Jeff Ridgway File 2

Case: 57CI1:24-cv-00024 Document #: 29 Filed: 06/24/2024 Page 1 of 2

IN THE CIRCUIT COURT OF PIKE COUNTY

STATE OF MISSISSIPPI
_________________________________________________________________________________
RIDGWAY MANAGEMENT, INC. PLAINTIFF
V. CAUSE NO. 24-024-PCS
NEW SOUTH LOGGING, LLC, TAYLOR

FORESTRY, INC., AND JEFFERY ALAN
TAYLOR DEFENDANTS
MOTION TO SET ASIDE ENTRY OF DEFAULT
COMES NOW Taylor Forestry, Inc. and Jeffery Alan Taylor, by and through counsel, and
file this, their Motion to Set Aside Entry of Default in accordance with Mississippi Rules of Civil
Procedure 55(c) and 60(b), and in support thereof would state as follows, to-wit:
1. On March 18, 2024, the Plaintiff herein filed his Amended Complaint in this matter.
2. On March 19, 2024, a copy of the Amended Complaint was allegedly served on the
Defendants, Taylor Forestry, Inc. and Jeffery Alan Taylor.
3. That on April 22, 2024, the Plaintiff herein filed their Application to Clerk for Entry of
Default, wherein they state that the Defendants, Taylor Forestry, Inc. and Jeffery Alan Taylor
did not file an answer to the Amended Complaint that was filed.
4. That on or about May 30, 2024, the Clerk’s Docket Entry of Default was entered.
5. That the Defendants, Taylor Forestry, Inc. and Jeffery Alan Taylor now move the Court to set
aside the entry of default, as they fully intended to defend this action.
6. That default judgments are not favored by the Courts.
7. Furthermore, there would be no prejudice to the Plaintiff in setting the entry of default aside,
as no statute of limitations are implicated at this time; no witnesses or evidence is at risk of
being lost; and no tactical advantage is lost to the Plaintiff, other than forcing them to prove
their case on the merits.

8. The Defendants pray the Court will grant a continuance of the Motion for Default Judgment
to allow briefing of this Motion, and reset this Motion to be heard in advance of the Motion
for Default Judgment on July 10, 2024, or on any date favored by the Court.
WHEREFORE, PREMISES CONSIDERED, the Defendants, Taylor Forestry, Inc.
and Jeffery Alan Taylor, pray that the Court will continue this matter to July 10, 2024, or up-
on any date the Court requests, and upon a hearing on the merits, the Honorable Court will set
aside the default against the them, and allow the Defendants to have a day their Court with a
trial on the merits.
Respectfully Submitted,
Taylor Forestry, Inc. and Jeffery Alan Taylor
/s/ John J. McNeil

By: John J. McNeil, of counsel
John J. McNeil, MS Bar #101895
McNeil Law Office, PLLC
160 S. Cherry Street
Magnolia, Mississippi 39652
Tel: 601-783-5800
Fax: 601-783-5801
Email: [email protected]
CERTIFICATE OF SERVICE
I, John J. McNeil, do hereby certify that I have this day, by electronic filing, caused a true and
correct copy of the above and foregoing to be served on the following:
Hon. John Alan Buffington

The Law Office of B. Scott Buffington
P.O. Box 477
Prentiss, MS 39474
Hon. James W. Shelson

Phelps Dunbar LLP
4270 I-55 N.
Jackson, MS 39201
THIS the 21st day of June, 2024.
____________________
JOHN J. McNEIL
IN THE CIRCUIT COURT OF PIKE COUNTY, MISSISSIPPI
VS. CIVIL ACTION NO. 24-024-PCS
NEW SOUTH LOGGING, LLC, TAYLOR DEFENDANTS

