. Juanita Renfroe contracted for funeral services, including the final disposition of the



419. Plaintiffs Debbie Richardson, Milton R. Collier, Jr., Beverly Williams, Brenda

Jones, Sharon Collier, and Pamela Collier are citizens and residents of Memphis, Shelby County,

Tennessee. They are the surviving family and next of kin of Larry Earl Collier, deceased and

Rosie Collier, deceased. Larry Earl Collier died on May 15, 2012. Rosie Collier, the mother of

the deceased, contracted for funeral services, including final disposition of the remains at Galilee


Tennessee.

420. Plaintiffs Sylvester Wright, Jr., and Helen Ross are citizens and residents of

Memphis, Shelby County, Tennessee. Mr. Wright is the surviving brother and next of kin and

Ms. Ross is the surviving friend of Carolyn Richardson, who died on February 20, 2013. Ms.

Ross contracted for funeral services, including final disposition of the remains at Galilee

Memorial Gardens, with M.J. Edwards & Sons Funeral Home, in Memphis, Tennessee.

421. Plaintiffs Irma Rouser and William Rouser are citizens and residents of Memphis,

Shelby County, Tennessee. Ms. Rouser is the surviving daughter of Ernestine Rouser, who died

on October 24. 2012. Mr. Rouser is the surviving husband and next of kin of Ernestine Rouser.

Ms. Rouser contracted for funeral services, including the final disposition of the remains at

Galilee Memorial Gardens, with M.J. Edwards & Sons Funeral Home, in Memphis, Tennessee.

90

422. Plaintiff Carolyn Sanders is a citizen and resident of Memphis, Shelby County,

Tennessee. Plaintiff Leon Sanders is an adult citizen and resident of Mesquite, Dallas County,

TX. They are the surviving children and next of kin of Pearline Sanders, who died on August 1,

2013. Ms. Sanders contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with M.J. Edwards & Sons Funeral Home Stage Road Chapel, in

Memphis, Tennessee.

423. Plaintiff Lah-Taria Smith is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving mother and next of kin of Mi’Yahna M. Smith, who died on July

31, 2013. Ms. Smith contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with M.J. Edwards Stage Road Chapel, in Memphis, Tennessee.

424. Plaintiff Reffy Wiggins is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving daughter and next of kin of Olivia Viola Swift, who died on

February 13, 2012. Ms. Wiggins contracted for funeral services, including final disposition of the


Tennessee.

425. Plaintiffs Debbie Richardson, Milton R. Collier, Jr., Beverly Williams, Brenda

Jones, Sharon Collier, and Pamela Collier are citizens and residents of Memphis, Shelby County,

Tennessee. They are the surviving family and next of kin of and Rosie Collier, who died on

August 18, 2013. Ms. Williams contracted for funeral services, including final disposition of the



426. Plaintiffs Bobbie G. Williams and Tonie F. Ball are citizens and residents of

Memphis, Shelby County, Tennessee. Ms. Williams is the surviving grandmother of Markeith

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Levell Bohanon, who died on August 9, 2012. Ms. Ball is the surviving mother and next of kin

of Markeith Levell Bohanon. Ms. Williams contracted for funeral services, including the final



427. Plaintiff Clarice B. Williams is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving wife and next of kin of Campbell Williams, who died on June

14, 2013. Ms. Williams contracted for funeral services, including final disposition of the remains

at Galilee Memorial Gardens, with M.J. Edwards & Sons Funeral Home, in Memphis,

Tennessee.

428. Plaintiff Emma Woodard is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving mother of Yul Knox, who died on February 4, 2013. Ms.

Woodard contracted for funeral services, including the final disposition of the remains at Galilee


Tennessee.

429. Plaintiff Jerry Craft is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving sister of Leroy Woods, who died on October 30, 2012. She


Gardens, with M.J. Edwards & Sons Funeral Home, in Memphis, Tennessee.

430. Plaintiffs Eddie Wright, Jr. and Michael Wright are citizens and residents of

Memphis, Shelby County, Tennessee. They are the surviving sons and next of kin of Lillie Pearl

Wright, who died on April 9, 2013. Mr. Eddie Wright contracted for funeral services, including

final disposition of the remains at Galilee Memorial Gardens, with M.J. Edwards & Sons Funeral

Home Stage Road Chapel, in Memphis, Tennessee.

92

431. Plaintiff Shirley Renee Brown is a citizen and resident of Atoka, Tipton County,

Tennessee. She is the surviving sister and next of kin of Cliften Ross, who died on August 18,

2012. Ms. Brown contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with Millington Funeral Home, Inc., in Memphis, Tennessee.

432. Plaintiff Monica L. Hayes-Roberson is a citizen and resident of Memphis, Shelby

County, Tennessee. She is the surviving wife and next of kin of Jason Kenneth Roberson, who

died on January 28, 2011. Ms. Hayes-Roberson contracted for funeral services, including final

disposition of the remains at Galilee Memorial Gardens, with Millington Funeral Home, Inc., in

Memphis, Tennessee.

433. Plaintiff Sandra Mabon is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving daughter and next of kin of Susie Mae Allen Mabon, who died

on December 23, 2013. Ms. Mabon contracted for funeral services, including final disposition of

the remains at Galilee Memorial Gardens, with Millington Funeral Home, Inc., in Memphis,

Tennessee.

434. Plaintiff Tara L. Mabon is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving daughter and next of kin of George Franklin Mabon, who died

on February 12, 2011. She contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with Millington Funeral Home, Inc., in Memphis,

Tennessee.

435. Plaintiff Karen Reed is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving wife and next of kin of Kelvin Reed, who died on February 26,

2013. Ms. Reed contracted for funeral services, including final disposition of the remains at


93

436. Plaintiff Clarence Ross is a citizen and resident of Memphis, Shelby County,

Tennessee. He is the surviving son and next of kin of Thelma Jones, who died on July 22, 2013.

Mr. Ross contracted for funeral services, including final disposition of the remains at Galilee

Memorial Gardens, with Millington Funeral Home, Inc., in Memphis, Tennessee.

437. Plaintiff Bre-Salle Steele is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving daughter and next of kin of Mattie E. Steele, who died on April

6, 2013. Ms. Steele contracted for funeral services, including final disposition of the remains at


438. Plaintiff Virginia Allen is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving sister of James Allen, who died on October 22, 2011. Ms. Allen


Gardens, with N.H. Owen & Son Funeral Home, in Memphis, Tennessee.

439. Plaintiffs Yvette Baker and Angela Baker are adult citizens and residents of

Memphis, Shelby County, Tennessee. Ms. Yvette Baker is the surviving sister of Clarence

Baker, who died on October 27, 2011. Ms. Angela Baker is the surviving daughter and next of

kin of Clarence Baker. Ms. Yvette Baker contracted for funeral services, including final

disposition of the remains at Galilee Memorial Gardens, with N.H. Owen & Son Funeral Home,


440. Plaintiff Margaret Buchanan is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving sister and next of kin of Melvin Burnett, who died on August 22,

2011. Ms. Buchanan contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with N.H. Owen & Son Funeral Home, Inc., in Memphis, Tennessee.

94

441. Plaintiff Rodney T. Hobson is a citizen and resident of Memphis, Shelby County,

Tennessee. He is the surviving son and next of kin of Dorothy Jean Hobson, who died on

September 6, 2013. Mr. Hobson contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with N. H. Owen & Son Funeral Home, Inc., in Memphis,

Tennessee.

442. Plaintiffs Vincent Horton and Antonio Alfonso Grandberry are adult citizens and

residents of Memphis, Shelby County, Tennessee. Mr. Horton is the surviving brother of

Vanessa Wicks, who died on September 10, 2011. Mr. Grandberry is the surviving son and next

of kin of Vanessa Wicks. Mr. Horton contracted for funeral services, including the final

disposition of the remains at Galilee Memorial Gardens, with N.H. Owen & Son Funeral Home,


443. Plaintiff Eva Jones is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving wife and next of kin of Charles K. Jones, who died on November

18, 2012. Ms. Jones contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with N. H. Owen & Son Funeral Home, Inc., in Memphis,

Tennessee.

444. Plaintiff Beatrice P. Lang is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving mother and next of kin of Sylvester Lang, Jr., who died on June

6, 2011. Ms. Lang contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with N.H. Owen & Son Funeral Home, in Memphis, Tennessee.

445. Plaintiff Martha Porter is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving Mother of Herbert C. Porter, who died on February 2, 2011. Ms.

95

Porter contracted for funeral services, including final disposition of the remains at Galilee

Memorial Gardens, with N.H. Owen & Son Funeral Home, in Memphis, Tennessee.

446. Plaintiffs Beverly Jean Sills, Robert L. Webb and Judy Sills are adult citizens and

residents of Memphis, Shelby County, Tennessee. They are the surviving children and next of

kin of Robbie Jean Amos Sills, who died on September 21, 2012. Ms. Jean Sills contracted for

funeral services, including the final disposition of the remains at Galilee Memorial Gardens, with

N.H. Owen & Son Funeral Home, in Memphis, Tennessee.

447. Plaintiff Cassandra Becton is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving mother and next of kin of Yolanda Yvette Bowen, who died on

September 19, 2011. Ms. Becton contracted for funeral services, including final disposition of

the remains at Galilee Memorial Gardens, with N.J. Ford & Sons Funeral Home, Inc., in

Memphis, Tennessee.

448. Plaintiffs Carlita Blakely and Calvin Blakely, Sr. are adult citizens and residents

of Memphis, Shelby County, Tennessee. Ms. Blakely is the surviving sister of Calvin Blakely,

who died on October 20, 2013. Mr. Blakely is the surviving father and next of kin of Calvin

Blakely. Ms. Blakely contracted for funeral services, including final disposition of the remains

at Galilee Memorial Gardens, with N.J. Ford & Sons Funeral Home, Inc., in Memphis,

Tennessee.

