Case: 25CI1:22-cv-00286-EFP Document #: 368 Filed: 05/04/2023 Page 1 of 64

IN THE CIRCUIT COURT OF HINDS COUNTY, MISSISSIPPI

FIRST JUDICIAL DISTRICT

MISSISSIPPI DEPARTMENT OF HUMAN SERVICES PLAINTIFF

VS. CASE NO. 25CI1:22cv286-EFP

MISSISSIPPI COMMUNITY EDUCATION CENTER, INC., et al DEFENDANTS

BRETT LORENZO FAVRE’S ANSWER AND AFFIRMATIVE DEFENSES TO

PLAINTIFF’S FIRST AMENDED COMPLAINT

COMES NOW, Defendant, Brett Lorenzo Favre (“Favre” or “Defendant”), by and

through counsel, and files this, his Answer and Affirmative Defenses to Mississippi Department

of Human Services’ (“MDHS”) First Amended Complaint filed herein against him. The

Defendant would show unto the Court the following, to wit:

AFFIRMATIVE DEFENSES

FIRST DEFENSE

MDHS’s First Amended Complaint fails to state a claim against Favre upon which relief

can be granted pursuant to Rule 12(b)(6) of the Mississippi Rules of Civil Procedure.

SECOND DEFENSE

MDHS’s First Amended Complaint, or parts thereof, is barred by the doctrines of waiver,

estoppel, release, laches, acquiescence, abandonment, ratification, and consent.

THIRD DEFENSE

MDHS’s First Amended Complaint, or parts thereof, is barred by Miss. Code Ann. § 15-

3-1, Mississippi’s statute of frauds.

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FOURTH DEFENSE

MDHS has no contractual or statutory basis for an award of attorneys’ fees or interest from

Favre, and MDHS’s request for attorneys’ fees, interest and damages should be dismissed.

FIFTH DEFENSE

The injuries and/or damages of MDHS, if any, were the result of independent intervening

events for which Favre is not responsible and has no liability.

SIXTH DEFENSE

MDHS failed to mitigate its alleged damages.

SEVENTH DEFENSE

Favre acted in good faith at all times.

EIGHTH DEFENSE

Granting the relief sought by MDHS would result in unjust enrichment.

NINTH DEFENSE

Favre affirmatively pleads the doctrine of payment, accord and satisfaction, recoupment,

contribution and/or set off to the extent the same may be applicable pursuant to the laws of the

State of Mississippi.

TENTH DEFENSE

Favre affirmatively pleads all relevant aspects of the Mississippi Litigation Accountability

Act, which provides in part:

In any civil action commenced or appealed in any court of record in this state,
the court shall award . . . reasonable attorney’s fees and costs against any party
or attorney if the court, upon the motion of any party or on its own motion, finds
that an attorney or party brought an action . . . that is without substantial
justification, or that the action, or any claim or defense asserted, was interposed
for delay or harassment. . . .

Miss. Code. Ann. 11-55-5(1).

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ELEVENTH DEFENSE

MDHS’s claims for damages, if any, are reduced or barred in accordance with Miss. Code

Ann. 11-7-15.

TWELFTH DEFENSE

Favre specifically asserts and invokes all rights and defenses available to him as set forth

in Miss. R. Civ. P. 12(b)(1) through 12(b)(7), and for which a good faith legal and/or factual basis

exists or may exist on his behalf. Favre further reserves his right to supplement these preliminary

defenses via amendment or separate motion.

THIRTEENTH DEFENSE

To the extent applicable, Favre asserts the defenses enumerated in Miss. R. Civ. P. 8(c):

accord and satisfaction, arbitration and award, assumption of risk, contributory negligence,

discharge in bankruptcy, duress, estoppel, failure of consideration, fraud, illegality, injury by

fellow servant, laches, license, payment, release, res judicata, statute of frauds, statute of

limitations, waiver, and any other matter constituting an avoidance or affirmative defense.

FOURTEENTH DEFENSE

MDHS’s First Amended Complaint should be dismissed due to its failure to plead all

averments of fraud or the circumstances constituting fraud with particularity as required by

Mississippi Rule of Civil Procedure 9.

FIFTEENTH DEFENSE

If there was a civil conspiracy as alleged in MDHS’s First Amended Complaint, MDHS,

acting through its officers, employees, and agents, was a co-conspirator and cannot recover any

damages alleged by MDHS.

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SIXTEENTH DEFENSE

MDHS’s First Amended Complaint, or parts thereof, is barred by the doctrine of in pari

delicto.

SEVENTEENTH DEFENSE

If funds were spent outside permissible Temporary Assistance for Needy Families

program (“TANF”) expenditures, then to the extent funds were spent outside permissible TANF

expenditures, Favre is entitled to contribution from MDHS, for its direction, approval and other

conduct, acting through MDHS’s officers, employees, and agents, that resulted, in whole or in

part in any damages alleged by MDHS.

EIGHTEENTH DEFENSE

MDHS, acting through MDHS’s officers, employees, and agents, were the proximate

cause of any damages alleged by MDHS.

NINETEENTH DEFENSE

MDHS’s action against Favre is barred because Miss. Code § 43-1-27 does not confer

jurisdiction over Favre.

TWENTIETH DEFENSE

The facts not having been fully developed, Favre adopts any affirmative defenses not

specifically cited in this Answer and Affirmative Defenses, any other matter constituting an

avoidance or affirmative defense as may be shown by the facts in this cause, and hereby reserves

his right to amend his Answer and Affirmative Defenses to assert any such defense.

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TWENTY-FIRST DEFENSE

Without waiving any other defenses elsewhere asserted herein, Favre would aver and plead

that any allegation contained in MDHS’s First Amended Complaint which has not been

specifically admitted is hereby denied.

JURY TRIAL DEMAND

Favre, pursuant to Miss. R. Civ. P. 38 and Miss. Const. art. 3, § 31, hereby demands a

trial by jury on all issues that may be tried and decided by jury.

ANSWER

Having set forth his Affirmative Defenses above, Favre now responds to MDHS’s First

Amended Complaint paragraph by paragraph, as follows:

PARTIES

1. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 1 and, therefore, Favre denies same.

2. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 2 and, therefore, Favre denies same.

3. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 3 and, therefore, Favre denies same.

4. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 4 and, therefore, Favre denies same.

5. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 5 and, therefore, Favre denies same.

6. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 6 and, therefore, Favre denies same.

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7. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 7 and, therefore, Favre denies same.

8. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 8 and, therefore, Favre denies same.

9. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 9 and, therefore, Favre denies same.

10. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 10 and, therefore, Favre denies same.

11. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 11 and, therefore, Favre denies same.

12. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 12 and, therefore, Favre denies same.

13. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 13 and, therefore, Favre denies same.

14. Favre admits that he is an adult resident of Lamar County, Mississippi. The

remainder of the allegations in Paragraph 14 contain legal conclusions to which no response is

required.

15. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 15 and, therefore, Favre denies same.

16. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 16 and, therefore, Favre denies same.

17. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 17 and, therefore, Favre denies same.

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18. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 18 and, therefore, Favre denies same.

19. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 19 and, therefore, Favre denies same.

20. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 20 and, therefore, Favre denies same.

21. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 21 and, therefore, Favre denies same.

22. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 22 and, therefore, Favre denies same.

23. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 23 and, therefore, Favre denies same.

24. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 24 and, therefore, Favre denies same.

25. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 25 and, therefore, Favre denies same.

26. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 26 and, therefore, Favre denies same.

27. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 27 and, therefore, Favre denies same.

28. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 28 and, therefore, Favre denies same.

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29. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 29 and, therefore, Favre denies same.

30. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 30 and, therefore, Favre denies same.

31. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 31 and, therefore, Favre denies same.

32. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 32 and, therefore, Favre denies same.

33. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 33 and, therefore, Favre denies same.

34. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 34 and, therefore, Favre denies same.

35. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 35 and, therefore, Favre denies same.

36. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 36 and, therefore, Favre denies same.

37. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 37 and, therefore, Favre denies same.

38. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 38 and, therefore, Favre denies same.

39. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 39 and, therefore, Favre denies same.

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40. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 40 and, therefore, Favre denies same.

41. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 41 and, therefore, Favre denies same.

42. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 42 and, therefore, Favre denies same.

43. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 43 and, therefore, Favre denies same.

44. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 44 and, therefore, Favre denies same.

45. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 45 and, therefore, Favre denies same.

46. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 46 and, therefore, Favre denies same.

47. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 47 and, therefore, Favre denies same.

II. JURISDICTION AND VENUE

48. Paragraph 48 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre admits only that the Circuit Court of Hinds County has

original jurisdiction over this action under Miss. Code Ann. § 9-7-81. Favre denies the remaining

allegations contained in Paragraph 48.

49. Paragraph 49 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre denies the allegations contained in Paragraph 49.

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50. Paragraph 50 consists of legal conclusions to which no response is required. To

the extent a response is required, Venue is proper in the First Judicial District of Hinds County

under Miss. Code Ann. § 11-11-3, in that the alleged events that caused the alleged injuries claimed

occurred in Hinds County, and numerous defendants reside or have their principal places of

business in Hinds County.

III. LEGAL REQUIREMENTS FOR USE OF TANF FUNDS

51. Paragraph 51 quotes from the “Personal Responsibility and Work Opportunity

Reconciliation Act of 1996,” the contents of which speaks for itself. To the extent any further

response is required, Favre denies the allegations contained in Paragraph 51.

52. Paragraph 52 quotes from Mississippi Code Ann. § 43-17-1(4), the contents of

which speaks for itself. To the extent any further response is required, Favre denies the allegations

contained in Paragraph 52.

53. Paragraph 53 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre denies the allegations contained in Paragraph 53.

54. Paragraph 54 quotes from Mississippi Code Ann. § 43-17-1(2), the contents of

which speaks for itself. To the extent any further response is required, Favre denies the allegations

contained in Paragraph 54.

55. Paragraph 55 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre denies the allegations contained in Paragraph 55.

56. Paragraph 56 purports to summarize Appendix VI to Part 200 of title 2, Subtitle A,

Chapter II of the Code of Federal Regulations, the contents of which speaks for itself. To the

extent any further response is required, Favre denies the allegations contained in Paragraph 56.

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57. Paragraph 57 purports to summarize 2 CFR § 200.434, the contents of which speaks

for itself. To the extent any further response is required, Favre denies the allegations contained in

Paragraph 57.

58. Paragraph 58 purports to summarize 2 CFR § 200.439(b)(3), the contents of which

speaks for itself. To the extent any further response is required, Favre denies the allegations

contained in Paragraph 58.

59. Paragraph 59 purports to summarize 2 CFR § 200.446, the contents of which speaks

for itself. To the extent any further response is required, Favre denies the allegations contained in

Paragraph 59.

60. Paragraph 60 purports to summarize 2 CFR § 200.450, the contents of which speaks

for itself. To the extent any further response is required, Favre denies the allegations contained in

Paragraph 60.

61. Paragraph 61 purports to summarize 2 CFR § 200.459, the contents of which speaks

for itself. To the extent any further response is required, Favre denies the allegations contained in

Paragraph 61.

62. Paragraph 62 purports to summarize 2 CFR § 200.319, the contents of which speaks

for itself. To the extent any further response is required, Favre denies the allegations contained in

Paragraph 62.

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IV. FACTUAL ALLEGATIONS

THE CONSPIRACY TO DEFRAUD MDHS

63. Paragraph 63 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre denies the allegations contained in Paragraph 63.

64. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 64 and, therefore, Favre denies same.

65. Favre denies the allegations contained in Paragraph 65 that are directed toward him.

Favre lacks knowledge or information sufficient to form a belief as to the truth of the remaining

allegations contained in Paragraph 65 and, therefore, Favre denies same.

66. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 66 and, therefore, Favre denies same.

67. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 67 and, therefore, Favre denies same.

68. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 68 and, therefore, Favre denies same.

69. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 69 and, therefore, Favre denies same.

70. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 70 and, therefore, Favre denies same.

71. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 71 and, therefore, Favre denies same.

72. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 72 and, therefore, Favre denies same.

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73. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 73 and, therefore, Favre denies same.

74. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 74 and, therefore, Favre denies same.

75. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 75 and, therefore, Favre denies same.

76. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 76 and, therefore, Favre denies same.

77. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 77 and, therefore, Favre denies same.

78. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 78 and, therefore, Favre denies same.

79. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 79 and, therefore, Favre denies same.

80. Paragraph 80 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre denies the allegations contained in Paragraph 80.

81. Paragraph 81 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre denies the allegations contained in Paragraph 81.

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BRETT FAVRE AND THE USM VOLLEYBALL FACILITY

82. Favre admits only that his daughter played volleyball at USM and otherwise denies

the remaining allegations in Paragraph 82.

83. Favre admits that he donated autographed materials for auction with the intent that

the proceeds would be used toward construction of a volleyball facility at The University of

Southern Mississippi. Favre denies the remainder of the allegations in Paragraph 83.

84. Favre admits that he solicited third parties to provide money, goods, and services

to help fund and assist with the construction of a volleyball facility at The University of Southern

Mississippi. Favre denies the remainder of the allegations in Paragraph 84.

85. Favre admits that he met with Nancy New in July 2017 to discuss The University

of Southern Mississippi’s plans to construct a volleyball facility. Favre denies being on the

Foundation’s Board of Directors in 2017, but admits to being on the Foundation’s Board of

Directors as either an at large member or honorary member in later years. Favre lacks knowledge

or information sufficient to form a belief as to the truth of the remaining allegations contained in

Paragraph 85 and, therefore, Favre denies same.