TAYLOR
MOTION FOR DEFAULT JUDGMENT
Plaintiff, Ridgway Management, Inc., (“Ridgway”), files this Motion for Default Judgment
under MRCP 55 as follows:
Overview
A default judgment should be entered against Taylor Forestry, Inc. (“Taylor Forestry”) and
Jeffery Alan Taylor (“Jeff Taylor”), individually. Taylor Forestry and Jeff Taylor were properly
served with process, but they failed to answer or otherwise defend, and the Clerk has made an
entry of default against them. Further, Taylor Forestry and Jeff Taylor breached two contracts
with Ridgway, as well as their fiduciary duty to Ridgway as its agent under the timber contracts,
when Jeff Taylor absconded with more than $300,000 in proceeds from the timber contracts that
is the property of Ridgway.
Facts
1. Ridgway entered into a Timber Contract with New South Logging, LLC (“New
South”), Taylor Forestry, and Jeff Taylor effective February 23, 2023, regarding timber located in
Rankin County, Mississippi (“Rankin Timber Contract”). Ridgway granted New South the right
to cut timber and Taylor Forestry agreed to act as Ridgway’s agent for the limited purposes stated
in the Rankin Timber Contract. A copy of the Rankin Timber Contract is attached as Exhibit 1.
PD.45582005.1
2. Ridgway entered into a Timber Contract with New South, Taylor Forestry, and Jeff
Taylor effective August 14, 2023, regarding timber located in Simpson County, Mississippi
(“Simpson Timber Contract”). Ridgway granted New South the right to cut timber and Taylor
Forestry agreed to act as Ridgway’s agent for the limited purposes stated in the Simpson Timber
Contract. A copy of the Simpson Timber Contract is attached as Exhibit 2. The Rankin Timber
Contract and the Simpson Timber Contract are collectively referred to in this Motion as the
“Timber Contracts.”
3. New South paid Taylor Forestry and Jeff Taylor approximately $329,835.48 under
the Timber Contracts (see the checks attached as Exhibit 3).
4. In turn, Taylor Forestry and Jeff Taylor sent two checks to Ridgway totaling
$306,747.00, but both checks were returned for insufficient funds (see Exhibit 4).
Procedural History
5. Taylor Forestry and Jeff Taylor were served with process on March 19, 2024 (Dkt.
20-1, ¶¶ 2-3). More than 30 days have passed since Taylor Forestry and Jeff Taylor were served
with process, but they have failed to answer or otherwise defend.
6. On April 22, 2024, Ridgway filed an Application to Clerk for Entry of Default (Dkt.
20).
7. On May 30, 2024, the Clerk entered default against Taylor Forestry and Jeff Taylor
(Dkt. 21).
Grounds for Default Judgment
8. The failure of a party to answer a complaint opens the party to a default judgment.
Brown v. Brown, 872 So.2d 787, 789 (Miss. Ct. App. 2004). Here, Taylor Forestry and Jeff Taylor
2
PD.45582005.1
were served with process, but they have failed to answer or otherwise defend, and the Clerk has
made an entry of default against them (Dkt. 21).
9. Taylor Forestry and Jeff Taylor breached the Timber Contracts and breached their
fiduciary duty to Ridgway. Accordingly, this Court should now enter a default judgment against
Taylor Forestry and Jeff Taylor, jointly and severally, for $306,747.00 in compensatory damages,