449. Plaintiffs Natalie Brown and Barbara Ann Smith are adult citizens and residents

of Memphis, Shelby County, Tennessee. Plaintiff, Barbara Ann Smith is the surviving spouse

and next of kin of Calvin James Smith, who died on August 5, 2013. Plaintiff Natalie Brown is

the surviving sister of Calvin James Smith. Ms. Natalie Brown contracted for funeral services,

96

including the final disposition of the remains at Galilee Memorial Gardens, with N.J. Ford &

Sons Funeral Home, Inc., in Memphis, Tennessee.

450. Plaintiff Laverne Buford is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving mother of Larrainne Vunncha Farris Morton, who died on

October 3, 2012. Ms. Buford contracted for funeral services, including the final disposition of the

remains at Galilee Memorial Gardens, with N.J. Ford & Sons Funeral Home, in Memphis,

Tennessee.

451. Plaintiff Cootee Burnette is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving mother and next of kin of Unyime Charles Williams, who died

on March 9, 2013. Ms. Burnette contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with N.J. Ford & Sons Funeral Home, Inc., in Memphis,

Tennessee.

452. Plaintiff Diane Clark is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving mother and next of kin of Tiffany M. Laird, who died on

February 18, 2013. Ms. Clark contracted for funeral services, including the final disposition of


Memphis, Tennessee.

453. Plaintiffs Tina Cornelius and Donna Vinson are citizens and residents of

Memphis, Shelby County, Tennessee. Tina Cornelius is the surviving daughter and next of kin

of Peggy Jean Cornelius, who died on June 4, 2011. Donna Vinson is the surviving sister of

Peggy Jean Cornelius. Ms. Vinson contracted for funeral services, including the final disposition

of the remains at Galilee Memorial Gardens, with N.J. Ford & Sons Funeral Home, in Memphis,

Tennessee.

97

454. Plaintiff Antonio Cruson is a citizen and resident of Memphis, Shelby County,

Tennessee. He is the surviving son and next of kin of Bonnie Hodges, who died on May 6, 2011.

Mr. Cruson contracted for funeral services, including final disposition of the remains at Galilee

Memorial Gardens, with N.J. Ford & Sons Funeral Home, Inc., in Memphis, Tennessee.

455. Plaintiff Antonio Cruson is a citizen and resident of Memphis, Shelby County,

Tennessee. He is the surviving grandson and next of kin of Mattie Reed, who died on October

29, 2011. Mr. Cruson contracted for funeral services, including the final disposition, including


Home, Inc., in Memphis, Tennessee.

456. Plaintiffs Gloria Garrett and Robert Garrett are adult citizens and residents of

Memphis, Shelby County, Tennessee. Plaintiff Christopher Isaac is a citizen and resident of

Cordova, Shelby County, Tennessee. Ms. Gloria Garrett is the surviving sister of Teresa K.

Isaac, who died on March 26, 2013. Mr. Christopher Isaac is the surviving son and next of kin of

Teresa K. Isaac. Robert and Gloria Garrett contracted for funeral services, including the final

disposition of the remains at Galilee Memorial Gardens, with N.J. Ford & Sons Funeral Home,


457. Plaintiffs Carroll Gholston, Tanisha Fowlkes and Dedrick Gholston are adult

citizens and residents of Memphis, Shelby County, Tennessee. Plaintiff Marcus Gholston is a

citizen and resident of Oxford, Mississippi. Plaintiff, Carroll Gholston is the surviving father of

Teresa Ann Gholston, who died on January 23, 2013. Plaintiffs, Tanisha Fowlkes, Marcus

Gholston, and Dedrick Gholston are the surviving children and next of kin of Teresa Ann

Gholston. Mr. Carroll Gholston contracted for funeral services, including the final disposition of

98


Memphis, Tennessee.

458. Plaintiffs Adrian Glen-Tutton, Michele Glen-Tutton, Samuel Glen are adult

citizens and residents of Memphis, Shelby County, Tennessee. They are the surviving children

and next of kin of Shirley Ann Glen, who died on April 30, 2013. Michelle Glen-Tutton


Gardens, with N.J. Ford & Sons Funeral Home, Inc., in Memphis, Tennessee.

459. Plaintiff Nicole Harris is a citizen and resident of Cordova, Shelby County,

Tennessee. Plaintiff Eugene Taylor is a citizen and resident of Memphis, Shelby County,

Tennessee. They are surviving children and next of kin of Regina Powell Taylor, who died on

October 23, 2013. Ms. Harris contracted for funeral services, including final disposition of the


Tennessee.

460. Plaintiff Charlotte Jackson is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving daughter and next of kin of Easter Mae Brown, who died on

March 30, 2011. Ms. Jackson contracted for funeral services, including final disposition of the


Tennessee.

461. Plaintiff Diane King is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving mother and next of kin of LaBorah King, who died on February

11, 2011. Ms. King contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with N.J. Ford & Sons Funeral Home, Inc., in Memphis, Tennessee.

99

462. Plaintiff Robert Lewis is a citizen and resident of Memphis, Shelby County,

Tennessee. He is the surviving husband and next of kin of Josephine Lewis, who died on April

17, 2013. Mr. Lewis contracted for funeral services, including final disposition of the remains at


463. Plaintiff Danease Liddell is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving daughter and next of kin of George Liddell, who died on June

28, 2013. Ms. Liddell contracted for funeral services, including final disposition of the remains at


464. Plaintiff Latoya Maxwell-Bearden is a citizen and resident of Memphis, Shelby

County, Tennessee. She is the surviving daughter and next of kin of Scott Lee Maxwell, who

died on May 22, 2011. Ms. Maxwell-Bearden contracted for funeral services, including final



465. Plaintiff Debra McGhee is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving daughter and next of kin of Glinnie Mae Holmes, who died on

April 28, 2012. She contracted for funeral services, including final disposition of the remains at


466. Plaintiff Florine Person is a citizen and resident of Memphis, Shelby County,

Tennessee. Bertha Guy is a citizen and resident of Greensboro, NC. They are the surviving

daughters and next of kin of Alpinnia Lorene Guy, who died on July 2, 2012. Ms. Person


Gardens, with N.J. Ford & Sons Funeral Home, Inc., in Memphis, Tennessee.

100

467. Plaintiff Sharline Lashun Powell is a citizen and resident of Memphis, Shelby

County, Tennessee. She is the surviving mother and next of kin of Cortney Lashun Madison,

who died on May 15, 2011. Ms. Powell contracted for funeral services, including final



468. Plaintiff Valarie Sanders is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving sister and next of kin of Gregory Pittman, who died on January

9, 2012. Ms. Sanders contracted for funeral services, including final disposition of the remains at


469. Plaintiff Uvonne Sharp is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving mother and next of kin of Darryl Louis Ingram, who died on

May 15, 2011. Ms. Sharp contracted for funeral services, including final disposition of the


Tennessee.

470. Plaintiffs Genice Tellis and Clydell Anderson Tellis are adult citizens and

residents of Memphis, Shelby County, Tennessee. Ms. Genice Tellis is the surviving daughter of

James Albert Tellis, who died on December 27, 2011. Ms. Clydell Anderson Tellis is the

surviving spouse and next of kin of James Albert Tellis. Ms. Genice Tellis contracted for funeral


& Sons Funeral Home, Inc., in Memphis, Tennessee.

471. Plaintiffs Felecia Williams, Brandon Cathey and Luvenia Thompson are citizens

and residents of Memphis, Shelby County, Tennessee. Plaintiffs Mark Merriweather, II is a

citizen and resident of West Memphis, Arkansas. Ms. Williams is the surviving sister and Ms.

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Thompson is the surviving mother of Mark Merriweather, who died on April 21, 2013. Mr.

Merriweather and Mr. Cathey are the surviving sons and next of kin of Mark Merriweather.

Ms. Thompson contracted for funeral services, including the final disposition of the remains at


472. Plaintiff Vanessa Anderson is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving wife and next of kin of Gregory Anderson, who died on March

25, 2013. Ms. Anderson contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with R.S. Lewis Funeral Home, in Memphis, Tennessee.

473. Plaintiff Betty J. Davis is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving wife and next of kin of Frank Davis, who died on July 11, 2012.

Ms. Davis contracted for funeral services, including final disposition of the remains at Galilee

Memorial Gardens, with R.S. Lewis Funeral Home, in Memphis, Tennessee.

474. Plaintiff Glenda Harris is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving daughter and next of kin of Vernice Harris, who died on July 11,

2011. Ms. Harris contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with R.S. Lewis Funeral Home, in Memphis, Tennessee.

475. Plaintiff Dorothy Jean Henderson is a citizen and resident of Memphis, Shelby

County, Tennessee. She is the surviving mother and next of kin of Kimberly R. Matthews, who

died on August 7, 2013. Ms. Henderson contracted for funeral services, including final

disposition of the remains at Galilee Memorial Gardens, with R.S. Lewis Funeral Home, in

Memphis, Tennessee.

476. Plaintiffs Jacqueline Robinson and Jeanette Monegain-Thomas are adult citizens

and residents of Memphis, Shelby County, Tennessee. They are the surviving daughters and

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next of kin of Wilma J. Jones, who died on January 27, 2012. Ms. Robinson contracted for


R.S. Lewis Funeral Home, in Memphis, Tennessee.

477. Plaintiffs Anita Louise Smith and LeShundra Jones are citizens and residents of

Memphis, Shelby County, Tennessee. Anita Louise Smith is the surviving sister and LeShundra

Jones is the surviving daughter of Debra Lynn Jones, who died on August 6, 2012. Ms. Smith

and Ms. Jones contracted for funeral services, including the final disposition of the remains at

Galilee Memorial Gardens, with R.S. Lewis Funeral Home, in Memphis, Tennessee.

478. Plaintiff Twollier Moore is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving daughter and next of kin of Lucille Stone, who died on May 27,

2011. Ms. Moore contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with R.S. Lewis Funeral Home, LLC, in Memphis, Tennessee.

479. Plaintiffs Brenda D. Webster and Karen D. Webster are citizens and residents of

Memphis, Shelby County, Tennessee. They are the surviving daughters of George Webster, Jr.,

who died on August 1, 2013. Brenda Webster contracted for funeral services, including the final


Memphis, Tennessee.

