INDICTMENT fraud 97-19-39 - 1 Uttforg 9 7 - 2 1 - 5 9 - 2 Emb 97-11-25-5

CIRCUIT COURT NO

THE STATE OF MISSISSIPPI CIRCUIT COURT [a jud dist] DISTRICT, HINDS COUNTY [a term] Term, A.D., [a year] [a jud dist] Judicial District of Hinds County. The Grand Jurors for the State of Mississippi, taken from the body of good and lawful persons of Hinds County, in the State of Mississippi, elected, impaneled, sworn and charged to inquire in and for said District, County and State aforesaid, in the name and by the authority of the State of Mississippi, upon their oaths present: That in said District, County, and State Count 1 on or about the T" day of September, 2001 --^^^ZZIT did wilfully, unlawfully and feloniously obtain from De Mon B. McClinton, the guardianship of De Mon B. McClinton, Thomas McClinton, and/or the Hinds County, Mississippi Chancery Court, $398,000.00 good and lawful money of the United States of America, by means of certain false and fraudulent representations, to-wif: by representing to De Mon B. McClinton, the guardianship of De Mon B. McCUnton, Thomas McClinton, and/or the Hinds County, Mississippi Chancery Court that he had performed legal services on the behalf of the guardianship of De Mon B. McClinton, when he then and there well knew he had not performed said legal services and at the time of making said representation the said Michael J. Brown knew it/them to be false and intended that De Mon B. McClinton, the guardianship of De Mon B. McClinton, Thomas McClinton, and/or the Hinds County, Mississippi Chancery Court rely on said representations; in reUance on said false representations, the said De Mon B. McClinton, the guardianship of De Mon B. McCUnton, Thomas McClinton, and/or the Hinds County, Mississippi Chancery Court parted with the aforesaid money, all of which said acts were done or caused to be done by the said Michael J. Brown, with his present intent to cheat and defraud De Mon B. McClinton, and/or the guardianship of De Mon B. McClinton, and/or the Hinds County, Mississippi Chancery Court, and/or other to the Grand Jury unknown, in violation of Section 97-19-39, Mississippi Code, 1972, annotated, as amended. Count 2 On or about the December 23, 2002 did wilfully, unlawfully, feloniously, fraudulently and falsely then and there utter and publish as MICHAEL J. BROWN

page 2 Brown true to one Trustmark National Bank, a banking corporation, a certain forged, altered or counterfeit endorsement on a writing on paper, an instrument in writing commonly known as and called and purporting to be a certain written and printed bank check and order for the payment of money, of the tenor, purport, effect and in words and figures as follows: SEE RIDER #1 ATTACHED HERETO, in the amount of $205,020,81, he, the said MICHAEL J. BROWN then and there well knowing the same to be false, forged, altered or counterfeit, with the willful and felonious intent, then and there, feloniously, willfully, unlawfully and fraudulently to injure and defraud the said Trustmark National Bank, a banking corporation, Thomas McCUnton, the guardianship of De Mon B. McClinton, Union Planters Bank, a banking corporation, and/or some other person or persons to the Grand Jury unknown, in violation of Section 97-21-59 of the Mississippi Code of 1972 Annotated, as amended and

Count 3 On or about December 23, 2002 did wilfully, unlawfully, feloniously, fraudulently and falsely then and there utter and pubUsh as true to one Trustmark National Bank, a banking corporation, a certain forged, altered or counterfeit endorsement on a writing on paper, an instrument in writing commonly known as and caUed and purporting to be a certain written and printed bank check and order for the payment of money, of the tenor, purport, effect and in words and figures as follows: SEE RIDER #2 ATTACHED HERETO, in the amount of $32,725.00, he, the said MICHAEL J. BROWN then and there well knowing the same to be false, forged, altered or counterfeit, with the wUlful and felonious intent, then and there, feloniously, willfully, unlawfully and fraudulently to injure and defraud the said Trustmark National Bank, a banking corporation, Thomas McClinton, the guardianship of De Mon B. McCUnton, Union Planters Bank, a banking corporation, and/or some other person or persons to the Grand Jury unknown, in violation of Section 97-21-59 of the Mississippi Code of 1972 Annotated, as amended and Count 4 On or about February 21, 2001 Michael J. Brown, being the attorney for the guardianship of De Mon B. McClinton, did wilfully, unlawfuUy and feloniously convert to his own use money in the amount of $ 51, 070.45, which money came into his hands or possession by virtue of his office or employment as the attorney for the guardianship of DeMon B. McCUnton, and he, the said Michael J. Brown, did not, when lawfully required to turn over such money, immediately do so according to his legal obligation, In violation of Section 97-11-25, Mississippi Code, as amended,

page 3 Brown Count 5 On or about February 21, 2001 Michael J. Brown, being the attorney for the guardianship of De Mon B. McClinton, did wilfully, unlawfully and feloniously convert to his own use money in the amount of $42,186.40, which money came into his hands or possession by virtue of his office or employment as the attorney for the guardianship of DeMon B. McClinton, and he, the said Michael J. Brown, did not, when lawfully required to turn over such money, immediately do so according to his legal obligation, In violation of Section 97-11-25, Mississippi Code, as amended, Count 6 On or about February 21, 2001 Michael J. Brown, being the attorney for the guardianship of De Mon B. McClinton, did wilfully, unlawfully and feloniously convert to his own use money in the amount of $50,582.20, which money came into his hands or possession by virtue of his office or employment as the attorney for the guardianship of DeMon B. McClinton, and he, the said Michael J. Brown, did not, when lawfully required to turn over such money, immediately do so according to his legal obligation. In violation of Section 97-11-25, Mississippi Code, as amended, Count 7 On or about February 22, 2001 Michael J. Brown, being the attorney for the guardianship of De Mon B. McClinton, did wilfully, unlawfully and feloniously convert to his own use money in the amount of $26,500.00, which money came into his hands or possession by virtue of his office or employment as the attorney for the guardianship of DeMon B, McClinton, and he, the said Michael J. Brown, did not, when lawfully required to turn over such money, immediately do so according to his legal obligation. In violation of Section 97-11-25, Mississippi Code, as amended, Count 8 On or about March 8, 2001 Michael J. Brown, being the attorney for the guardianship of De Mon B. McClinton, did wilfully, unlawfully and feloniously convert to his own use money in the amount of $ 38,815.90, which money came into his hands or possession by virtue of his office or employment as the attorney for the guardianship of DeMon B. McClinton, and he, the said Michael J. Brown, did

Page 4 Brown not, when lawfully required to turn over such money, immediately do so according to his legal obligation. In violation of Section 97-11-25, Mississippi Code, as amended.

contrary to the form of the statute in such cases made and provided, and against the peace and dignity of the State of Mississippi.

Grand Jury Foreman

A^t lilstfict Attornev