as well as attorney’s fees and punitive damages in an amount to be determined at the hearing on
Ridgway’s Motion.
10. A breach of contract has two elements: (i) the existence of a valid and binding
contract, and (ii) a showing that defendant has breached the contract. Business Commc’ns, Inc. v.
Banks, 90 S.3d 1221, 1224 (Miss, 2012). The Timber Contracts are valid and binding contracts.
Taylor Forestry and Jeff Taylor were required to pay Ridgway $306,747.00 under the Timber
Contracts, but they did not pay anything to Ridgway. Therefore, Taylor Forestry and Jeff Taylor
breached the Timber Contracts.
11. The relationship between principal and agent is a fiduciary one. Van Zandt v. Van
Zandt, 86 So.2d 466, 469 (Miss, 1966). An agent owes his principal the utmost loyalty and good
faith. Id. at 469-70. “Any breach of this good faith whereby the principal suffers any
disadvantages and the agent reaps any benefit is a fraud for which the agent will be held
accountable, either in damages or by judgment precluding the agent from taking or retaining the
benefits so obtained.” Id. at 470. Taylor Forestry and Jeff Taylor owe a fiduciary duty to Ridgway
because they are Ridgway’s agent under the Timber Contracts. Taylor Forestry and Jeff Taylor
breached their fiduciary duty to Ridgway by failing to pay any of the proceeds from the Timber
Contracts to Ridgway. Taylor Forestry and Jeff Taylor’s breach of fiduciary duty, which also
constitutes fraud, entitles Ridgway to compensatory and punitive damages, as well as attorney’s
3
PD.45582005.1
fees. A breach of fiduciary duty is an extreme or a special additional circumstance where punitive
damages and attorney’s fees can be allowed. Ross-King-Walker, Inc. v. Henson, 672 So.2d 1188,
1192 (Miss. 1996).
12. Jeff Taylor is individually liable for breach of contract and breach of fiduciary duty
for two reasons. First, New South paid at least $265,771.23 in proceeds from the Timber Contracts
to Jeff Taylor, individually, and he fraudulently kept the proceeds for himself. Second the
corporate veil of Taylor Forestry should be pierced. To pierce the veil, the complaining party must
prove some frustration of contractual expectations, flagrant disregard of corporate formalities, and
fraud or misfeasance by a corporate shareholder. Gray v. Edgewater Landing, Inc., 541 So.2d
1044, 1047 (Miss. 1989). Here, Jeff Taylor frustrated the contractual expectations of the parties
to the Timber Contracts by not paying the proceeds from those Contracts to Ridgway. Jeff Taylor
flagrantly disregarded the corporate formalities of Taylor Forestry by treating the entity’s funds as
his own. Jeff Taylor also committed fraud or misfeasance while a shareholder of Taylor Forestry
by not paying the proceeds from the Timber Contracts to Ridgway.
Relief Requested
Ridgway’s Motion should be granted, and the Court should enter a default judgment
against Taylor Forestry and Jeff Taylor, jointly and severally, for $306,747.00 in compensatory
damages, plus attorney’s fees and punitive damages in an amount to be determined at the hearing
on Ridgway’s Motion.
Dated: May 31, 2024.
4
PD.45582005.1
Respectfully submitted,
RIDGWAY MANAGEMENT, INC.
By Its Attorneys:
PHELPS DUNBAR, LLP
BY: /s/ James W. Shelson