480. Plaintiff Romona Wilkes is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving mother and next of kin of Samuel Earl Wilkes, Jr., who died on

April 8, 2012. Ms. Wilkes contracted for funeral services, including final disposition of the


481. Plaintiff Annie Woods is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving mother and next of kin of Anthony Gerald Jones, who died on

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September 7, 2011. Ms. Woods contracted for funeral services, including final disposition of the


482. Plaintiffs Rose A. Woods and Aretha Levy are adult citizens and residents of

Memphis, Shelby County, Tennessee. Ms. Rose A. Woods is the surviving sister of Henry

Albert Levy, who died on January 26, 2013. Ms. Aretha Levy is a surviving child and next of

kin of Henry Albert Levy. Ms. Woods contracted for funeral services, including the final


Memphis, Tennessee.

483. Plaintiff Syma Collins is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving daughter and next of kin of Edna Fisher Hollowell, who died on

May 12, 2011. Ms. Collins contracted for funeral services, including the final disposition of the

remains at Galilee Memorial Gardens, with Snow Funeral Home, in Memphis, Tennessee.

484. Plaintiff Angela Gibson is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving mother and next of kin of Candace Fason, who died on June 28,

2012. Ms. Gibson contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with Snow Funeral Homes in Memphis, Tennessee.

485. Plaintiffs Russell Robinson is a citizens and residents of Memphis, Shelby

County, Tennessee. He is the surviving child and next of kin of Evelyn Kay Robinson, who died

on January 5, 2012. Mr. Robinson contracted for funeral services, including the final disposition

of the remains at Galilee Memorial Gardens, with Snow Funeral Homes in Memphis, Tennessee.

486. Plaintiff Lisa Patrice Bradley is a citizen and resident of Memphis, Shelby

County, Tennessee. She is the surviving sister and next of kin of James Eric Bradley, who died

on May 17, 2013. Ms. Patricia Bradley, deceased as of October 3, 2013 contracted for funeral

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services, including the final disposition of the remains at Galilee Memorial Gardens, with

Superior Funeral Home Hollywood Chapel in Memphis, Tennessee. Ms. Lisa Patrice Bradly is

only surviving heir of both Ms. Patricia Bradley and James Eric Bradley.

487. Plaintiff Frances Brown is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving wife and next of kin of Johnnie Brown, who died on August 12,

2011. Ms. Brown contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with Superior Funeral Home Hollywood Chapel in Memphis,

Tennessee.

488. Plaintiff Jack Dupree is a citizen and resident of Memphis, Shelby County,

Tennessee. He is the surviving son and next of kin of Luerean D. Taylor, who died on October

12, 2012. Mr. Dupree contracted for funeral services, including final disposition of the remains at


Tennessee.

489. Plaintiffs Louise H. Garrett and Nicole Hester are adult citizens and residents of

Memphis, Shelby County, Tennessee. Ms. Garrett is the surviving sister of Ray Edward Hester,

who died on December 2, 2012. Ms. Hester is the surviving daughter and next of kin of Ray

Edward Hester. Ms. Garrett contracted for funeral services, including final disposition of the

remains at Galilee Memorial Cemetery, with Superior Funeral Home Hollywood Chapel in

Memphis, Tennessee.

490. Plaintiff Lena Moore is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving mother and next of kin of Lester Moore, who died on May 19,

2011. Ms. Moore contracted for funeral services, including final disposition of the remains at

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Tennessee.

491. Plaintiff Josie L. Moss is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving mother and next of kin of Joseph Leon Moss, who died on

February 16, 2013. Ms. Moss contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with Superior Funeral Home Hollywood Chapel in

Memphis, Tennessee.

492. Plaintiff Essa Sarjo is a citizen and resident of Memphis, Shelby County,

Tennessee. He is the surviving husband and next of kin of Tammy Sarjo, who died on December

27, 2010. Mr. Sarjo contracted for funeral services, including final disposition of the remains at


Tennessee.

493. Plaintiffs Oletha Sims and Eric Sims are adult citizens and residents of Memphis,

Shelby County, Tennessee. Ms. Sims is the surviving aunt and Mr. Sims is the father and next of

kin of China M. Malone, who died on April 14, 2012. Ms. Sims contracted for funeral services,

including final disposition of the remains at Galilee Memorial Gardens, with Superior Funeral

Home Hollywood Chapel in Memphis, Tennessee.

494. Plaintiffs Felicia Stringfellow and Ciera Piegus are adult citizens and residents of

Memphis, Shelby County, Tennessee. Ms. Stringfellow is the surviving sister of Shelia Poole,

who died on June 27, 2013. Ms. Piegus is the surviving daughter and next of kin of Shelia Poole.

Ms. Stringfellow contracted for funeral services, including the final disposition of the remains at


Tennessee.

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495. Plaintiff Katrina Walker and Cheryl Ross are citizens and residents of Memphis,

Shelby County, Tennessee. Ms. Ross is the surviving sister and Ms. Walker is the surviving

daughter and next of kin of Carolyn Walker, who died on May 12, 2013. Ms. Ross contracted for


Superior Funeral Home Hollywood Chapel in Memphis, Tennessee.

496. Plaintiff Patrick Washington is a citizen and resident of Millington, Shelby

County, Tennessee. Plaintiff Jeanette Washington is a citizen and resident of Memphis, Shelby

County, Tennessee. Mr. Washington is the surviving brother of Arthur V. Washington, Jr., who

died on May 6, 2013. Ms. Washington is the surviving spouse and next of kin of Arthur V.

Washington, Jr. Mr. Washington contracted for funeral services, including the final disposition

of the remains at Galilee Memorial Gardens, with Superior Funeral Home Hollywood Chapel in

Memphis, Tennessee.

497. Plaintiffs Brenda Webb, Timmy Caples are adult citizens and residents of

Memphis, Shelby County, Tennessee. Plaintiff Arica Brison is a citizen and resident of Hot

Springs, Arkansas. Ms. Webb is the surviving niece and Mr. Caples and Ms. Brison are the

surviving children and next of kin of Betty Caples, who died on November 9, 2012. Ms. Webb


Gardens, with Superior Funeral Home Hollywood Chapel in Memphis, Tennessee.

498. Plaintiffs Beverly Willis, Almetta Nelson, Joyce Ann Foster Pittman, Charles

Pittman and Robert L. Pittman are adult citizens and residents of Memphis, Shelby County,

Tennessee. They are the surviving children and next of kin of Alberta Pittman, who died on

April 11, 2012. Ms. Willis contracted for funeral services, including final disposition of the

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remains at Galilee Memorial Gardens, with Superior Funeral Home Hollywood Chapel in

Memphis, Tennessee.

499. Plaintiffs Errance W. Davis, Arturo Morris and Lamonica Wright are citizens and

residents of Memphis, Shelby County, Tennessee. They are surviving children and next of kin of

William Davis, who died on March 2, 2013. Mr. Davis, Mr. Morris and Ms. Wright contracted


Signature Funeral Services in Memphis, TN.

500. Plaintiffs Gloria J. Wortham, Bryan Nevills, Jason Bowen and Brandy Nevills are

adult citizens and residents of Memphis, Shelby County, Tennessee. Ms. Wortham is the sister

of and Mr. Nevills and Mr. Bowen are the sons and next of kin of Paula Yvette Nevills, who died

on November 3, 2011. Ms. Wortham contracted for funeral services, including the final

disposition of the remains at Galilee Memorial Gardens with Superior Funeral Home in

Memphis, TN.

501. Plaintiff Steven Tuggle is a citizen and resident of Memphis, Shelby County,

Tennessee. He is the surviving son and next of kin of Vickie Renee Tuggle, who died on

October 24, 2011. Mr. Tuggle contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with Joe Ford Funeral Home in Memphis, TN.

502. Plaintiff Minnie Morton is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving mother and next of kin of Jamie Morton, who died on July 13,

2012. Ms. Morton contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with Millington Funeral Home, Inc. in Millington, Tennessee.

503. Plaintiff Lakisha Nunley is a citizen and resident of Memphis, Shelby County,

Tennessee. Plaintiff Gwendolyn Tatum is a citizen and resident of Memphis, Shelby County,

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Tennessee. Ms. Nunley is the surviving daughter and next of kin of Eugene Nunley, who died

on February 17, 2012. Ms. Tatum is the surviving sister of Eugene Nunley. Ms. Tatum and Ms.

Nunley contracted for funeral services, including final disposition of the remains at Galilee

Memorial Gardens, with J.E. Herndon Funeral Home in Memphis, TN.

504. Plaintiff Rosalyn M. Reed is a citizen and resident of Memphis, Shelby County,

Tennessee. Ms. Reed is the surviving daughter and next of kin of Geraldine Reed, who died on

December 16, 2011. Ms. Reed contracted for funeral services, including the final disposition of

the remains at Galilee Memorial Gardens, with M.J. Edwards Funeral Home in Memphis,

Tennessee.

505. Plaintiff Phillip Hodges is a citizen and resident of Cordova, Shelby County,

Tennessee. Mr. Hodges is the surviving son and next of kin of Earl Theodore Hodges, who died

on November 26, 2011. Ms. Janet Boudreax contracted for funeral services, including the final

disposition of the remains at Galilee Memorial Gardens, with J.E. Herndon Funeral Home in

Memphis, Tennessee.

506. Plaintiff Timothy Wells is a citizen and resident of Southaven, Mississippi. Mr.

Wells is the surviving son and next of kin of Julia Mae Ellis, who died on August 26, 2011. Mr.

Wells contracted for funeral services, including final disposition of the remains at Galilee

Memorial Gardens, with N.H. Owens and Son Funeral Home in Memphis, Tennessee.

507. Plaintiff Racheal Williams is a citizen and resident of McDonough, Georgia. Ms.

Williams is the surviving sister and next of kin of Quienton Thomas, who died on July 29, 2011.

Ms. Williams contracted for funeral services, including final disposition of the remains at Galilee

Memorial Gardens, with Christian Funeral Directors in Memphis, Tennessee.

