Knight-McDowell v. Rival Group, LLC et al

Filing 4

First AMENDED COMPLAINT against All Defendants with Jury Demand, filed by Gladys Knight-McDowell. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E)(Bussert, Christopher) Please visit our website at to obtain Pretrial Instructions which includes the Consent To Proceed Before U.S. Magistrate form.

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EXHIBIT E From: Sent: To: Cc: Subject: Dana Tucker Davis <> Wednesday, August 17, 2016 1:58 PM Michael Lambros; Bussert, Chris RE: State v. Hankerson All, Let me be clear – my client is NOT in possession of any intellectual property of his mother’s. He signed a statement asserting that he has no ownership rights to her name or the intellectual property. The memorabilia and replicas are physically in the restaurants. The restaurants are NOT under the control or management of my client. The State, through the Receiver, has control and decision making authority regarding any requests from Mrs. Knight McDowell. My client has no desire to fight his mother for the use of her name. He has bigger fights to handle at this time. Thanks, Dana. Dana M. Tucker Davis, Esq. Managing Member Tucker Davis Law, LLC 2675 Paces Ferry Road, Suite 215 Atlanta, GA 30339 Main: 678-909-2341 Fax: 678-909-6093 This is a communication from a debt collector. Unless you dispute the validity of this debt, or any portion thereof, within thirty (30) days after receipt of this letter, we will assume this debt to be valid. If you notify us in writing within the thirty (30) day period that the debt, or any portion thereof, is disputed, we will obtain verification of the debt during which time our debt collecting actions will stop, and a copy of such verification will be mailed to you. Additionally, upon your written request within the thirty (30) day period, we will provide you with the name and address of the original creditor, if different from the current creditor. We may proceed against you within the thirty (30) days if instructed to do so by our client and we are not verifying the debt. This correspondence may be an attempt to collect a debt, and any information obtained will be used for that purpose. This communication (together with all attachments) may contain privileged or confidential information and its sender reserves and asserts all rights that may apply to it. If you are not the intended recipient or believe that you have received this communication in error, please do not print, copy, retransmit, disseminate or otherwise use the information. Also, please indicate to the sender that you have received this communication in error and delete the copy you received. If you have not executed an engagement letter with this firm, we do not represent you as your attorney and no duties are intended or created by this communication. Most legal rights have time limits, and this e-mail does not constitute advice on the application of limitation periods unless otherwise so expressly stated. IRS CIRCULAR 230 Disclosure: Under U.S. Treasury regulations, we are required to inform you that any advice contained in this e1 mail or any attachment hereto is not intended to be used, and cannot be used, to avoid penalties imposed under the Internal Revenue Code. From: Michael Lambros [] Sent: Wednesday, August 17, 2016 12:25 PM To: Cc:; Dana Tucker Davis <> Subject: State v. Hankerson Chris: Thank you for your patience in waiting for my response. I have received conflicting information/claims related to the intellectual property rights and ownership rights of certain memorabilia purportedly owned by your client. My understanding is that Hankerson’s is claiming ownership of some if not all of the memorabilia. Further and I know he signed the release but I have been told by counsel that the corporations/businesses and/or Hankerson do have the rights to use the intellectual property. All to say this seems to be a battle between your client and her son and his companies. In addition, the Receiver has control of the businesses’ assets and probably needs to be involved in this discussion. If your client, the Defendants and the Receiver reach some understanding on the matter the Plaintiff will most likely have no objection. It may be best for your client to intervene in the action to pursue the relief she is seeking. Otherwise we can serve her with the complaint or you can acknowledge service and file an answer or claim. Lambros. MICHAEL G. LAMBROS The Lambros Firm, LLC 1355 Peachtree Street Suite 1280 Atlanta, Georgia 30309 Telephone No.(404) 221-1000 Fax No. (404) 577-3900 “Illegitimi non carborundum” CONFIDENTIALITY NOTICE This message is being sent by or on behalf of a lawyer. It is intended exclusively for the individual or entity to which it is addressed. This communication may contain information that is proprietary, privileged, confidential or otherwise legally exempt from disclosure. If you are not the intended or named addressee, you are not authorized to read, print, retain, copy or disseminate this message or any part of it. If you have recieved this message in error, please notify the sender immediately by email and delete all copies of the message. Thank you. 2

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