James W. Shelson (MSB 9693)
Nash E. Gilmore (MSB 105554)
PHELPS DUNBAR, LLP
4270 I-55 North
Jackson, MS 39211-6391
Telephone: (601) 352-2300
Facsimile: (601)-360-9777
[email protected]
[email protected]
I, James W. Shelson, certify that a copy of this document has been filed with the Court’s
MEC online document filing system, which sent notice of the filing to all counsel of record.
This, the 31st day of May, 2024.
/s/ James W. Shelson

JAMES W. SHELSON
5
PD.45582005.1

TAYLOR
VERIFIED MOTION FOR TEMPORARY RESTRAINING ORDER
Plaintiff, Ridgway Management, Inc., ("Ridgway"), files this Motion for Temporary
Restraining Order under MRCP 65(b) as follows:
Facts
1. Ridgway entered into a Timber Contract with New South Logging, LLC ("New
South"), Taylor Forestry, Inc. ("Taylor Forestry"), and Jeffrey Alan Taylor ("Jeff Taylor")
effective February 23, 2023, regarding timber located in Rankin County, Mississippi ("Rankin
Timber Contract"). Ridgway granted New South the right to cut timber and Taylor Forestry agreed
to act as Ridgway's agent for the limited purposes stated in the Rankin Timber Contract. A copy
of the Rankin Timber Contract is attached as Exhibit 1.
2. Ridgway entered into a Timber Contract with New South, Taylor Forestry, and Jeff
Taylor effective August 14, 2023, regarding timber located in Simpson County, Mississippi
("Simpson Timber Contract"). Ridgway granted New South the right to cut timber and Taylor
Forestry agreed to act as Ridgway's agent for the limited purposes stated in the Simpson Timber
Contract. A copy of the Simpson Timber Contract is attached as Exhibit 2.
3. Paragraph 2 of Rankin Timber Contract and the Simpson Timber Contract requires
New South to make payment to Ridgway, supported by weekly settlement records, "for all Timber
cut and removed the preceding week."
PD.44778894.1
4. Instead of sending payment directly to Ridgway as required by the Rankin Timber
Contract and the Simpson Timber Contract, New South paid Taylor Forestry and Jeff Taylor
approximately $300,000.
5. No proceeds from the timber that New South cut under the Rankin Timber Contract
and the Simpson Timber Contract have been paid to Ridgway.
6. Jeff Taylor is the owner and manager of Taylor Forestry. To the extent, if any, that
Jeff Taylor, individually, has received any proceeds for timber that was cut under the Rankin
Timber Contract and the Simpson Timber Contract, the corporate veil of Taylor Forestry should
be pierced because Taylor Forestry and Jeff Taylor are frustrating the contractual expectations of
the parties to the Rankin Timber Contract and the Simpson Timber Contract, Taylor Forestry has
flagrantly disregarded its corporate formalities, and/or Taylor Forestry and Jeff Taylor have
committed fraud or malfeasance by retaining money that rightfully belongs to Ridgway.
7. The decision to grant or deny injunctive relief is within the sound discretion of the
trial court. Lauderdale v. DeSoto County ex rel. Bd. of Supervisors, 196 So.3d 1091, 1099 (Miss.
Ct. App. 2016). The party seeking an injunction must show an entitlement to injunctive relief by
a preponderance of the evidence. Id. A temporary restraining order (TRO) "may be issued where
`immediate and irreparable injury, loss, or damage will result to the applicant' before such time as
a hearing on the matter can be held.' Id. (citation omitted).
8. Ridgway is entitled to a TRO because New South paid approximately $300,000 to
Taylor Forestry and Jeff Taylor that rightfully belongs to Ridgway, Taylor Forestry and Jeff Taylor
refuse to pay those funds to Ridgway, and Ridgway will suffer an immediate and irreparable injury
if Taylor Forestry and Jeff Taylor expend those funds.
2
PD.44778894.1
9. This Motion is verified by William B. Ridgway, Jr., the Secretary-Treasurer of
Ridgway Management, Inc.
Relief Requested
Ridgway's Motion should be granted and the Court should issue a TRO that (i) requires
Taylor Forestry and Jeff Taylor to identify the location(s) of the funds that New South paid to
Taylor Forestry and/or Jeff Taylor under the Rankin Timber Contract and the Simpson Timber
Contract, and (ii) enjoins Taylor Forestry and Jeff Taylor from expending any such funds until
further order of the Court.
Dated: March 19, 2024.
By Its Attorneys:
PHELPS DUNBAR, LLP
BY: /s/ James W. Shelson

James W. Shelson (MSB 9693)
Nash E. Gilmore (MSB 105554)
PHELPS DUNBAR, LLP
4270 I-55 North
Telephone: (601) 352-2300
Facsimile: (601)-360-9777
[email protected]
[email protected]
3
PD.44778894.1
VERIFICATION
STATE OF MISSISSIPPI
COUNTY OF HINDS
Personally appeared before me, the undersigned authority in and for the jurisdiction
aforesaid, the within named William B. Ridgway, Jr. who, on behalf of Ridgway Management,
Inc., verifies that the above responses are true and correct to the best of his knowledge, information,
and belief.
William B. Ridgway, Jr.

Ridgway Management, Inc.
4-L
SWORN TO AND SUBSCRIBED before me, this the S day of March, 2024.
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My Commission Expires:
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JANET S. TR1MM
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PD.44776894.1
I certify that on March 19, 2024, that I caused a copy of this Motion to be emailed to Larry
Buffington, counsel for New South Logging, LLC.
/s/ James W. Shelson