86. Favre admits to meeting with Jon Gilbert, Nancy New, and John Davis on or around

July 24, 2017 to discuss funding for the construction of a volleyball facility at The University of

Southern Mississippi. Favre also admits that other people attended that meeting, but he lacks

sufficient knowledge or information to form a belief as to whether Teddy DiBiase or Garrig Shields

attended that meeting. Favre also admits that John Davis suggested that MDHS could provide $4

million in funding for the construction of a volleyball facility at The University of Southern

Mississippi. Favre lacks knowledge or information sufficient to form a belief as to the truth of the

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allegation that Jon Gilbert sat on the Board of Directors of the Foundation. Favre denies the

remainder of the allegations in Paragraph 86.

87. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the remaining allegations contained in Paragraph 87 and, therefore, Favre denies same.

88. Paragraph 88 quotes from text messages, the contents of which speaks for

themselves.

89. Favre denies the allegations contained in Paragraph 89 that are directed toward him.

Favre lacks knowledge or information sufficient to form a belief as to the truth of the remaining

allegations contained in Paragraph 89 and, therefore, Favre denies same.

90. Paragraph 90 quotes from text messages, the contents of which speak for

themselves. To the extent any further answer is required, Favre denies the allegations in Paragraph

90.

91. Favre denies the allegations contained in Paragraph 91 that are directed toward him.

Favre lacks knowledge or information sufficient to form a belief as to the truth of the remaining

allegations contained in Paragraph 91 and, therefore, Favre denies same.

92. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 92 and, therefore, Favre denies same.

93. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 93 and, therefore, Favre denies same.

94. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 94 and, therefore, Favre denies same.

95. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 95 and, therefore, Favre denies same.

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96. Paragraph 96 consists of legal conclusions to which no response is required. To the

extent a response is required, Favre denies the allegations contained in Paragraph 96.

97. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 97 and, therefore, Favre denies same.

98. Favre denies the allegations in Paragraph 98.

99. Favre denies the allegations that the payments referenced in Paragraph 99 were

“made with TANF funds.” MDHS receives funding from multiple federal, state, and “other”

sources which is comingled, and, because money is fungible, it is impossible to determine from

the commingled funds whether MDHS’s transfers to Mississippi Community Education Center,

Inc. (“MCEC”) consisted of federal, state, or “other” appropriations. Favre lacks knowledge or

information sufficient to form a belief as to the truth of the remainder of the allegations contained

in Paragraph 99 and, therefore, Favre denies same.

100. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 100 and, therefore, Favre denies same.

101. Favre denies the allegations contained in Paragraph 101 that are directed toward

him. Favre lacks knowledge or information sufficient to form a belief as to the truth of the

remaining allegations contained in Paragraph 101 and, therefore, Favre denies same.

102. Favre denies the allegations in Paragraph 102.

103. Favre denies the allegations in Paragraph 103.

104. Favre admits only that MCEC paid Favre Enterprises, Inc. $1.1 million in exchange

for services Favre performed for MCEC, which included Favre recording a radio advertisement

for MDHS’s Family First initiative that aired state-wide over the course of several months. Favre

denies the allegations that the payment referenced in Paragraph 104 was made with “TANF grant

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funds.” MDHS receives funding from multiple federal, state, and “other” sources which is

comingled, and, because money is fungible, it is impossible to determine from the commingled

funds whether MDHS’s transfers to MCEC consisted of federal, state, or “other” appropriations.

105. Favre admits only that he repaid $1.1 million to the State. Favre denies the

remaining allegations in Paragraph 105.

106. Favre denies the allegations in Paragraph 106.

107. Paragraph 107 quotes from text messages, the contents of which speaks for

themselves. Favre denies all remaining allegations in Paragraph 107.

108. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 108 and, therefore, Favre denies same.

109. Favre denies the allegations contained in Paragraph 109. Favre further denies that

the “source of the funding was federal TANF grant funds.” MDHS receives funding from multiple

federal, state, and “other” sources which is comingled, and, because money is fungible, it is

impossible to determine from the commingled funds whether MDHS’s transfers to MCEC

consisted of federal, state, or “other” appropriations.

110. Favre denies the allegations contained in Paragraph 110 that are directed toward

him. Favre lacks knowledge or information sufficient to form a belief as to the truth of the

remaining allegations contained in Paragraph 110 and, therefore, Favre denies same.

111. Paragraph 111 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre denies the allegations contained in Paragraph 111.

112. Paragraph 112 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre denies the allegations contained in Paragraph 112.

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BRETT FAVRE AND THE CONCUSSION DRUG COMPANY, PREVACUS

113. Favre admits only that as of December 2018, he had invested over $250,000 in

Prevacus, Inc., a private, for-profit biotechnology corporation. Favre lacks knowledge or

information sufficient to form a belief as to the truth of the remaining allegations contained in

Paragraph 113 and, therefore, Favre denies same.

114. Favre admits only that he solicited third parties to invest in Prevacus. Favre denies

the remaining allegations contained in Paragraph 114 that are directed toward him. Favre lacks

knowledge or information sufficient to form a belief as to the truth of the remaining allegations

contained in Paragraph 114 and, therefore, Favre denies same.

115. Paragraph 115 paraphrases text messages, the contents of which speaks for

themselves. To the extent any further answer is required, Favre denies the allegations in Paragraph

115.

116. Favre admits only that he hosted Jake VanLandingham, Nancy New, and John

Davis at his home on or around January 2, 2019. Favre also admits that other people may have

attended, but he lacks sufficient knowledge or information to form a belief as to who else may

have attended. Favre denies the remainder of the allegations contained in Paragraph 116.

117. Favre denies the allegations contained in Paragraph 117 that are directed toward

him. Favre lacks knowledge or information sufficient to form a belief as to the truth of the

remaining allegations contained in Paragraph 117 and, therefore, Favre denies same.

118. Favre denies the allegations contained in Paragraph 118 that are directed toward

him. Favre lacks knowledge or information sufficient to form a belief as to the truth of the

remaining allegations contained in Paragraph 118 and, therefore, Favre denies same.

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119. Favre denies the allegations contained in Paragraph 119 that are directed toward

him. Favre lacks knowledge or information sufficient to form a belief as to the truth of the

remaining allegations contained in Paragraph 119 and, therefore, Favre denies same.

120. Paragraph 120 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre denies the allegations contained in Paragraph 120 that are

directed toward him. Favre lacks knowledge or information sufficient to form a belief as to the

truth of the remaining allegations contained in Paragraph 120 and, therefore, Favre denies same.

121. Favre denies the allegations contained in Paragraph 121 that are directed toward

him. Favre lacks knowledge or information sufficient to form a belief as to the truth of the

remaining allegations contained in Paragraph 121 and, therefore, Favre denies same.

122. Paragraph 122 consists of legal conclusions to which no response is required. To

the extent a response is required, denies the allegations contained in Paragraph 122.

123. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 123 and, therefore, Favre denies same.

124. Paragraph 124 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre denies the allegations contained in Paragraph 124 that are

directed toward him. Favre lacks knowledge or information sufficient to form a belief as to the

truth of the remaining allegations contained in Paragraph 124 and, therefore, Favre denies same.

125. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 125 and, therefore, Favre denies same.

126. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 126 and, therefore, Favre denies same.

19
Case: 25CI1:22-cv-00286-EFP Document #: 368 Filed: 05/04/2023 Page 20 of 64

PAUL LACOSTE AND VICTORY SPORTS FOUNDATION

127. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 127 and, therefore, Favre denies same.

128. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 128 and, therefore, Favre denies same.

129. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 129 and, therefore, Favre denies same.

130. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 130 and, therefore, Favre denies same.

131. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 131 and, therefore, Favre denies same.

132. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 132 and, therefore, Favre denies same.

133. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 133 and, therefore, Favre denies same.

134. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 134 and, therefore, Favre denies same.

135. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 135 and, therefore, Favre denies same.

136. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 136 and, therefore, Favre denies same.

137. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 137 and, therefore, Favre denies same.

20
Case: 25CI1:22-cv-00286-EFP Document #: 368 Filed: 05/04/2023 Page 21 of 64

138. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 138 and, therefore, Favre denies same.

139. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 139 and, therefore, Favre denies same.

140. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 140 and, therefore, Favre denies same.

MARCUS DUPREE AND THE MARCUS DUPREE FOUNDATION

141. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 141 and, therefore, Favre denies same.

142. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 142 and, therefore, Favre denies same.

143. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 143 and, therefore, Favre denies same.

144. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 144 and, therefore, Favre denies same.

145. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 145 and, therefore, Favre denies same.

146. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 146 and, therefore, Favre denies same.

147. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 147 and, therefore, Favre denies same.

21
Case: 25CI1:22-cv-00286-EFP Document #: 368 Filed: 05/04/2023 Page 22 of 64

THE DIBIASE FAMILY

(A) Teddy DiBiase, Jr.

148. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 148 and, therefore, Favre denies same.

149. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 149 and, therefore, Favre denies same.

150. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 150 and, therefore, Favre denies same.

151. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 151 and, therefore, Favre denies same.

152. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 152 and, therefore, Favre denies same.

153. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 153 and, therefore, Favre denies same.

154. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 154 and, therefore, Favre denies same.

155. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 155 and, therefore, Favre denies same.

156. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 156 and, therefore, Favre denies same.

157. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 157 and, therefore, Favre denies same.

158. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 158 and, therefore, Favre denies same.

22
Case: 25CI1:22-cv-00286-EFP Document #: 368 Filed: 05/04/2023 Page 23 of 64

159. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 159 and, therefore, Favre denies same.

160. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 160 and, therefore, Favre denies same.

161. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 161 and, therefore, Favre denies same.

162. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 162 and, therefore, Favre denies same.

163. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 163 and, therefore, Favre denies same.

164. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 164 and, therefore, Favre denies same.

(B) Brett DiBiase

165. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 165 and, therefore, Favre denies same.

166. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 166 and, therefore, Favre denies same.

167. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 167 and, therefore, Favre denies same.

168. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 168 and, therefore, Favre denies same.

169. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 169 and, therefore, Favre denies same.

23
Case: 25CI1:22-cv-00286-EFP Document #: 368 Filed: 05/04/2023 Page 24 of 64

170. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 170 and, therefore, Favre denies same.

171. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 171 and, therefore, Favre denies same.

172. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 172 and, therefore, Favre denies same.

173. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 173 and, therefore, Favre denies same.

174. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 174 and, therefore, Favre denies same.

175. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 175 and, therefore, Favre denies same.

176. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 176 and, therefore, Favre denies same.

177. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 177 and, therefore, Favre denies same.

178. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 178 and, therefore, Favre denies same.

179. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 179 and, therefore, Favre denies same.

180. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 180 and, therefore, Favre denies same.

24
Case: 25CI1:22-cv-00286-EFP Document #: 368 Filed: 05/04/2023 Page 25 of 64

181. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 181 and, therefore, Favre denies same.

(C) Ted DiBiase, Sr.

182. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 182 and, therefore, Favre denies same.

183. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 183 and, therefore, Favre denies same.

184. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 184 and, therefore, Favre denies same.

185. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 185 and, therefore, Favre denies same.

186. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 186 and, therefore, Favre denies same.

187. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 187 and, therefore, Favre denies same.

188. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 188 and, therefore, Favre denies same.

189. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 189 and, therefore, Favre denies same.

190. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 190 and, therefore, Favre denies same.

191. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 191 and, therefore, Favre denies same.

25
Case: 25CI1:22-cv-00286-EFP Document #: 368 Filed: 05/04/2023 Page 26 of 64

192. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 192 and, therefore, Favre denies same.

193. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 193 and, therefore, Favre denies same.

194. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 194 and, therefore, Favre denies same.

195. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 195 and, therefore, Favre denies same.

196. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 196 and, therefore, Favre denies same.

197. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 197 and, therefore, Favre denies same.

THE DIBIASES’ FRIENDS

(A) Adam Such and SBGI, LLC

198. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 198 and, therefore, Favre denies same.

199. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 199 and, therefore, Favre denies same.

200. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 200 and, therefore, Favre denies same.

201. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 201 and, therefore, Favre denies same.

202. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 202 and, therefore, Favre denies same.

26
Case: 25CI1:22-cv-00286-EFP Document #: 368 Filed: 05/04/2023 Page 27 of 64

203. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 203 and, therefore, Favre denies same.

204. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 204 and, therefore, Favre denies same.

(B) Nick Coughlin and NCC Ventures

205. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 205 and, therefore, Favre denies same.

206. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 206 and, therefore, Favre denies same.

207. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 207 and, therefore, Favre denies same.

208. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 208 and, therefore, Favre denies same.

209. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 209 and, therefore, Favre denies same.

210. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 210 and, therefore, Favre denies same.

211. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 211 and, therefore, Favre denies same.

212. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 212 and, therefore, Favre denies same.

213. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 213 and, therefore, Favre denies same.

27
Case: 25CI1:22-cv-00286-EFP Document #: 368 Filed: 05/04/2023 Page 28 of 64

214. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 214 and, therefore, Favre denies same.

JOHN DAVIS’S FAMILY MEMBERS

(A) John Davis’s brother-in-law, Brian Jeff Smith

215. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 215 and, therefore, Favre denies same.

216. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 216 and, therefore, Favre denies same.

217. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 217 and, therefore, Favre denies same.

218. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 218 and, therefore, Favre denies same.

219. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 219 and, therefore, Favre denies same.

220. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 220 and, therefore, Favre denies same.

221. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 221 and, therefore, Favre denies same.

222. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 222 and, therefore, Favre denies same.

223. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 223 and, therefore, Favre denies same.

224. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 224 and, therefore, Favre denies same.

28
Case: 25CI1:22-cv-00286-EFP Document #: 368 Filed: 05/04/2023 Page 29 of 64

(B) John Davis’s nephew, Austin Smith

225. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 225 and, therefore, Favre denies same.

226. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 226 and, therefore, Favre denies same.

227. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 227 and, therefore, Favre denies same.

228. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 228 and, therefore, Favre denies same.

229. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 229 and, therefore, Favre denies same.

230. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 230 and, therefore, Favre denies same.

231. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 231 and, therefore, Favre denies same.

232. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 232 and, therefore, Favre denies same.

233. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 233 and, therefore, Favre denies same.

234. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 234 and, therefore, Favre denies same.

235. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 235 and, therefore, Favre denies same.

29
Case: 25CI1:22-cv-00286-EFP Document #: 368 Filed: 05/04/2023 Page 30 of 64

236. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 236 and, therefore, Favre denies same.

237. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 237 and, therefore, Favre denies same.

238. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 238 and, therefore, Favre denies same.

239. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 239 and, therefore, Favre denies same.

240. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 240 and, therefore, Favre denies same.

MCEC’S OTHER TRANSFEREES

(A) New Learning Resources

241. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 241 and, therefore, Favre denies same.

242. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 242 and, therefore, Favre denies same.

243. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 243 and, therefore, Favre denies same.

244. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 244 and, therefore, Favre denies same.

245. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 245 and, therefore, Favre denies same.

246. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 246 and, therefore, Favre denies same.

30
Case: 25CI1:22-cv-00286-EFP Document #: 368 Filed: 05/04/2023 Page 31 of 64

247. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 247 and, therefore, Favre denies same.

248. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 248 and, therefore, Favre denies same.

(B) Jesse New and Magnolia Strategies

249. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 249 and, therefore, Favre denies same.

250. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 250 and, therefore, Favre denies same.

251. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 251 and, therefore, Favre denies same.

252. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 252 and, therefore, Favre denies same.

253. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 253 and, therefore, Favre denies same.

254. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 254 and, therefore, Favre denies same.

255. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 255 and, therefore, Favre denies same.

256. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 256 and, therefore, Favre denies same.

257. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 257 and, therefore, Favre denies same.

31
Case: 25CI1:22-cv-00286-EFP Document #: 368 Filed: 05/04/2023 Page 32 of 64

258. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 258 and, therefore, Favre denies same.

(C) Lobaki Foundation and Lobaki, Inc.

259. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 259 and, therefore, Favre denies same.

260. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 260 and, therefore, Favre denies same.

261. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 261 and, therefore, Favre denies same.

262. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 262 and, therefore, Favre denies same.

263. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 263 and, therefore, Favre denies same.

264. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 264 and, therefore, Favre denies same.

265. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 265 and, therefore, Favre denies same.

266. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 266 and, therefore, Favre denies same.

267. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 267 and, therefore, Favre denies same.

268. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 268 and, therefore, Favre denies same.

32
Case: 25CI1:22-cv-00286-EFP Document #: 368 Filed: 05/04/2023 Page 33 of 64

269. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 269 and, therefore, Favre denies same.

270. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 270 and, therefore, Favre denies same.

271. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 271 and, therefore, Favre denies same.

272. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 272 and, therefore, Favre denies same.

273. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 273 and, therefore, Favre denies same.

274. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 274 and, therefore, Favre denies same.

(E) Soul City Hospitality

275. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 275 and, therefore, Favre denies same.

276. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 276 and, therefore, Favre denies same.

277. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 277 and, therefore, Favre denies same.

278. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 278 and, therefore, Favre denies same.

33
Case: 25CI1:22-cv-00286-EFP Document #: 368 Filed: 05/04/2023 Page 34 of 64

FRC’S OTHER TRANSFEREES

(A) SouthTec, Inc.

279. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 279 and, therefore, Favre denies same.

280. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 280 and, therefore, Favre denies same.

281. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 281 and, therefore, Favre denies same.

(B) Chase Computer Services, Inc.

282. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 282 and, therefore, Favre denies same.

283. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 283 and, therefore, Favre denies same.

284. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 284 and, therefore, Favre denies same.

285. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 285 and, therefore, Favre denies same.

V. LEGAL CLAIMS

COUNT 1: VIOLATIONS OF MISS. CODE ANN. § 31-7-57(1) BY JOHN DAVIS,

GARRIG SHIELDS AND JACOB BLACK

286. Paragraph 286 quotes from Miss. Code Ann. § 31-7-57(1), the contents of which

speaks for itself. To the extent any further response is required, Favre denies the allegations

contained in Paragraph 286.

287. Paragraph 287 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-

34
Case: 25CI1:22-cv-00286-EFP Document #: 368 Filed: 05/04/2023 Page 35 of 64

278. Favre denies the remaining allegations contained in Paragraph 287 that are directed toward

him. Favre lacks knowledge or information sufficient to form a belief as to the truth of the

remaining allegations contained in Paragraph 287 and, therefore, Favre denies same.

288. Paragraph 288 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 288 and, therefore, Favre denies same.

289. Paragraph 289 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 289 and, therefore, Favre denies same.

290. Paragraph 290 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-

62, 182-197, and 205-214. Favre lacks knowledge or information sufficient to form a belief as to

the truth of the remaining allegations contained in Paragraph 290 and, therefore, Favre denies

same.

291. Paragraph 291 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 291 and, therefore, Favre denies same.

292. Paragraph 292 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-

62 and 148-164. Favre lacks knowledge or information sufficient to form a belief as to the truth

of the remaining allegations contained in Paragraph 292 and, therefore, Favre denies same.

35
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293. Paragraph 293 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 293 and, therefore, Favre denies same.

COUNT 2: DEBTS DUE UNDER MISSISSIPPI CODE ANN. § 43-1-27

294. Paragraph 294 quotes from Miss. Code Ann. § 43-1-27, the contents of which

speaks for itself. To the extent any further response is required, Favre denies the allegations

contained in Paragraph 294.

295. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the allegations contained in Paragraph 295 and, therefore, Favre denies same.

296. Favre denies the allegations in Paragraph 296.

297. Paragraph 297 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-

278. Favre lacks knowledge or information sufficient to form a belief as to the truth of the

remaining allegations contained in Paragraph 297 and, therefore, Favre denies same.

298. Paragraph 298 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-

112. Favre denies the remaining allegations contained in Paragraph 298.

299. Paragraph 299 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-81

and 113-126. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the remaining allegations contained in Paragraph 299 and, therefore, Favre denies same.

300. Paragraph 300 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-81

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and 113-126. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the remaining allegations contained in Paragraph 300 and, therefore, Favre denies same.

301. Paragraph 301 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-81

and 127-140. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the remaining allegations contained in Paragraph 301 and, therefore, Favre denies same.

302. Paragraph 302 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-81

and 141-147. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the remaining allegations contained in Paragraph 302 and, therefore, Favre denies same.

303. Paragraph 303 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 52-81

and 148-164. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the remaining allegations contained in Paragraph 303 and, therefore, Favre denies same.

304. Paragraph 304 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-81

and 148-164. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the remaining allegations contained in Paragraph 304 and, therefore, Favre denies same.

305. Paragraph 305 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-81

and 148-164. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the remaining allegations contained in Paragraph 305 and, therefore, Favre denies same.