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508. Plaintiff Felicia Crawford is a citizen and resident of Charlotte, North Carolina.

Ms. Crawford is the surviving daughter and next of kin of Ann Delores Crawford, who died on

January 25, 2013. Ms. Crawford contracted for funeral services, including final disposition of

the remains at Galilee Memorial Gardens, with N.H. Owens & Sons Funeral Home in Memphis,

Tennessee.

509. Plaintiff Gertrude F. Jamison is a citizen and resident of Memphis, Tennessee.

Ms. Jamison is the surviving niece and next of kin of Mary Alice Fifer, who died on November

30, 2011. Ms. Jamison contracted for funeral services, including final disposition of the remains

at Galilee Memorial Gardens, with R.S. Lewis Funeral Home in Memphis, Tennessee.

510. Plaintiff Tracy Nicole Bobo is a citizen and resident of Memphis, Tennessee. Ms.

Bobo is the surviving sister and next of kin of Jarvis Cordell Tabors, who died on December 9,

2011. Ms. Bobo contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with N.J. Ford & Sons Funeral Home in Memphis, Tennessee.

511. Plaintiffs Eddie Lee Black, Jr., Sherry Denise Black and Steven Louis Black are

citizens and residents of Memphis, Tennessee. They are the children and next of kin of Mildred

Louise Patterson, who died on April 26, 2012. Mr. Eddie Lee Black, Jr. contracted for funeral

services, including final disposition of the remains at Galilee Memorial Gardens, with Joe Ford

Funeral Home in Memphis, Tennessee.

512. Plaintiff Vera Milton is a citizen and resident of Memphis, Tennessee. Ms.

Milton is the surviving spouse and next of kin of Robert Earl Milton, who died on November 19,

2012. Ms. Milton contracted for funeral services, including final disposition of the remains at

Galilee Memorial Gardens, with Christian Funeral Directors in Memphis, Tennessee.

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513. Plaintiff James Shipp is a citizen and resident of Memphis, Tennessee. Plaintiff

Kimberly Shipp is a citizen and resident of Chicago, Illinois. Mr. Shipp is the grandfather of

Paul Shipp, who died on August 18, 2012. Ms. Shipp is the mother and next of kin of Paul

Shipp. Mr. James Shipp contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with E H Ford Mortuary in Memphis, Tennessee.

514. Plaintiff Edwin E. White is a citizen and resident of Horn Lake, Mississippi.

Plaintiff Linda White is a citizen and resident of Horn Lake, Mississippi. Plaintiff Annette

Parker is a citizen and resident of Horn Lake, Mississippi. Plaintiffs are the surviving children

and next of kin of Lula Bell White, who died on April 29, 2013. Mr. White contracted for

funeral services, including final disposition of the remains at Galilee Memorial Gardens, with E

H Ford Mortuary in Memphis, Tennessee.

515. Plaintiffs Edwin E. White, Linda White and Annette Parker are adult citizens and

residents of Horn Lake, Mississippi. They are the surviving siblings and, next of kin of Anthony

Lee White, who died on April 10, 2011. Mr. White contracted for funeral services, including

final disposition of the remains at Galilee Memorial Gardens, with E H Ford Mortuary in

Memphis, Tennessee.

516. Plaintiff Vickie Jones is a citizen and resident of Memphis, Shelby County,

Tennessee. She is the surviving child and next of kin of Inez St. Clair-Reed, who died on

January 30, 2012. Ms. Jones contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with M.J. Edwards Funeral Home in Memphis,

Tennessee.

517. Plaintiffs Jarrita Jones and Lisa Jones are adult citizens and residents of Memphis,

Shelby County, Tennessee. They are the surviving daughters of Maryann Hunt Humphrey-Hill,

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who died on July 28, 2012. They contracted for funeral services, including final disposition of

the remains at Galilee Memorial Gardens, with M.J. Edwards Funeral Home in Memphis,

Tennessee.

518. Plaintiffs Harriet Young and Shirley Jean Reid are adult citizens and residents of


Museta Reid, who died on August 21, 2012. Ms. Young contracted for funeral services,

including final disposition of the remains at Galilee Memorial Gardens, with N.H. Owens &

Sons Funeral Home in Memphis, Tennessee.

519. Plaintiff Jeremy D. Young is a citizen and resident of Memphis, Shelby County,

Tennessee. He is the surviving spouse and next of kin of Michelle Patrice Young, who died on

June 15, 2013. Mr. Young contracted for funeral services, including final disposition of the

remains at Galilee Memorial Gardens, with Signature Funeral Services in Memphis, Tennessee.

520. Plaintiffs Toni Green and Tresia Greene are adult citizens and residents of

Memphis, Shelby County, Tennessee. They are the surviving children and next of kin of Bobbye

J. Greene, who died on October 11, 2013. They contracted for funeral services, including final

disposition of the remains at Galilee Memorial Gardens, with N.J. Ford & Sons Funeral Home in

Memphis, Tennessee.

521. Plaintiff Jeffrey Lavon Turner is a citizen and resident of Memphis, Shelby

County, Tennessee. He is the surviving brother and next of kin of Elmer Morris Pack, who died

on August 19. 2011. He contracted for funeral services, including final disposition of the remains

at Galilee Memorial Gardens, with Christian Funeral Directors in Memphis, Tennessee.

522. Plaintiff Louis Antonio Burton is a citizen and resident of Memphis, Shelby

County, Tennessee. Plaintiff Nissa Pleshette Foster is a citizen and resident of Memphis, Shelby

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County, Tennessee. They are the surviving children and next of kin of Sherrie Denise Burton,

who died on August 8, 2012. They contracted for funeral services, including final disposition of

the remains at Galilee Memorial Gardens, with E.H. Ford Mortuary Services in Memphis,

Tennessee.

523. Plaintiff Gregory Mabone is a citizen and resident of Memphis, Shelby County,

Tennessee. He is the surviving child and next of kin of Loistene Mabone, who died on

November 22. 2012. He contracted for funeral services, including final disposition of the remains

at Galilee Memorial Gardens, with Family Mortuary, LLC, in Memphis, Tennessee.

524. Plaintiff Michelle Woods is a citizen and resident of Memphis, Shelby County,

Tennessee. Plaintiff Stephanie Watkins is a citizen and resident of New Orleans, Louisiana.

They are the surviving children and next of kin of Sophia Gilmore, who died on April 18, 2012.

Ms. Watkins contracted for funeral services, including final disposition of the remains at Galilee

Memorial Gardens with M.J. Edwards Funeral Home in Memphis, Tennessee.

525. Plaintiff Lavonne Yarbor is a citizen and resident of Ridgeland, MS. She is the

surviving mother and next of kin of Demont Yarbor, who died on February 11, 2011. They


Gardens, with Superior Funeral Home in Memphis, Tennessee.

526. Plaintiffs Vanessa Ann Slater, Charles Golden and Bernice Nelson are citizens

and residents of Memphis, Shelby County, TN. Plaintiff Pamela D. Golden is a citizen and

resident of Milwaukee, Milwaukee County, WI. They are the surviving children and next of kin

of Willie Charles Golden, who died on December 3, 2011. Ms. Slater contracted for funeral

services, including the final disposition of the remains at Galilee Memorial Gardens, with Joe

Ford Funeral Home, in Memphis, Tennessee.

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527. Plaintiffs Claudia Worthy, Ruth Ann Wofford, Tommy Wofford and Lawrence

Wofford are adult citizens and residents of Memphis, Shelby County, TN. They are surviving

children and next of kin of L.C. Wofford, who died on June 10, 2013. Ms. Akilah Wofford, their

sister, contracted for funeral services, including final disposition of the remains at Galilee

Memorial Gardens, with M.J. Edwards & Sons Funeral Home, Inc., Stage Road Chapel, in

Memphis, Tennessee.

528. Defendant M.J. Edwards & Sons Funeral Home, Inc. is a Tennessee corporation

with its principal place of business at 1165 Airways Blvd, Memphis, TN 38114, and may be

served through its registered agent for service of process: Corporation Service Company, 2908

Poston Ave., Nashville, TN 37203-1312.

529. Defendant N.J. Ford and Sons Funeral Home Inc. is a Tennessee corporation with

its principal place of business at 12 S Parkway W, Memphis, TN 38109, and may be served

through its registered agent for service of process: Harold Ford, 12 S Parkway W, Memphis, TN

38109.

530. Defendant Christian Funeral Directors, Inc. is a corporation organized under the

laws of the State of Tennessee, which may be served with process through its agent for service of

process: Laron Jackson at 2615 Overton Crossing Street, Memphis, TN 38127-8612. Christian

Funeral Directors, Inc. operates under a d/b/a Christian Funeral Directors South East. Christian

Funeral Directors, Inc. is licensed by the State of Tennessee as a funeral establishment.

531. Defendant Christian Funeral Directors, Inc. is a corporation organized under the

laws of the State of Tennessee, which may be served with process through its agent for service of

process: Laron Jackson at 2615 Overton Crossing Street, Memphis, TN 38127-8612. Christian

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Funeral Directors, Inc. operates under a d/b/a Christian Funeral Directors South East. Christian

Funeral Directors, Inc. is licensed by the State of Tennessee as a funeral establishment.

532. Defendant E.H. Ford Mortuary Services, Inc. is a Tennessee corporation with its

principal place of business at 3390 Elvis Presley Boulevard, Memphis, TN 38116, and may be

served through its registered agent for service of process: Edmund H. Ford, Sr., 3390 Elvis

Presley Boulevard, Memphis, TN 38116.

533. Defendant Joseph Sampson Ford a resident of Memphis, Tennessee, is a licensed

funeral director, and may be served at 1616 Winchester Road, Memphis, TN 38116. Defendant

Ford operates under a d/b/a Joe Ford Funeral Home, LLC, which is licensed in the State of

Tennessee as a funeral establishment.