JAMES W. SHELSON
5
PD.44778894.1

TAYLOR
FIRST AMENDED COMPLAINT
Plaintiff, Ridgway Management, Inc., ("Ridgway"), files this First Amended Complaint
against New South Logging, LLC ("New South"), Taylor Forestry, Inc. ("Taylor Forestry"), and
Jeffery Alan Taylor as follows:
PARTIES
1. Ridgway is a Mississippi corporation qualified to do business in, and currently
doing business in, the State of Mississippi, with its principal place of business located in Hinds
County, Mississippi.
2. New South Logging, LLC is a Mississippi limited liability company and can be
served with process upon its Registered Agent, Lorrie Griffin, 204 Magnolia Street, Ellisville,
Mississippi, or as otherwise permitted by the Mississippi Rules of Civil Procedure.
3. Taylor Forestry, Inc. is a Mississippi corporation and can be served with process
upon its owner and manager, Jeffery Alan Taylor, 1189 Kenna Road, Summit, Mississippi, or
otherwise as otherwise permitted by the Mississippi Rules of Civil Procedure.
4. Jeffery Alan Taylor is an adult resident citizen of Pike County, Mississippi and can
be served with process as permitted by the Mississippi Rules of Civil Procedure.
PD.44784376. I
JURISDICTION AND VENUE
5. Venue is proper in Pike County, Mississippi because Taylor Forestry has its
principal place of business in Pike County, and a substantial alleged act or omission occurred or a
substantial event that caused the injury occurred in Pike County.
6. This Court has general and specific personal jurisdiction over Defendants because
New South is a Mississippi LLC, Taylor Forestry is a Mississippi corporation, and Jeff Taylor is
a Mississippi resident.
7. This Court has subject matter jurisdiction over the claims asserted in this lawsuit.
FACTS
8. Ridgway entered into a Timber Contract with New South and Taylor Forestry
effective February 23, 2023, regarding timber located in Rankin County, Mississippi ("Rankin
to act as Ridgway's agent for the limited purposes stated in the Rankin Timber Contract. A copy
of the Rankin Timber Contract is attached as Exhibit 1.
9. Ridgway entered into a Timber Contract with New South and Taylor Forestry
effective August 14, 2023, regarding timber located in Simpson County, Mississippi ("Simpson
to act as Ridgway's agent for the limited purposes stated in the Simpson Timber Contract. A copy
of the Simpson Timber Contract is attached as Exhibit 2.
10. Paragraph 2 of Rankin Timber Contract and the Simpson Timber Contract requires
New South to make payment to Ridgway, supported by weekly settlement records, "for all Timber
cut and removed the preceding week."
2
PD.44784376.1
11. Instead of sending payment directly to Ridgway as required by the Rankin Timber
Contract and the Simpson Timber Contract, New South claims it sent payment to Taylor Forestry
and Jeff Taylor.
12. No proceeds from the timber that New South cut under the Rankin Timber Contract
and the Simpson Timber Contract have been paid to Ridgway.
13. Ridgway is owed more than $300,000 under the Rankin Timber Contract and the
Simpson Timber Contract.
14. Jeff Taylor is the owner and manager of Taylor Forestry. To the extent, if any, that
Jeff Taylor, individually, has received any proceeds for timber that was cut under the Rankin
Timber Contract and the Simpson Timber Contract, the corporate veil of Taylor Forestry should
be pierced because Taylor Forestry and Jeff Taylor are frustrating the contractual expectations of
the parties to the Rankin Timber Contract and the Simpson Timber Contract, Taylor Forestry has
flagrantly disregarded its corporate formalities, and/or Taylor Forestry and Jeff Taylor have
committed fraud or malfeasance by retaining money that rightfully belongs to Ridgway.
CAUSES OF ACTION
COUNT ONE
BREACH OF CONTRACT - NEW SOUTH
15. Ridgway incorporates and reasserts Paragraphs 1 through 14.
16. New South breached the Rankin Timber Contract and the Simpson Timber Contract
by failing to pay the proceeds from the timber it cut under the Rankin Timber Contract and the