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Case: 25CI1:22-cv-00286-EFP Document #: 368 Filed: 05/04/2023 Page 38 of 64

306. Paragraph 306 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-81

and 161-164. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the remaining allegations contained in Paragraph 306 and, therefore, Favre denies same.

307. Paragraph 307 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-81

and 165-181. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the remaining allegations contained in Paragraph 307 and, therefore, Favre denies same.

308. Paragraph 308 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-81

and 165-181. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the remaining allegations contained in Paragraph 308 and, therefore, Favre denies same.

309. Paragraph 309 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-81

and 176-181. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the remaining allegations contained in Paragraph 309 and, therefore, Favre denies same.

310. Paragraph 310 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-81

and 182-197. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the remaining allegations contained in Paragraph 310 and, therefore, Favre denies same.

311. Paragraph 311 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-81

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Case: 25CI1:22-cv-00286-EFP Document #: 368 Filed: 05/04/2023 Page 39 of 64

and 182-197. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the remaining allegations contained in Paragraph 311 and, therefore, Favre denies same.

312. Paragraph 312 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-81

and 198-204. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the remaining allegations contained in Paragraph 312 and, therefore, Favre denies same.

313. Paragraph 313 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-81

and 205-214. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the remaining allegations contained in Paragraph 313 and, therefore, Favre denies same.

314. Paragraph 314 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-81

and 215-224. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the remaining allegations contained in Paragraph 314 and, therefore, Favre denies same.

315. Paragraph 315 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-81

and 215-224. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the remaining allegations contained in Paragraph 315 and, therefore, Favre denies same.

316. Paragraph 316 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-81

and 225-240. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the remaining allegations contained in Paragraph 316 and, therefore, Favre denies same.

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Case: 25CI1:22-cv-00286-EFP Document #: 368 Filed: 05/04/2023 Page 40 of 64

317. Paragraph 317 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-81

and 241-248. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the remaining allegations contained in Paragraph 317 and, therefore, Favre denies same.

318. Paragraph 318 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-81

and 249-258. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the remaining allegations contained in Paragraph 318 and, therefore, Favre denies same.

319. Paragraph 319 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-81

and 259-267. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the remaining allegations contained in Paragraph 319 and, therefore, Favre denies same.

320. Paragraph 320 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-81

and 268-274. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the remaining allegations contained in Paragraph 320 and, therefore, Favre denies same.

321. Paragraph 321 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-81

and 275-278. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the remaining allegations contained in Paragraph 321 and, therefore, Favre denies same.

COUNT 3: TORTS OF CIVIL CONSPIRACY

322. Paragraph 322 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-

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Case: 25CI1:22-cv-00286-EFP Document #: 368 Filed: 05/04/2023 Page 41 of 64

278. Favre denies that Favre Enterprises is a Defendant. Favre also denies the allegations

contained in Paragraph 322 that are directed toward him. Favre lacks knowledge or information

sufficient to form a belief as to the truth of the remaining allegations contained in Paragraph 322

and, therefore, Favre denies same.

323. Paragraph 323 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-

278. Favre denies the allegations contained in Paragraph 323 that are directed toward him. Favre

lacks knowledge or information sufficient to form a belief as to the truth of the remaining

allegations contained in Paragraph 323 and, therefore, Favre denies same.

324. Paragraph 324 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-

112. Favre denies the remaining allegations contained in Paragraph 324.

325. Paragraph 325 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre denies the allegations contained in Paragraph 325.

326. Paragraph 326 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-81

and 113-126. Favre denies the allegations contained in Paragraph 326 that are directed toward

him. Favre lacks knowledge or information sufficient to form a belief as to the truth of the

remaining allegations contained in Paragraph 326 and, therefore, Favre denies same.

327. Paragraph 327 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre denies the allegations contained in Paragraph 327 that are

directed toward him. Favre lacks knowledge or information sufficient to form a belief as to the

truth of the remaining allegations contained in Paragraph 327 and, therefore, Favre denies same.

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Case: 25CI1:22-cv-00286-EFP Document #: 368 Filed: 05/04/2023 Page 42 of 64

328. Paragraph 328 consists of legal conclusions to which no response is required. To the

extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-81 and

141-147. Favre lacks knowledge or information sufficient to form a belief as to the truth of the

remaining allegations contained in Paragraph 328 and, therefore, Favre denies same.

329. Paragraph 329 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 329 and, therefore, Favre denies same.

330. Paragraph 330 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-81

and 148-164. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the remaining allegations contained in Paragraph 330 and, therefore, Favre denies same.

331. Paragraph 331 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 331 and, therefore, Favre denies same.

332. Paragraph 332 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-81

and 165-181. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the remaining allegations contained in Paragraph 332 and, therefore, Favre denies same.

333. Paragraph 333 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 333 and, therefore, Favre denies same.

334. Paragraph 334 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-81

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Case: 25CI1:22-cv-00286-EFP Document #: 368 Filed: 05/04/2023 Page 43 of 64

and 182-197. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the remaining allegations contained in Paragraph 334 and, therefore, Favre denies same.

335. Paragraph 335 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 335 and, therefore, Favre denies same.

336. Paragraph 336 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-81

and 182-197. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the remaining allegations contained in Paragraph 336 and, therefore, Favre denies same.

337. Paragraph 337 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 337 and, therefore, Favre denies same.

338. Paragraph 338 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-81

and 198-204. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the remaining allegations contained in Paragraph 338 and, therefore, Favre denies same.

339. Paragraph 339 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 339 and, therefore, Favre denies same.

340. Paragraph 340 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-81

and 205-214. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the remaining allegations contained in Paragraph 340 and, therefore, Favre denies same.

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Case: 25CI1:22-cv-00286-EFP Document #: 368 Filed: 05/04/2023 Page 44 of 64

341. Paragraph 341 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 341 and, therefore, Favre denies same.

342. Paragraph 342 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-81

and 215-224. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the remaining allegations contained in Paragraph 342 and, therefore, Favre denies same.

343. Paragraph 343 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 343 and, therefore, Favre denies same.

344. Paragraph 344 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-81

and 225-240. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the remaining allegations contained in Paragraph 344 and, therefore, Favre denies same.

345. Paragraph 345 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 345 and, therefore, Favre denies same.

346. Paragraph 346 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-81

and 241-248. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the remaining allegations contained in Paragraph 346 and, therefore, Favre denies same.

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Case: 25CI1:22-cv-00286-EFP Document #: 368 Filed: 05/04/2023 Page 45 of 64

347. Paragraph 347 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 347 and, therefore, Favre denies same.

348. Paragraph 348 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre incorporates by reference his answers to Paragraphs 51-81

and 249-258. Favre lacks knowledge or information sufficient to form a belief as to the truth of

the remaining allegations contained in Paragraph 348 and, therefore, Favre denies same.

349. Paragraph 349 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 349 and, therefore, Favre denies same.

COUNT 4: AIDING AND ABETTING FRAUD AND STATUTORY VIOLATIONS

350. Favre, in response to Paragraph 350, incorporates by reference all of his answers to

the preceding Paragraphs of the First Amended Complaint.