534. Defendant James E. Herndon, III, a resident of Memphis, Tennessee, is a licensed

funeral director, and may be served at 1779 Winchester Road, Memphis, TN 38116. Defendant

Herndon operates under a d/b/a J.E. Herndon Funeral Home, which is licensed in the State of


535. Defendant Hardeman County Funeral Services, Inc. is a corporation organized

under the laws of the State of Tennessee, which may be served with process through its agent for

service of process: Timothy Sanders at 109 South Porter Street, Bolivar, TN 38008.

536. Defendant Signature Funeral Services, LLC is a Tennessee limited liability

company with its principal place of business at 5359 Knight Arnold Road, Memphis, TN 38115,

and may be served through its registered agent for service of process: Signature Funeral

Services, LLC at 5359 Knight Arnold Road, Memphis, TN 38115.

537. Defendant Vernal H. Bins, Jr. a resident of Memphis, TN, is the owner of a

funeral establishment, and may be served at 1265 Mississippi Boulevard, Memphis, TN 38106.

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Defendant Bins operates under a d/b/a V.H. Bins & Son Mid-South Funeral Home, which is

licensed in the State of Tennessee as a funeral establishment.

538. Defendant Peter Showers, Jr. a resident of Memphis, TN, is the owner of a funeral

establishment, and may be served at 1382 Florida Street, Memphis, TN 38106. Defendant

Showers operates under a d/b/a Snow Funeral home, which is licensed in the State of Tennessee

as a funeral establishment.

539. Defendant N.H. Owens & Son Funeral Home, Inc. is a Tennessee corporation

with its principal place of business at 421 Scott Street, Memphis, TN 38112, and may be served

through its registered agent for service of process: Cheryl L. Owens, 1857 South Parkway E.,

Memphis, TN 38114.

540. Defendant R.S. Lewis Funeral Home, LLC is a Tennessee limited liability

company with its principal place of business at 3380 Pearson Road, Memphis, TN 38118, and

may be served through its registered agent for service of process: Kevin Swinton, 3380 Pearson

Road, Memphis, TN 38118. R.S. Lewis Funeral Home, LLC operates under a d/b/a R.S. Lewis

& Sons Funeral Home.

541. Defendant Durell Antoine Williams a resident of Memphis, TN, is the owner of a

funeral establishment, and may be served at 659 Semmes Street, Memphis, TN 38111.

Defendant Williams operates under a d/b/a Calvary Memorial Funeral home, which is licensed in

the State of Tennessee as a funeral establishment.

542. Defendant Family Mortuary, Inc. is a Tennessee limited liability company with its

principal place of business at 878 Jackson Avenue, Memphis, TN 38107, and may be served

through its registered agent for service of process: Essie B. Williams, 878 Jackson, Memphis, TN

38107.

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543. Defendant Harrison's Funeral Home, Incorporated is a Tennessee corporation

with its principal place of business at 2647 Carnes Avenue, Memphis, TN 38114, and may be

served through its registered agent for service of process: Adriana C. Harrison, 2647 Carnes

Avenue, Memphis, TN 38114.

544. Defendant Preston Jefferson a resident of Millington, TN, is the owner of a

funeral establishment, and may be served at 7788 Church Street, Millington, TN 38053.

Defendant Jefferson operates under a d/b/a Jefferson Mortuary, which is licensed in the State of


545. Defendant Millington Funeral Home, Inc. is a Tennessee corporation with its

principal place of business at 7738 Church Street, Millington, TN 38053, and may be served

through its registered agent for service of process: Eva E. Smith, 7738 Church Street, Millington,

TN 38053.

546. Defendant SLS, LLC is a Tennessee limited liability company with its principal

place of business at 460 E. McLemore Avenue, Memphis, TN 38106, and may be served through

its registered agent for service of process: Business Filings Incorporated, 800 S. Gay Street, Suite

2021, Knoxville, TN 37929. Defendant SLS, LLC operates under a d/b/a Superior Funeral Home

Hollywood Chapel.

547. Defendant Golden Gate Funeral Home is a licensed funeral establishment doing

business in the State of Tennessee and which may be served upon Sheila Davis Parrish,

Manager, at its principal place of business located at 734 Vance Avenue, Memphis, TN 38126.

548. Defendant Sheila Davis Parrish an adult resident of the State of TN, is a funeral

director licensed by the State of Tennessee, is the owner and/or manager of the Defendant

Golden Gate Funeral Home, and may be served at 734 Vance Avenue, Memphis, TN 38126.

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549. Defendant J.O. Patterson Funeral Home Inc. a/k/a J.O. Patterson Mortuary is a

dissolved corporation originally organized under the laws of the State of Tennessee. Defendant

J.O. Patterson Funeral Home, Inc.'s funeral establishment license issued by the State of

Tennessee expired on November 30, 2013. Defendant J.O. Patterson Funeral Home, Inc.'s

registered agent for service of process is listed as JO Patterson, Jr., 5034 Elvis Presley, Memphis,

TN 38116; however, in the event that service upon this Defendant cannot be obtained at that

location, service may be made upon its current owner and/or manager, Joseph H. Ivy, at 2116

Curry Ave. Memphis, TN 38111.

550. Defendant Joseph H. Ivy is an adult resident of the State of Tennessee, is a funeral

director licensed by the State of Tennessee, is the owner and /or manager of the Defendant J.O.

Patterson Funeral Home, Inc., and may be served at 2116 Curry Ave., Memphis, TN 38111.

551. Defendant M.J. Edwards - Whitehaven Funeral Chapel, Inc., d/b/a as M.J.

Edwards Whitehaven Funeral Chapel, is a corporation formed under the laws of the State of

Tennessee with its principal office located at 9th Floor Dept. 2934, 1929 Allen Parkway,

Houston, Texas 77019-2506, and its registered agent for service of process listed as Corporation

Service Company, 2908 Poston Avenue, Nashville, TN 37203-1312. This Defendant is a funeral

establishment licensed by the State of Tennessee in Shelby County, TN.

552. Defendant M.J. Edwards Hillside Chapel, Inc., d/b/a M.J. Edwards Funeral Home

Stage Road Chapel, is a corporation formed under the laws of the State of Tennessee with its

principal office located at 9th Floor Dept. 2934, 1929 Allen Parkway, Houston, TX 77019-2506,

and its registered agent for service of process listed as Corporation Service Company, 2908

Poston Avenue, Nashville, TN 37203-1312. This Defendant is a funeral establishment licensed

by the State of Tennessee and does business in Shelby County, Tennessee.

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553. Defendant Kenneth Gerald Mays is a resident of TN and a licensed funeral

director, and may be served at 2034 Elvis Presley Blvd., Memphis, TN 38106. Defendant Mays

operates under a d/b/a Mays Funeral Home, which is licensed in the State of Tennessee as a

funeral establishment.

554. Defendant Carol Ford Beasley is a resident of TN and a licensed funeral director,

and may be served at 203 Washington St. Collierville, TN 38017. Defendant Beasley operates

under a d/b/a H.C. Jett/H.C. Ford & Son Funeral Home, which is licensed in the State of


555. Defendant Galilee Memorial Gardens is a Tennessee cemetery with its principal

place of business at 8283 Ellis Road, Memphis, TN 38133, and address also shown as Bartlett,

Tennessee, and may be served through its registered agent for service of process, Jemar Lambert,

who may be served at 8283 Ellis Road, Memphis, TN 38133. The Chancery Court for Davidson

County has appointed the Tennessee Commissioner of Commerce and Insurance as the receiver

for this entity and service is also appropriate on the Commissioner.

556. Defendant JM&M Services, Inc. (JM&M) is a dissolved corporation originally

organized under the laws of the State of Tennessee. Its principal office is located at 8283 Ellis

Road, Memphis, TN 38133, and its registered agent for service of process is listed as Jemar

Lambert, who may be served at 8283 Ellis Road, Memphis, TN 38133. The Chancery Court for

Davidson County has appointed the Tennessee Commissioner of Commerce and Insurance as the

receiver for this entity and service is also appropriate on the Commissioner.

Upon information and belief, Defendant Lambert Memorial Co., a/k/a Lambert

Memorials Inc. (LMC) is a business name that has appeared on one or more bank accounts that

have been used by Jemar Lambert in connection with the operation of Galilee. The address for

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LMC is also 8283 Ellis Road, Memphis, TN 38133. The Chancery Court for Davidson County

has appointed the Tennessee Commissioner of Commerce and Insurance as the receiver for this

entity and service is also appropriate on the Commissioner.

557. Upon information and belief, Defendant Lambert & Sons, Inc. is a business name

that has appeared on one or more bank accounts that have been used by Jemar Lambert in

connection with the operation of Galilee. The address for Lambert & Sons, Inc. is also 8283 Ellis

road, Memphis, TN 38133. The Chancery Court for Davidson County has appointed the

Tennessee Commissioner of Commerce and Insurance as the receiver for this entity and service

is also appropriate on the Commissioner.

558. Defendant Jemar Lambert is an adult citizen of Shelby County, Tennessee whose

business address is 3174 Ruby Cove, Memphis, TN 38111.

559. Defendant Marje Lambert is an adult resident of Shelby County, Tennessee whose

business address is 3174 Ruby Cove, Memphis, TN 38111.

560. Defendant Mary H. Lambert is an adult resident of Shelby County, Tennessee

whose business address is 3174 Ruby Cove, Memphis, TN 38111.

561. Defendants Galilee Memorial Gardens, JM&M Services, Inc., Lambert Memorial

Co., aka Lambert Memorials, Inc., Jemar Lambert, Marje Lambert and Mary H. Lambert are

collectively referred to herein as “Galilee defendants.”

JURISDICTION AND VENUE

562. This Court has jurisdiction over this matter pursuant to Tenn. Code. Ann. §16-11-

101, 16-11-103 and 16-11-102.

563. Venue is properly situated in Shelby County, Tennessee pursuant to Tenn. Code.

Ann. § 20-4-101.

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CLASS ACTION ALLEGATIONS

564. The named plaintiffs (hereinafter “The Families”) seek equitable relief and

damages on behalf of themselves and all other families of decedents whose remains were

consigned to Galilee. This action alleges breach of contract, breach of fiduciary duty, reckless

and negligent mishandling of remains, negligence, reckless and negligent infliction of emotional

distress, and unjust enrichment. Additionally, should a class not be certified, these families seek

all recoverable damages and remedies under the Tennessee Consumer Protection Act including

treble damages and attorneys’ fees and costs.