Simpson Timber Contract directly to Ridgway and by otherwise not paying the full amount it owes
to Ridgway under the Rankin Timber Contract and the Simpson Timber Contract.
3
PD.44784376.1
17. As a direct, foreseeable, and proximate result of New South's acts or omissions,
Ridgway has been damaged. Ridgway has incurred actual, incidental, consequential, and other
damages as a result of New South's acts or omissions.
COUNT TWO
BREACH OF CONTRACT - TAYLOR FORESTRY AND JEFF TAYLOR
19. To the extent that New South paid any proceeds for cutting timber under the Rankin
Timber Contract or the Simpson Timber Contract to Taylor Forestry and/or Jeff Taylor instead of
paying Ridgway directly, Taylor Forestry and/or Jeff Taylor have breached those Contracts by
retaining those proceeds and not paying them to Ridgway.
20. As a direct, foreseeable, and proximate result of Taylor Forestry and/or Jeff
Taylor's acts or omissions, Ridgway has been damaged. Taylor Forestry and/or Jeff Taylor has
incurred actual, incidental, consequential, and other damages as a result of Taylor Forestry and/or
Jeff Taylor's acts or omissions.
COUNT THREE
BREACH OF FIDCUTARY DUTY — TAYLOR FORESTRY AND JEFF TAYLOR
22. Taylor Forestry and Jeff Taylor owe a fiduciary duty to Ridgway because they are
Ridgway's agent for the limited purposes stated in the Rankin Timber Contract and the Simpson
Timber Contract.
23. To the extent that New South paid any proceeds for cutting timber under the Rankin
Timber Contract or the Simpson Timber Contract to Taylor Forestry and/or Jeff Taylor instead of
paying Ridgway directly, Taylor Forestry and/or Jeff Taylor have breached their fiduciary duty to
Ridgway by retaining those proceeds and not paying them to Ridgway.
4
PD.44784376.1
Taylor's acts or omissions, Ridgway has been damaged. Ridgway has incurred actual, incidental,
consequential, and other damages as a result of Taylor Forestry and/or Jeff Taylor's acts or
omissions. Taylor Forestry and/or Jeff Taylor's breach of fiduciary duty further entitles Ridgway
to punitive damages and attorney's fees.
COUNT FOUR
INJUNCTIVE RELIEF — TAYLOR FORESTRY AND JEFF TAYLOR
26. Taylor Forestry and Jeff Taylor should be temporarily, preliminarily, and
permanently enjoined from expending any proceeds New South paid to Taylor Forestry and/or Jeff
Taylor for timber cut under the Rankin Timber Contract or the Simpson Timber Contract.
27. Injunctive relief is warranted because Ridgway is substantially likely to prevail on
the merits, an injunction is necessary to prevent irreparable harm (Taylor Forestry and/or Jeff
Taylor expending timber proceeds that rightfully belong to Ridgway), and the threatened injury to
Ridgway (loss of funds that rightfully belong to it) outweighs any alleged harm to Taylor Forestry
and/or Jeff Taylor (improperly retaining Ridgway's property).
COUNT FIVE
UNJUST ENRICHMENT - TAYLOR FORESTRY AND JEFF TAYLOR
29. Alternatively, to the extent that New South paid any proceeds for cutting timber
under the Rankin Timber Contract or the Simpson Timber Contract to Taylor Forestry and/or Jeff
Taylor, an implied-in-law promise exists for Taylor Forestry and/or Jeff Taylor to pay those
proceeds to Ridgway because any such proceeds are in equity and good conscience Ridgway's
property and Taylor Forestry and/or Jeff Taylor are improperly retaining the proceeds.
5
PD.44784376.1
Taylor's acts or omissions, Ridgway has been damaged. Ridgway has incurred actual, incidental,
consequential, and other damages as a result of Taylor Forestry and/or Jeff Taylor's acts or
omissions. Further, the Court should impose a constructive trust on any proceeds New South paid
to Taylor Forestry and/or Jeff Taylor for timber cut under the Rankin Timber Contract or the
Simpson Timber Contract.
JURY DEMAND
31. Ridgway demands a trial by jury.
RELIEF REQUESTED
32. Ridgway requests the following relief:
a. Compensatory, actual, incidental, and consequential damages for all sums

