COMPLAINT

1.Central Arkansas House Buyers, LLC (“CAHB”) is an Arkansas limited liability company with a principal place of business in Pulaski County, Arkansas.

2.CAHB Operating, LLC (“CAHB Operating”) is an Arkansas limited liability company with a principal place of business in Pulaski County, Arkansas. CAHB and CAHB Operating shall collectively be referred to as “the Companies”.

3.Plaintiff, Matthew Lamb (“Lamb”), is an individual and resident of Pulaski County, Arkansas. At all times relevant to the misconduct alleged herein, Lamb and his Former Business Partner were equal 50% members of CAHB and CAHB Operating. By order of the Pulaski County Circuit Court dated April 12, 2024, the Former Business Partner was judicially expelled from CAHB for conversion and was separately expelled from CAHB Operating on the same date. Lamb is now the sole member and manager of both entities (hereinafter, collectively, the “Companies”).

4.Separate Defendant Little, Shaneyfelt, Marshall & Co., P.A. (“LSM”) operates as a professional association organized under the laws of the State of Arkansas, with its principal place of business at 1501 N. University Ave., Suite 600, Little Rock, Arkansas 72207. LSM can be served via its registered agent, Jeff Shaneyfelt, at 1501 N. University Ave., Suite 600, Little Rock, Arkansas.

5.Separate Defendant Jeff Shaneyfelt (“Shaneyfelt”) is an individual and resident of Pulaski County, Arkansas. Upon information and belief, Shaneyfelt can be served at 20125 Colonel Glenn, Little Rock, Arkansas. Upon information and belief, Jeff Shaneyfelt holds a Certified Public Accountant license issued by the State of Arkansas, PTIN P01001009.

6.Separate Defendant Aaron Kyle Shaneyfelt is a licensed CPA employed by or acting through LSM, directly participated in the CAHB engagement, and may be served at LSM’s principal place of business.

7.Separate Defendant Krissie Gayle Williams is a licensed CPA employed by or acting through LSM, directly participated in the CAHB engagement, and may be served at LSM’s principal place of business.

8.Separate Defendant Shanna Miller is a licensed CPA employed by or acting through LSM, directly participated in the CAHB engagement, and may be served at LSM’s principal place of business.

9.This Court has subject-matter jurisdiction pursuant to Ark. Code Ann. § 16-13-201. Venue is proper in Pulaski County pursuant to Ark. Code Ann. § 16-60-101.

10.CAHB, CAHB Operating and Lamb retained Shaneyfelt and LSM because Lamb (and the Companies) could not verify the books himself. That is why businesses hire accountants. They hire them to maintain reliable books, prepare returns on a reasonable basis, disclose material conflicts, and tell clients when records cannot be trusted.

11.Shaneyfelt did the opposite. On July 30, 2024, under oath, he admitted that the books were “unauditable,” that he did not comply with GAAP, and that no jury should consider the financial data he prepared in awarding damages in this case. His full sworn admissions are set forth below.

12.This case is not about an accountant (and accounting firm) who innocently failed to detect someone else’s theft. It is about an accountant who accepted information from one side of a 50/50 dispute without verification, concealed conflicts of interest, maintained books he knew could not be trusted, and gave the misconduct the appearance of legitimacy by turning it into tax returns, K-1s, journal entries, and accounting work product.

13.Much of the misconduct alleged herein occurred after Lamb filed suit against his Former Business Partner in July 2022, and some of it occurred after a court-appointed receiver was put in place in January 2023. Defendants continued to make unsupported entries, file returns based on unsupported figures, and withhold material information from Lamb throughout active litigation and receivership.

14.The Defendants did not merely fail to stop damage. Defendants concealed, prolonged, and magnified that damage. They caused direct tax-related injury, levy-related harm, lender denials, forensic reconstruction costs, and fees paid for defective work. They also caused or prolonged a share of broader business loss, including lost profits and impaired borrowing capacity, by corrupting the records on which Lamb, lenders, and third parties had to rely.

15.Had Defendants disclosed that the books were unreliable, commingled, or unsupported, Lamb would have been in a position to investigate, challenge transfers, and make different business and litigation decisions earlier.

16.Plaintiffs seek recovery for those direct harms, for the share of broader business losses a jury attributes to Defendants’ misconduct, for disgorgement and other fiduciary remedies, and for punitive damages based on Defendants’ own consciously indifferent conduct.

17.Defendants served as accountants and tax preparers for Lamb individually from 2019 through 2022. The engagement originated no later than March 2019, when Shaneyfelt and Lamb exchanged tax information and Shaneyfelt began work on Lamb’s returns. A subsequent December 4, 2020 communication in which Lamb confirmed Shaneyfelt’s engagement for CAHB Operating and Mid South pertained to that newly formed entity, not to the original CAHB or personal engagement, which had been ongoing since early 2019.

18.Defendants served as accountants and bookkeepers for CAHB, preparing federal partnership returns from 2019 through 2023 and maintaining the books and general ledger beginning in 2019.

19.Defendants served as accountants and bookkeepers for CAHB Operating from its formation in December 2020 through 2023.