565. Because of the exceptional public importance of this case, the need for timely

answers to grieving Tennessee families, and the need to ensure that the statute of limitations is

tolled. The Families request that the Court provisionally certify this class action as soon as

practicable.

566. The extraordinary public importance of this situation was demonstrated on

January 24, 2014, when the Shelby County District Attorney General announced that she had

executed a search warrant for Galilee Memorial Gardens, and issued the following release:

Jemar Lambert, 38, was arrested by investigators with the District Attorney’s Office whoalso executed a search warrant for burial records in the cemetery office.Last year Lambert was indicted on charges of theft of property over $60,000 for allegedlyselling burial plots to bereaved families on adjacent land not owned by the cemetery thatencompasses about nine acres at 8283 Ellis Road.He is scheduled to be in Criminal Court on Feb. 13 on that case.In connection with Friday’s action, the Tennessee Department of Commerce andInsurance, which regulates cemetery and funeral home practices, filed a request for atemporary restraining order shutting down cemetery operations.“We are sensitive to the importance of Galilee Memorial Gardens to countless familiesand to our community,” Weirich said Friday. “We will continue working with theDepartment of Commerce and Insurance to resolve this situation respectfully andeffectively.”The search warrant and new arrest stem from an investigation that began in Novemberwhen a search for a missing body led those helping with the search to make a report to theTennessee Department of Commerce and Insurance.

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That report indicated the cemetery had improperly buried the remains of three differentindividuals in the same grave on March 9 and March 12 of last year.The search warrant seeks cemetery files, computer records and electronic or digitalstorage data used to record information related to potential criminal acts involving theburial records kept by the cemetery.In Nashville, Department of Commerce and Insurance Commissioner Julie Mix McPeakand the Tennessee Attorney General’s Office also filed a petition asking a DavidsonCounty Court for an order appointing the commissioner as receiver for Galilee MemorialGardens.“We believe that the owners and proprietors of Galilee Memorial Gardens cannot act inthe best interest of the community,” said McPeak. “This is a complex process thatinvolves many moving parts. Know that we are working alongside the Shelby CountyDistrict Attorney General’s Office to identify the extent of issues with Galilee.”

http://www.scdag.com/neww/item/469-shelby-county-district-attorney-general-executes-search-warrant-at-local-cemetery-owner-arrested

567. In addition to the criminal proceedings initiated by The Shelby County District

Attorney's Office, the Davidson County Chancery Court appointed the Commissioner of the

Tennessee Department of Commerce and Insurance as the Receiver for Galilee Memorial

Gardens and granted certain injunctive relief. The Cemetery continues to be under the exclusive

custody and control of the Receiver and the jurisdiction of the Chancery Court.

568. Mr. Jemar Lambert, an unlicensed owner and operator of Galilee Memorial

Gardens, faces charges for theft and abuse of a corpse in Shelby County, TN Criminal Court.

569. The magnitude and complexity of this catastrophe has been described in the local

press:

The arrests were followed by revelations about multiple bodies buried in the samegrave at Galilee and inaccurate records about who was buried where in thecemetery on Ellis Road east of Germantown Road. Witnesses reported seeingworkers crush caskets with the tires of heavy equipment to get multiple caskets ingraves, and Galilee employees peeling back the tops of coffins to determine theidentities of the corpses. The cemetery apparently was out of space, leading to thepractices.Cemetery operator took case till the end, The Commercial Appeal (Feb. 8, 2014)

Lambert’s actions were further described by Shelby County Criminal Court Judge

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Lee Coffey during Lambert’s bond hearing as a “crime against humanity…and everything that is

good.”

570. This action is brought pursuant to the applicable provisions of Rule 23 of the

TRCP on behalf of a class defined as:

a) All those who are or were next of kin1 of any decedent delivered to Galilee for burialfrom January 1, 2011 through January 31, 2014; and

b) All persons or entities who were parties to any contract with any defendant regardingfuneral arrangements for a decedent who was delivered to Galilee for burial fromJanuary 1, 2011 through January 31, 2014.

571. Excluded from the class are the defendants, including an parent, subsidiary,

affiliate or controlled person of these entities and their officers, directors, agents, employees and

members of their immediate families; and the judicial officers to whom this case is assigned,

their staff, and the members of their immediate families.

572. The class and subclass are so numerous that individual joinder of all its members

is impracticable.

573. The identities of the class members for purposes of class notice may be readily

obtained from the defendants’ and public records.

574. In this action, common issues of law and fact relating to the conduct, duty and

resulting liability of the defendants predominate over any issues affecting only individual class

members.

575. The claims of the Families are typical of the claims of the class. The Families and

the class members have been subjected to the same unlawful behavior of the defendants, giving

rise to common legal and equitable claims.

1 Next of kin for purposes of this class is defined pursuant to Akers v. Buckner-Rush Enterprises, Inc., 270 S.W.3d67 (Tenn. Ct. App. 2007).

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576. The Families will fairly and adequately represent and protect the interests of the

class and none have any interests that are adverse to the interests of the class.

577. The Families have retained counsel who are competent and experienced in class

actions and complex litigation, including in cases involving the desecration, commingling and

mishandling of remains.

578. This Court may elect, in its discretion, to maintain these claims as a class action

under Rule 23.02(1), (2) and/or (3) of the TRCP.

579. Class certification is appropriate pursuant to Rule 23.02(1) of the TRCP because

the prosecution of separate actions by the individual members of the class would create a risk of

inconsistent or varying adjudications that would establish incompatible standards of conduct for

the defendants and/or because adjudications respecting individual members of the class would,

as a practical matter, be dispositive of the interests of the other members or would risk

substantially impairing or impeding their ability to protect their interests.

580. Class certification is also appropriate pursuant to Rule 23.02(2) of the TRCP

because the defendants acted on grounds generally applicable to the class, making appropriate

equitable, injunctive and/or declaratory relief.

581. Class certification is also appropriate pursuant to Rule 23.02(3) of the TRCP

because common issues of law and fact predominate over issues involving only individual class

members.

582. A class action approach is superior to other available methods for the fair and

efficient adjudication of this dispute because common questions of law and fact predominate

over any questions that may affect only individual members of the class and there would be

significant economies to the courts and the parties in litigating the common issues on a class

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wide basis rather than in repetitive individual trials. A class action approach is also superior in

this matter because hundreds of individual lawsuits would unnecessarily burden the courts,

multiply the costs of litigation, and could impede the ability of some class members to receive

any compensation at all should the funds available to satisfy individual claims be exhausted. A

class approach would consolidate these matters and create fewer management difficulties

because it would provide the benefits of unitary adjudication, judicial economy, economies of

scale and comprehensive supervision by a single court.

583. Class certification is also appropriate because this Court can designate particular

claims or issues for class wide treatment pursuant to Rule 23.03(4)(a) and may designate one or

more subclasses pursuant to Rule 23.03(4)(b) of the TRCP.

FACTUAL ALLEGATIONS APPLICABLE TO ALL CLAIMS

584. The Families, on behalf of themselves and the class, re-allege and incorporate

herein, as if set forth in full, each and every allegation contained in the preceding paragraphs and

further allege:

585. Commencing on January 1, 2011 and continuing through January 31, 2014

(hereinafter, “Class Period”) the funeral home defendants contracted with and for the benefit of

The Families in this complaint and the class members to provide funeral director services and to

accomplish the disposition and burial of loved ones’ remains with dignity and respect in keeping

with public sensibilities and in accordance with the law.

586. Under Tennessee law, only properly qualified and licensed persons can engage in

the disposal and burial of human remains. See T.C.A. § 62-5-303 and 62-5-101(6)(A)(defining

“Funeral Directing” as the “practice of directing or supervising funerals or the practice of

preparing dead human bodies for burial by any means...”) Licensing requires continuing

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education and ethics. See Rules of the Tennessee Board of Funeral Directors and Embalmers,

Ch. 0660-10. It is specifically prohibited for a person who is not duly registered and licensed as a

funeral director to engage in funeral directing. See T.C.A § 62-5-303 (b). It is further required

that no employee or member of any firm or corporation shall engage in the care, preparation,

disposal or burial of dead bodies unless he is a licensed funeral director. See T.C.A § 62-5-

313(a). Under Tennessee law, there are requirements that the license issued to a funeral

establishment be for a period of two years and is not transferable or assignable. See T.C.A § 62-

5-315. Grounds for the suspension, denial or revocation of a license under T.C.A § 62-5-317(5)

include an applicant or holder of a funeral license knowingly permitting an unlicensed person to

engage in the profession or business of funeral director or embalming under the applicant's or

holder’s supervision. Under Tennessee law funeral directing includes the “practice of preparing

human bodies for burial by any means.” See T.C.A § 62-5-101(6)(A)(i). T.C.A § 62-5-317(b)(1)

prohibits misrepresentation or fraud in the conduct of the business of the funeral establishment.

T.C.A § 62-5-317(b)(6) prohibits “Aiding or abetting an unlicensed person to practice within the

funeral profession.” Tennessee law requires that a cemetery company shall maintain its

cemeteries so as to reflect respect to the memory of the dead in keeping with the reasonable

sensibilities of survivors whose remains are interred in the cemeteries. See T.C. A. § 46-1-304

(a).

587. Contrary to their contractual, fiduciary and non-delegable duties, the defendants

commonly and systematically failed, throughout the Class Period, to accomplish the burial and

disposition of the remains entrusted to them with the dignity and respect expected of them by

public sensibilities and required of them by law. Rather than discharging their duties to The

Families and the class members by fully and faithfully carrying out their obligations, and without

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describing their actual practices or obtaining express written permission therefore, the defendants

knowingly, recklessly and/or negligently permitted and facilitated the disrespectful, improper

and illegal mishandling, misplacement, loss and desecration of the remains of the decedents.