351. Paragraph 351 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 351 and, therefore, Favre denies same.

352. Paragraph 352 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 352 and, therefore, Favre denies same.

353. Paragraph 353 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 353 and, therefore, Favre denies same.

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Case: 25CI1:22-cv-00286-EFP Document #: 368 Filed: 05/04/2023 Page 46 of 64

354. Paragraph 354 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 354 and, therefore, Favre denies same.

355. Paragraph 355 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 355 and, therefore, Favre denies same.

356. Paragraph 356 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 356 and, therefore, Favre denies same.

357. Paragraph 357 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 357 and, therefore, Favre denies same.

358. Paragraph 358 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 358 and, therefore, Favre denies same.

359. Paragraph 359 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 359 and, therefore, Favre denies same.

360. Paragraph 360 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 360 and, therefore, Favre denies same.

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Case: 25CI1:22-cv-00286-EFP Document #: 368 Filed: 05/04/2023 Page 47 of 64

361. Paragraph 361 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 361 and, therefore, Favre denies same.

362. Paragraph 362 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 362 and, therefore, Favre denies same.

363. Paragraph 363 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 363 and, therefore, Favre denies same.

364. Paragraph 364 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 364 and, therefore, Favre denies same.

365. Paragraph 365 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 365 and, therefore, Favre denies same.

366. Paragraph 366 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 366 and, therefore, Favre denies same.

COUNT 5: MISSISSIPPI UNIFORM FRAUDULENT TRANSFER ACT

367. Favre, in response to Paragraph 367, incorporates by reference all of his answers to

the preceding Paragraphs of the First Amended Complaint.

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Case: 25CI1:22-cv-00286-EFP Document #: 368 Filed: 05/04/2023 Page 48 of 64

368. Paragraph 368 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 368 and, therefore, Favre denies same.

369. Paragraph 369 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre denies the allegations contained in Paragraph 369.

370. Paragraph 370 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre denies the allegations contained in Paragraph 370.

371. Paragraph 371 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 371 and, therefore, Favre denies same.

372. Paragraph 372 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 372 and, therefore, Favre denies same.

373. Paragraph 373 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 373 and, therefore, Favre denies same.

374. Paragraph 374 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 374 and, therefore, Favre denies same.

375. Paragraph 375 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 375 and, therefore, Favre denies same.

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Case: 25CI1:22-cv-00286-EFP Document #: 368 Filed: 05/04/2023 Page 49 of 64

376. Paragraph 376 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 376 and, therefore, Favre denies same.

377. Paragraph 377 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 377 and, therefore, Favre denies same.

378. Paragraph 378 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 378 and, therefore, Favre denies same.

379. Paragraph 379 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 379 and, therefore, Favre denies same.

380. Paragraph 380 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 380 and, therefore, Favre denies same.

381. Paragraph 381 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 381 and, therefore, Favre denies same.

382. Paragraph 382 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 382 and, therefore, Favre denies same.

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Case: 25CI1:22-cv-00286-EFP Document #: 368 Filed: 05/04/2023 Page 50 of 64

383. Paragraph 383 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 383 and, therefore, Favre denies same.

384. Paragraph 384 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 384 and, therefore, Favre denies same.

385. Paragraph 385 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 385 and, therefore, Favre denies same.

386. Paragraph 386 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 386 and, therefore, Favre denies same.

387. Paragraph 387 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 387 and, therefore, Favre denies same.

388. Paragraph 388 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 388 and, therefore, Favre denies same.

389. Paragraph 389 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 389 and, therefore, Favre denies same.

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Case: 25CI1:22-cv-00286-EFP Document #: 368 Filed: 05/04/2023 Page 51 of 64

390. Paragraph 390 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 390 and, therefore, Favre denies same.

391. Paragraph 391 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 391 and, therefore, Favre denies same.

392. Paragraph 392 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 392 and, therefore, Favre denies same.

393. Paragraph 393 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 393 and, therefore, Favre denies same.

394. Paragraph 394 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 394 and, therefore, Favre denies same.

395. Paragraph 395 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 395 and, therefore, Favre denies same.

396. Paragraph 396 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 396 and, therefore, Favre denies same.

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Case: 25CI1:22-cv-00286-EFP Document #: 368 Filed: 05/04/2023 Page 52 of 64

397. Paragraph 397 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 397 and, therefore, Favre denies same.

COUNT 6: NEGLIGENCE AGAINST TANF FUND RECIPIENTS

398. Favre, in response to Paragraph 398, incorporates by reference all of his answers to

the preceding Paragraphs of the First Amended Complaint.

399. Paragraph 399 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre denies that Favre Enterprises is a defendant. Favre also

denies the allegations contained in Paragraph 399 that are directed toward him. Favre lacks

knowledge or information sufficient to form a belief as to the truth of the remaining allegations

contained in Paragraph 399 and, therefore, Favre denies same.

400. Paragraph 400 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 400 and, therefore, Favre denies same.

401. Paragraph 401 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre denies the allegations contained in Paragraph 401 that are

directed toward him. Favre lacks knowledge or information sufficient to form a belief as to the

truth of the remaining allegations contained in Paragraph 401 and, therefore, Favre denies same.

402. Paragraph 402 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre denies the allegations contained in Paragraph 402 that are

directed toward him. Favre lacks knowledge or information sufficient to form a belief as to the

truth of the remaining allegations contained in Paragraph 402 and, therefore, Favre denies same.

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403. Paragraph 403 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre denies the allegations contained in Paragraph 403 that are

directed toward him. Favre lacks knowledge or information sufficient to form a belief as to the

truth of the remaining allegations contained in Paragraph 403 and, therefore, Favre denies same.

404. Paragraph 404 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 404 and, therefore, Favre denies same.

405. Paragraph 405 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 405 and, therefore, Favre denies same.

406. Paragraph 406 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 406 and, therefore, Favre denies same.

407. Paragraph 407 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 407 and, therefore, Favre denies same.

408. Paragraph 408 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 408 and, therefore, Favre denies same.

409. Paragraph 409 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre denies the allegations contained in Paragraph 409 that are

directed toward him. Favre lacks knowledge or information sufficient to form a belief as to the

truth of the remaining allegations contained in Paragraph 409 and, therefore, Favre denies same.

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410. Paragraph 410 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre denies the allegations contained in Paragraph 410 that are

directed toward him. Favre lacks knowledge or information sufficient to form a belief as to the

truth of the remaining allegations contained in Paragraph 410 and, therefore, Favre denies same.

411. Paragraph 411 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre denies the allegations contained in Paragraph 411 that are

directed toward him. Favre lacks knowledge or information sufficient to form a belief as to the

truth of the remaining allegations contained in Paragraph 411 and, therefore, Favre denies same.

COUNT 7: PROFESSIONAL NEGLIGENCE OF WILLIAMS, WEISS, HESTER & CO.