Ridgway is owed under the Rankin Timber Contract and the Simpson
Timber Contract;
b. Punitive damages and attorney's fees against Taylor Forestry and Jeff
Taylor for their breach of fiduciary duty;
c. Pre- and post-judgment interest at the legal rate of 8%;
d. Costs incurred in this action; and
e. Such other and further relief to which Ridgway may be entitled in the
premises.
Dated: March 18, 2024.
6
PD.44784376.1
By Its Attorneys:
PHELPS DUNBAR, LLP
BY:
. Shelson (MSB 9693)
Gilmore (MSB 105554)
P S DUNBAR, LLP
4270 1-55 North
Telephone: (601) 352-2300
Facsimile: (601)-360-9777
[email protected]
[email protected]
7
PDA4784376.1

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Case: 57CI1:24-cv-00024 Document #: 29 Filed: 06/24/2024 Page 1 of 2

Case: 57CI1:24-cv-00024 Document #: 29 Filed: 06/24/2024 Page 2 of 2

IN THE CIRCUIT COURT OF PIKE COUNTY

RIDGWAY MANAGEMENT, INC. PLAINTIFF

V. CAUSE NO. 24-024-PCS

NEW SOUTH LOGGING, LLC, TAYLOR

MOTION TO SET ASIDE ENTRY OF DEFAULT

Defendants, Taylor Forestry, Inc. and Jeffery Alan Taylor.

6. That default judgments are not favored by the Courts.

as no statute of limitations are implicated at this time; no witnesses or evidence is at risk of

their case on the merits.

WHEREFORE, PREMISES CONSIDERED, the Defendants, Taylor Forestry, Inc.

trial on the merits.

Taylor Forestry, Inc. and Jeffery Alan Taylor

/s/ John J. McNeil

correct copy of the above and foregoing to be served on the following:

Hon. John Alan Buffington

Hon. James W. Shelson

THIS the 21st day of June, 2024.

IN THE CIRCUIT COURT OF PIKE COUNTY, MISSISSIPPI

RIDGWAY MANAGEMENT, INC. PLAINTIFF

VS. CIVIL ACTION NO. 24-024-PCS

NEW SOUTH LOGGING, LLC, TAYLOR DEFENDANTS

MOTION FOR DEFAULT JUDGMENT

under MRCP 55 as follows:

is the property of Ridgway.

the Timber Contracts (see the checks attached as Exhibit 3).

with process, but they have failed to answer or otherwise defend.

Grounds for Default Judgment

made an entry of default against them (Dkt. 21).

breached the Timber Contracts.

1192 (Miss. 1996).

by not paying the proceeds from the Timber Contracts to Ridgway.

Dated: May 31, 2024.

RIDGWAY MANAGEMENT, INC.

BY: /s/ James W. Shelson

This, the 31st day of May, 2024.

/s/ James W. Shelson

IN THE CIRCUIT COURT OF PIKE COUNTY, MISSISSIPPI

RIDGWAY MANAGEMENT, INC. PLAINTIFF

VS. CIVIL ACTION NO. 24-024-PCS

NEW SOUTH LOGGING, LLC, TAYLOR DEFENDANTS

VERIFIED MOTION FOR TEMPORARY RESTRAINING ORDER

Restraining Order under MRCP 65(b) as follows:

of the Rankin Timber Contract is attached as Exhibit 1.

Contract. A copy of the Simpson Timber Contract is attached as Exhibit 2.

cut and removed the preceding week."

4. Instead of sending payment directly to Ridgway as required by the Rankin Timber

and the Simpson Timber Contract have been paid to Ridgway.

committed fraud or malfeasance by retaining money that rightfully belongs to Ridgway.

a hearing on the matter can be held.' Id. (citation omitted).

8. Ridgway is entitled to a TRO because New South paid approximately $300,000 to

if Taylor Forestry and Jeff Taylor expend those funds.

9. This Motion is verified by William B. Ridgway, Jr., the Secretary-Treasurer of

Ridgway Management, Inc.

further order of the Court.

Dated: March 19, 2024.

RIDGWAY MANAGEMENT, INC.

BY: /s/ James W. Shelson

William B. Ridgway, Jr.

Buffington, counsel for New South Logging, LLC.

/s/ James W. Shelson

IN THE CIRCUIT COURT OF PIKE COUNTY, MISSISSIPPI

RIDGWAY MANAGEMENT, INC. PLAINTIFF