588. Throughout the Class Period, the Galilee defendants systematically and

commonly mishandled, desecrated, abused and commingled the remains of the decedents in a

manner offensive to human sensibilities and/or expressly prohibited by law. The Galilee

defendants operated without a valid license and/or certificate, disinterred bodies without

necessary court orders, stacked multiple caskets in single burial plots, crushed caskets in order to

fit many caskets into single burial plots, misplaced or completely lost track of remains, and

buried bodies without authorization on neighboring property owned by third parties both before

and after a Restraining Order was issued by Chancery Court of Shelby County enjoining Galilee

from encroaching on the neighboring property.

589. The funeral home defendants knew or reasonably should have known that Galilee

was not licensed as of December 31, 2010, and that burials at Galilee were improper and illegal

after that date. See Tenn. Code. Ann § 46-1-103, and Verified Petition for the Appointment of

the Commissioner as Receiver for Galilee Memorial Gardens and for Temporary and Permanent

Injunctive Relief. The funeral home defendants also knew or reasonably should have known that

the individual who held the Galilee license had died months before the license expired, and in the

exercise of reasonable and ordinary care for their profession, should have inquired as to Galilee’s

authority to conduct business and its licensing status once the license-holder passed away.

590. The funeral home defendants contracted and charged for burial services and then,

in violation of their contractual and legal duty, abandoned the remains at Galilee, negligently and

recklessly failed to supervise the burials and, instead, allowed unlicensed agents and/or

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employees of Galilee to perform the burials and unlawful acts alleged in this complaint.

Furthermore, these defendants allowed agents and/or employees of Galilee to perform tasks and

duties legally entrusted exclusively to licensed funeral directors. Galilee did not have an agent

and/or employee who was a licensed funeral director at any time relevant to the claims alleged.

591. Tennessee law and the standards of conduct for funeral directors required each

funeral director in charge of the funeral for each class member personally to ensure that the

burial of the deceased was accomplished in a proper fashion. By ignoring Tennessee law and

their professional responsibilities, they allowed Galilee’s unlawful and reprehensible practices to

become routine. In breaching the contractual and solemn duties the funeral home defendants

owed, these defendants also injured multiple parties not in privity with them by allowing Galilee

to unlawfully disturb the graves and the remains of other decedents who had been buried at

Galilee before and after December 31, 2010.

592. Had a licensed funeral director actually supervised the burials at Galilee, as was

required by law, the unlawful mishandling and desecration of these remains would never have

occurred. Galilee’s unlawful business practices included stacking multiple, unrelated bodies in

the same grave, removing caskets and bodies from graves and crushing them, losing bodies,

illegally removing bodies from purchased burial plots, burying individuals in plots previously

purchased by other families specifically for family members to be laid to rest next to their loved

ones and spouses, and illegally trespassing on neighboring land for purposes of burial.

593. Every funeral home and funeral director that did business with Galilee had a legal,

non-delegable duty to ensure the burial of the decedents’ remains was accomplished through a

licensed and qualified (competent) facility. Each defendant further had a contractual and legal

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responsibility to investigate with due diligence to determine that the cemetery to which they were

bringing remains for burial services was licensed and operating within the bounds of the law.

594. In gross and unconscionable dereliction of their contractual, moral, ethical and

legal duties, the defendants uniformly failed to investigate the practices of Galilee, willfully

ignored open and obvious conditions at the cemetery that should have been reported to the

proper authorities, failed to ensure that the contracted for services were being provided and,

perhaps most critically, failed to supervise the actual burials for which they were exclusively

responsible.

595. Moreover, the funeral home defendants failed to inform The Families and the

class members that their loved ones’ remains would be taken for burial to an uncertified

Tennessee cemetery, that the funeral home defendants’ sacred, legal and contractual duties for

the proper and respectful disposition of remains would be handed over to an unlicensed and

unqualified cemetery in violation of Tennessee law, and that the funeral director defendants

would abandon the remains at Galilee with no investigation whatsoever of its practices, no care

or effort to ensure the remains were treated with respect and in accordance with the law and no

thought for the ultimate treatment and disposition of the remains.

596. The failure of each of the funeral home defendants to discharge the duty of special

care to ensure that the remains entrusted to their care were handled and laid to rest respectfully

and lawfully contributed to and caused harm to The Families and the class as a whole. Had any

one of the defendant funeral homes inspected, supervised or monitored Galilee’s practices, as

this special duty requires, Galilee’s practices would have been discovered and stopped before

widespread injury took place. Because each of the funeral home defendants failed to meet its

duty, Galilee was able to continue, undiscovered, its practice of mishandling, commingling and

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desecrating the remains of the loved ones of family after family. Through the defendants'

knowing, reckless, or negligent failure to discover and disclose the true nature of the practices,

and procedures utilized at Galilee, each defendant contributed to and caused harm to every

member of the class by enabling and facilitating the mishandling, commingling and desecration

of the decedents’ remains.

597. Furthermore, at all material times, Galilee was the agent, ostensible agent,

servant, employee, representative, joint venturer, and associate of the funeral home defendants in

effectuating the respectful and lawful disposition of the remains that are the subject matter of this

action. At all material times, Galilee was acting within the course and scope of that authority

and with the knowledge, authorization, consent, permission or ratification of each of the other

defendants. The funeral home defendants owed a non-delegable contractual duty to The

Families and to the class members to ensure that the remains of their loved one were respectfully

laid to rest, in accordance with all legal obligations. The funeral homes breached that duty and

thus are vicariously liable for the actions of Galilee, regardless of whether Galilee was an agent

of defendants or an independent contractor.

598. Because of the nature of the conduct alleged herein, this is an appropriate case to

pierce the corporate veil or hold the parent and affiliate corporations of all defendants liable

under theories of alter-ego, domination, control, agency by estoppel, misrepresentation and

unconscionability.

599. The Families are now informed and believe, and thereon allege, that their

decedents were subjected to the unlawful and improper practices of Galilee. Their loved ones’

remains were not laid to rest with dignity and respect or in accordance with their wishes or the

law. Instead, their remains were subjected by the defendants to mishandling, abuse,

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misplacement, and desecration. The families have been and continue to be deprived of any

closure and a final resting place for their loved ones.

600. Perhaps more horrifying to The Families and the class members is the knowledge

that, because the defendants exercised complete control over the remains of the decedents and

due to the defendants’ improper and unlawful desecration of the remains, including the efforts to

conceal the bad acts, many families whose loved ones were abandoned at Galilee by the funeral

home defendants may never know the final resting place of their loved ones and will never know

to what treatment their loved ones’ remains were subjected.

601. Moreover, as a proximate result of (a) the representations of defendants that the

decedents’ remains would be and had been handled and laid to rest in the lawfully authorized and

requested manner, with dignity and respect; (b) the defendants’ possession and control of the

decedents’ remains, and complete control over the manner of treatment of these remains; and (c)

the concealment by the defendants of the mistreatment, mishandling, and desecration of the

remains, The Families and class members did not discover that their decedents’ remains were

subjected to the defendants’ misconduct until within one year preceding the filing of this

complaint.

COUNT 1: BREACH OF CONTRACT

602. The allegations contained in the proceeding paragraphs are incorporated as if fully

set forth herein.

603. The Families and the class members and/or their decedents entered into written or

oral contracts with the funeral home defendants and with the Galilee defendants to obtain and

ensure the disposition of the decedents’ remains in an individual, dignified, respectful and lawful

manner. The expectations of The Families and the class members, as reasonable persons, were

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that these contracts, expressly or by reasonable implication, assured the legal, dignified and

respectful disposition of their decedents’ remains.

604. The defendants have copies of all written contracts with The Families and the

class members.

605. These contracts uniformly omitted material information regarding Galilee’s actual

practices, Galilee’s unlicensed status, and the funeral home defendants’ failure to carry out their

duties including to ensure the burial was proper and lawful, and to inspect, monitor or supervise

Galilee’s laying to rest of the decedents’ remains.

606. The Families and the class members were the natural and intended beneficiaries

of those written and oral contracts.

607. The Families and the class members and/or their decedents performed all

promises, covenants and conditions required on their part to be performed pursuant to the

contracts and have fully paid the agreed-upon price for the defendants’ services.

608. The funeral home defendants and the Galilee defendants breached their contracts

with The Families and the class members by improperly handling or causing or allowing the

improper handling of the decedent’s remains, by failing to supervise and ensure proper,

respectful burials, and by failing to disclose the true nature of Galilee’s practices and conduct

and their own lack of care, concern or investigation of what would befall the remains at Galilee.

609. As a direct and proximate cause of the defendants' breaches of their contractual

agreements, The Families and the class members have suffered damages and losses including (a)

the amounts they previously paid the defendants for funeral directing and burial services, and (b)

the amounts that The Families and class members have incurred and will incur in attempting to

recover, identify and respectfully lay their loved ones’ remains to rest.

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COUNT II: EQUITABLE (INJUNCTIVE AND/OR DECLARATORY) RELIEF



further allege:

611. The remains of the decedents were improperly and unlawfully handled while in

the defendants’ exclusive possession and control, without the authorization, knowledge,

permission, consent or ratification of The Families or the class members. The decedents’

remains were not afforded individual, respectful and dignified disposition and were, instead,

mishandled, abused and desecrated.

612. The Families and the class members are charged by law, by their own perceived

moral obligations and ethical duties and by natural sentiments to accomplish the disposition of

their decedents’ remains as requested by the decedents, as set forth in the funeral services

contracts with the defendants, and in keeping with public sensibilities and the law.

613. No adequate remedy at law exists to address the desecration of the decedents’

remains and, due to the defendants’ actions, there may be no way to undo the injustices that have

been done. Worse, many family members who entrusted their departed loved ones to the

defendants many never be able to learn the true fate of their loved ones’ remains.