412. Paragraph 412 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 412 and, therefore, Favre denies same.

413. Paragraph 413 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 413 and, therefore, Favre denies same.

414. Paragraph 414 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 414 and, therefore, Favre denies same.

415. Paragraph 415 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 415 and, therefore, Favre denies same.

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416. Paragraph 416 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 416 and, therefore, Favre denies same.

417. Paragraph 417 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 417 and, therefore, Favre denies same.

COUNT 8: BREACH OF TANF SUBGRANTS BY MCEC, FRC, AND HEART OF

DAVID

418. Favre, in response to Paragraph 418, incorporates by reference all of his answers to

the preceding Paragraphs of the First Amended Complaint.

419. Paragraph 419 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 419 and, therefore, Favre denies same.

420. Paragraph 420 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 420 and, therefore, Favre denies same.

421. Paragraph 421 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 421 and, therefore, Favre denies same.

422. Paragraph 422 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 422 and, therefore, Favre denies same.

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423. Paragraph 423 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 423 and, therefore, Favre denies same.

424. Paragraph 424 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 424 and, therefore, Favre denies same.

425. Paragraph 425 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 425 and, therefore, Favre denies same.

426. Paragraph 426 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 426 and, therefore, Favre denies same.

427. Paragraph 427 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 427 and, therefore, Favre denies same.

428. Paragraph 428 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 428 and, therefore, Favre denies same.

429. Paragraph 429 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 429 and, therefore, Favre denies same.

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COUNT 9: BREACH OF CONTRACTS FOR MISUSE OF TANF FUND

430. Paragraph 430 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 430 and, therefore, Favre denies same.

431. Paragraph 431 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 431 and, therefore, Favre denies same.

432. Paragraph 432 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 432 and, therefore, Favre denies same.

433. Paragraph 433 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 433 and, therefore, Favre denies same.

434. Paragraph 434 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 434 and, therefore, Favre denies same.

435. Paragraph 435 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 435 and, therefore, Favre denies same.

436. Paragraph 436 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 436 and, therefore, Favre denies same.

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COUNT 10: BREACH OF CONTRACT BY FRC’S TRANSFEREES

437. Paragraph 437 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 437 and, therefore, Favre denies same.

438. Paragraph 438 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 438 and, therefore, Favre denies same.

439. Paragraph 439 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 439 and, therefore, Favre denies same.

440. Paragraph 440 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 440 and, therefore, Favre denies same.

441. Paragraph 441 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 441 and, therefore, Favre denies same.

442. Paragraph 442 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 442 and, therefore, Favre denies same.

443. Paragraph 443 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 443 and, therefore, Favre denies same.

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444. Paragraph 444 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 444 and, therefore, Favre denies same.

445. Paragraph 445 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 445 and, therefore, Favre denies same.

COUNT 11: PIERCING THE CORPORATE VEIL AND RECEIVERSHIP OVER

MCEC

446. Paragraph 446 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 446 and, therefore, Favre denies same.

447. Paragraph 447 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 447 and, therefore, Favre denies same.

448. Paragraph 448 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 448 and, therefore, Favre denies same.

449. Paragraph 449 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 449 and, therefore, Favre denies same.

450. Paragraph 450 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 450 and, therefore, Favre denies same.

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451. Paragraph 451 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 451 and, therefore, Favre denies same.

452. Paragraph 452 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 452 and, therefore, Favre denies same.

453. Paragraph 453 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 453 and, therefore, Favre denies same.

454. Paragraph 454 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 454 and, therefore, Favre denies same.

455. Paragraph 455 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 455 and, therefore, Favre denies same.

COUNT 12: PIERCING THE CORPORATE VEIL AND ALTER EGO LIABILITY

456. Paragraph 456 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 456 and, therefore, Favre denies same.

457. Paragraph 457 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 457 and, therefore, Favre denies same.

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458. Paragraph 458 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 458 and, therefore, Favre denies same.

459. Paragraph 459 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 459 and, therefore, Favre denies same.

460. Paragraph 460 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 460 and, therefore, Favre denies same.

461. Paragraph 461 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 461 and, therefore, Favre denies same.

COUNT 13: DECLARATORY JUDGMENT AND CLAIM TO QUIET TITLE

PROPERTY ACQUIRED BY DEFENDANTS WITH TANF FUNDS

462. Paragraph 462 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 462 and, therefore, Favre denies same.

463. Paragraph 463 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 463 and, therefore, Favre denies same.

464. Paragraph 464 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 464 and, therefore, Favre denies same.

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465. Paragraph 465 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 465 and, therefore, Favre denies same.

466. Paragraph 466 consists of legal conclusions to which no response is required. To

the extent a response is required, Favre lacks knowledge or information sufficient to form a belief

as to the truth of the allegations contained in Paragraph 466 and, therefore, Favre denies same.

RESPONSE TO PRAYER FOR RELIEF

Favre denies that Plaintiffs are entitled to any of the relief sought in the First Amended

Complaint, including, but not limited to, any relief sought in paragraphs (1) through (14) of the

Prayer for Relief in the First Amended Complaint.

WHEREFORE, PREMISES CONSIDERED, Favre respectfully requests that this

Court deny the relief requested by MDHS, dismiss MDHS’s First Amended Complaint in its

entirety with prejudice, award Favre all reasonable attorneys’ fees and costs, and afford Favre

any other relief as the Court finds just and proper.

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RESPECTFULLY SUBMITTED on this, the 4th day of May, 2023.

BRETT LORENZO FAVRE, Defendant

By: /s/ Eric. D. Herschmann

ERIC D. HERSCHMANN

Prepared by:

ERIC D. HERSCHMANN, Esq.

(PHV #995916)
210 Lavaca Street
Austin, Texas 78701
Telephone: (512) 551-3344
Facsimile: (512) 798-4376
Email: EDHNotice@gmail.com

KASOWITZ BENSON TORRES LLP

Daniel R. Benson (PHV# 995927)
DBenson@kasowitz.com
Jennifer M. McDougall (PHV# 995926)
JMcDougall@kasowitz.com
Daniel J. Koevary (PHV# 995925)
DKoevary@kasowitz.com
1633 Broadway
New York, NY 10019
Telephone: (212) 506-1700
Facsimile: (212) 506-1800

MICHAEL J. SHEMPER, PLLC

Michael J. Shemper (MSB# 100531)
Attorney at Law
140 Mayfair Road, Suite 1200
Hattiesburg, MS 39402
Telephone: (601) 545-7787
Facsimile: (601) 545-1711
Email: michael@shemperlaw.com

Counsel for Defendant Brett Lorenzo Favre

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Case: 25CI1:22-cv-00286-EFP Document #: 368 Filed: 05/04/2023 Page 64 of 64

CERTIFICATE OF SERVICE

I, Eric D. Herschmann, do hereby certify that I have on this 4th day of May, 2023, served

a true and correct copy of the foregoing pleading on all counsel of record herein via the MEC

filing system.

This, the 4th day of May, 2023.

/s/ Eric. D. Herschmann

ERIC D. HERSCHMANN