614. Accordingly, The Families, on behalf of themselves and the class, request the

following equitable relief:

a) A judicial determination and declaration of the rights of Families and the class and theresponsibilities of the defendants with respect to the remains that are the subject ofthis action;

b) That the defendants disclose to The Families and the class, insofar as is possible, thewhereabouts of the desecrated remains so that The Families and the class may carryout the dignified and respectful disposition of same;

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c) That the property upon which the remains were desecrated and interred be held intrust for the benefit of the class pending the ultimate disposition by the Court;

d) That the defendants be enjoined to cease and desist all mishandling, and desecrationof human remains; and

e) That the defendants be determined and declared to be financially responsible for thecosts and expenses of accomplishing any and all dignified and respectful dispositionof the decedents’ remains as may be possible.

COUNT III: BREACH OF FIDUCIARY DUTY



further allege:

616. The funeral home defendants sought and undertook a position of special trust and

confidence with the Families and the class members. The funeral home defendants undertook

and assumed responsibility for the funeral, disposition and burial services for The Families and

the class. The Families and the class members placed special trust and confidence in the funeral

home defendants for these services.

617. Thus the funeral home defendants had fiduciary relationships with The Families

and the class members.

618. The funeral home defendants were under a duty to exercise good faith and due

diligence, and to act with due regard for the interests of The Families and the class in

effectuating the proper, lawful, dignified laying to rest of the remains of their loved ones.

619. The funeral home defendants breached their fiduciary duties to The Families and

the class as described herein including my mishandling the decedents’ remains, and causing,

contributing to, or aiding and abetting Galilee’s mishandling by knowingly failing to supervise,

monitor and assure the final laying to rest of the decedents’ remains, and by failing to assure that

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Galilee’s operations were conducted properly, respectfully, and in accordance with all applicable

law and regulations.

620. As a direct and proximate result of the defendants’ breach of fiduciary duty, The

Families and the class have suffered and continue to suffer injury and damages.

COUNT IV: RECKLESS AND NEGLIGENT MISHANDLING OF REMAINS



further allege:

622. The Families and the class, as the decedents’ next of kin, had or have a personal

quasi-property right to control the disposition of the remains of their loved ones.

623. The Families and the class expressed their wishes to the defendants regarding the

manner in which the remains were to be handled.

624. The defendants had the opportunity to comply with The Families’ and the class

member’s expressed wishes.

625. The defendants, however, recklessly and negligently mishandled the decedents’

remains, and/or caused, contributed to, or aided and abetted Galilee’s mishandling by knowingly

failing to supervise, monitor and assure the final laying to rest of the decedents’ remains, and by

failing to assure that Galilee’s operations were conducted properly, respectfully, and in

accordance with all applicable law and regulations. The defendants’ conduct was accomplished

through a common course and practice of improper handling of remains, resulting from the

defendants’ own recklessness, negligence, and reckless and negligent entrustment of the

decedents’ remains to persons who lacked the qualifications, training, sensitivity, experience and

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integrity required to handle the remains properly and by the defendants’ reckless and negligent

failure to control, supervise and investigate the actions of such persons and entities.

626. Through this conduct, the defendants interfered with the rights and

responsibilities of The Families and the class to effect the proper disposition of the remains with

utmost dignity, in accordance with the law and their wishes, requests and beliefs.

627. The defendants’ mishandling of the remains and their interference with the rights

of The Families and the class precluded The Families and the class from exercising their rights

and performing their responsibilities of appropriately disposing of the remains of their decedents.

628. As a direct, known, foreseeable and proximate result of the reckless and negligent

mishandling of the remains by the defendants, The Families and the class have suffered and

continue to suffer injury and damages.

COUNT V. NEGLIGENCE AND RECKLESS AND NEGLIGENT INFLICTIONOF EMOTIONAL DISTRESS


herein, as if set forth in full, each and every allegation contained in the proceeding paragraphs

and further allege:

630. At all material times, the defendants owed a duty to The Families and the class to

act with the ordinary care of a reasonable professional in the field with respect to all aspects of

the services promised including, but not limited to, all phases of the disposition and burial

process, including but not limited to the hiring, retention, training and supervision of all agents,

employees and representatives of the defendants, the management and administration of the

services and transaction, the association with other persons and entities to accomplish the

performance of such services, the performance of and supervision and assurance of the

individual, proper and respectful performance of all steps of the disposition and burial process,

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and the ascertainment that all such services were being fully and properly undertaken and

performed.

631. The defendants negligently and recklessly failed to discharge these duties.

632. The defendants further negligently and recklessly violated the statutes set forth

above, thus invoking the doctrine of negligence per se.

633. As a proximate cause of the defendants’ recklessness and negligence, The

Families and the class members have suffered damages, including but not limited to serious and

severe mental injuries and emotional distress that no reasonable person could be expected to

endure or adequately cope with.

COUNT VI: UNJUST ENRICHMENT



further allege:

635. The Families and the class members conferred a benefit upon the defendants,

which the defendants received. Specifically The Families and the class members made payments

for funeral directing services for the proper, respectful disposition and burial of their decedents’

remains.

636. The defendants have been and will continue to be unjustly enriched at the expense

of The Families and the members of the class by accepting payments from The Families and the

class for services which they not only failed to render as promised but which were provided in a

completely inappropriate, unauthorized, unlawful and egregious manner.

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637. It would be inequitable to permit the defendants to retain the benefits they have

wrongfully gained through these actions, which they accordingly hold in constructive trust for,

and must be ordered to restore to, The Families and the class.

COUNT VII: PUNITIVE DAMAGES



further allege:

639. In mishandling or causing or contributing to the mishandling of the remains of the

decedents, the defendants acted intentionally, fraudulently, maliciously, or recklessly, and in

conscious disregard of the rights of The Families and the class.

640. The Families and the class are, therefore, entitled to punitive damages from the

defendants in such amount as shall be necessary and appropriate to punish the defendants and to

deter them and anyone else from ever committing similar indecencies upon human remains.

COUNT VIII: VIOLATION OF THE TENNESSEE CONSUMER PROTECTION ACT(ASSERTED SOLELY IN THE EVENT CLASS CERTIFICATION IS DENIED)

641. The Families re-allege and incorporate herein, as if set forth in full, each and

every allegation contained in the preceding paragraphs and further allege:

642. In addition to the above claims, in the event this Court does not grant class action

certification, The Families individually assert claims against the defendants under the Tennessee

Consumer Protection Act.

643. The defendants’ conduct was unfair and/or deceptive as defined in Tenn. Code.

Ann §47-18-104. The defendants deceptively represented that they would perform their sacred

and contractual duties with the legally and ethically required care to ensure that the decedents’

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remains would be treated with dignity and respect and would be laid to rest appropriately under

the standards of human decency and the law.

644. To the contrary, the defendants abandoned the remains at an unlicensed,

unsupervised, illegal operation, without a care, thought or provision for the ultimate fate of the

remains.

645. The defendants’ deceptive practices are all the more egregious under the

circumstances, given the emotional vulnerability of The Families when they were contracting

with the defendants, and the fact that The Families were required to entrust the remains of their

loved ones entirely to the defendants to perform the disposition services. The funeral home

defendants, in fact, are well aware of and specifically trained in the vulnerability and fragility of

those grieving the recent loss of a loved one.

646. The defendants’ unfair and/or deceptive practices were knowing and willful.

Contrary to their representations about the seriousness and professionalism with which they

would provide their services, the defendants knew – unlike The Families – either that Galilee

was unlicensed or knew that they, the defendants, had not made any reasonable inquiry into

Galilee’s status. The defendants further knew that they would not supervise the burial, nor

would they ensure that the decedent’s remains were treated lawfully and respectfully and were

laid to rest appropriately. The defendants – unlike The Families – also knew that they would

abandon the remains at Galilee without another thought or care for how the remains were treated

or laid to rest.

647. As a direct and proximate result of the defendants’ unfair and/or deceptive

practices, The Families suffered an ascertainable loss of money as well as interference with their

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quasi-property right in the remains of their loved ones for the purpose of final disposition of the

remains.

DEMAND FOR JURY TRIAL

648. A jury trial is demanded.

PRAYER FOR RELIEF

WHEREFORE, The Families, individually and on behalf of the class, request the

following relief:

(a) Certification of this action as a class action, appointment of The Families as classrepresentatives and undersigned counsel as class counsel, and designation of anyappropriate subclasses, for any or all claims and issues, under the applicable classaction provisions;

(b) An award of equitable, injunctive and declaratory relief described herein,including judicial supervision of the Galilee property and a judicial determinationof the rights and responsibilities of the parties regarding the remains that are thesubject to this action;

(c) An award of compensatory damages in an amount deemed appropriate by the trierof fact, jointly and severally against the defendants;

(d) An award of punitive damages, jointly and severally against the defendants;

(e) The establishment of a constructive trust upon the defendants’ property, revenuesand/or profits for the benefit of the class and disgorgement and restitution of thepast revenues and/or profits to the class;

(f) In the event a class is not certified, an award to The Families, individually, of allrecoverable damages under the Tennessee Consumer Protection Act, includingtreble damages, attorneys’ fees and costs;

(g) An award of prejudgment and post-judgment interest;

(h) An award of costs, including but not limited to discretionary costs, attorneys’ feesand expenses incurred in pursuing this case;

(i) Any other and further equitable relief this Court deems just and proper; and

(j) Any other and further relief to which they may be entitled at law or in equity.

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Dated this the 9th day of December 2014.

Howard B. Manis (BPR#16202)MANIS LAW FIRM

1000 Ridgeway Loop, Suite 320Memphis, TN 38120Phone: (901) [email protected]

Respectfully Submitted,

/s/Kathryn E. BarnettKathryn E. Barnett (BPR#15361)MORGAN & MORGAN-NASHVILLE, PLLC810 Broadway Suite 105Nashville, TN 37203Phone: (615) [email protected]

James E. Blount, IV (BPR#19301)BLOUNT LAW FIRM, PLLC1950 West Poplar Ave.Collierville, TN 38017Phone: (901) [email protected]

Samuel Cherry (BPR#21130)Danese K. BanksUrsula Yvette HolmesTHE COCHRAN FIRM

One Commerce Square, #1700Memphis, TN 38103Phone: (901) [email protected]

James Andrews (BPR)#157721405 Magnolia Ave.Knoxville, TN 37917Phone: (865) [email protected]

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