20.On November 21 and 22, 2019, LSM transmitted a written engagement agreement to CAHB limited to 20 hours of QuickBooks maintenance work. Lamb signed that agreement as CAHB’s managing member. No further written engagement agreement was executed for the far broader scope of services Defendants ultimately performed — including bookkeeping, general-ledger maintenance, entity structuring, and federal tax-return preparation.

21.In July 2022, Lamb filed suit against his equal 50% co-member in the Companies (“Lamb’s Former Business Partner”). On August 22, 2022, after that litigation had already begun, Shaneyfelt confirmed in writing, with Lamb’s attorney copied, that LSM was recording accounting transactions in general-ledger format for the Companies.

22.Shaneyfelt later testified that LSM did not customarily use engagement letters and that such documentation came only later. The contemporaneous engagement documents undercut that testimony.

23.Shaneyfelt had a fifteen-to-twenty-year personal relationship with Lamb’s Former Business Partner that extended well beyond professional acquaintance. Lamb’s Former Business Partner served as a minister — specifically, as full-time worship leader and small groups minister — at Crosswalk Family of God Church (also known as Crosswalk Church of Christ) in Little Rock, Arkansas, where Shaneyfelt attended as a congregant — and both the Former Business Partner and his Spouse performed as vocalists at the wedding of Shaneyfelt’s son, Aaron Kyle Shaneyfelt, who is also named as a defendant in this action.

24.Lamb’s Former Business Partner initiated the engagement and introduced Shaneyfelt to Lamb. The prior relationship was never disclosed to Lamb by either Shaneyfelt or Lamb’s Former Business Partner.

25.In December 2020, with Shaneyfelt advising on the structure, Lamb and Lamb’s Former Business Partner formed CAHB Operating as a separate entity. Shaneyfelt later testified that he designed the structure after researching how to separate the operating side from the holding side.

26.By 2022, Shaneyfelt was simultaneously representing multiple affiliated entities owned by Lamb’s Former Business Partner and persons whose interests were adverse to Lamb and the Companies. Shaneyfelt did not disclose those conflicts to Lamb and did not withdraw. He maintained the CAHB accounts for approximately thirteen months after Lamb filed suit against his Former Business Partner.

27.Instead, Shaneyfelt later admitted under oath that when the conflict ripened, he chose to work for Lamb’s Former Business Partner rather than Lamb and that, in hindsight, he probably should have withdrawn.

28.LSM served as the accountant and bookkeeper for the Companies. However, rather than gathering financial information directly from Lamb or from verified records, Defendants relied principally on the Spouse of Lamb’s Former Business Partner as their source of company financial data — despite knowing she had no accounting credentials.

29.Shaneyfelt admitted that the Spouse was not a bookkeeper, was not qualified to perform accounting functions, and was not capable of making the journal entries that Defendants nevertheless based their work upon. Defendants never raised this concern with Lamb.

30.Despite that knowledge, Shaneyfelt continued to accept substantive accounting information from the Spouse of Lamb’s Former Business Partner without independent verification, including after the parties’ dispute had become open litigation.

31.Financial communications and invoices were routinely routed through the Spouse of Lamb’s Former Business Partner rather than Lamb, even though Lamb was the managing member and a 50% owner of the Companies.

32.Lamb repeatedly requested access to financial records and the underlying bookkeeping system. He did not receive access sufficient to inspect the underlying QuickBooks entries and audit trail.

33.Internally, LSM personnel documented that the books were difficult to trace and that it was very difficult to chase the money down. That warning was not disclosed to Lamb as a material reliability problem requiring corrective action.

34.After Lamb and his Former Business Partner entered into litigation, Shaneyfelt continued to make accounting decisions based on information from the Spouse of Lamb’s Former Business Partner.

35.Shaneyfelt admitted that he personally made at least some of the disputed journal entries.

36.On or about September 30, 2022, Defendants dated or recorded a series of QuickBooks journal entries (identified by the codes below) retroactively restructuring CAHB’s books. As described in Paragraph 45, discovery later revealed that the entries were recorded as of that date but may have been actually created at a later time.

37.Entry JS122 created more than $1.5 million in liabilities attributed to private lenders and related parties — combining notes payable and accumulated interest — without supporting schedules.

38.Entry JS129 removed $866,556 in debt from CAHB’s books as purportedly assumed private debt. Shaneyfelt later admitted that the direction for that entry came from the Spouse of Lamb’s Former Business Partner and that he did not verify whether the debt was actually assumed or paid.

39.Entry JS130 zeroed intercompany accounts, eliminated down-payment receivables, added line-of-credit debt to CAHB’s books even though CAHB had no line of credit, and posted a multi-million-dollar retained-earnings adjustment without supporting documentation.

40.On CAHB Operating’s books, Defendants made similar entries zeroing receivables, adding unsupported line-of-credit debt, and booking large expense and fee figures without adequate documentation.

41.Shaneyfelt later admitted that the September 30, 2022 date on JS129 was not necessarily the date the entry was actually made and that the entry could have been made much later.

42.In May and June 2024, the court-appointed receiver received written demands from multiple private lenders — including formal written demands from Josiah Clarke, David Leslie, Sheila Leslie, Suzanne Leslie, Norman Stamps, and Tom Chapin — claiming that CAHB still owed debts that Shaneyfelt had purported to remove from the books, arising within weeks of the April 12, 2024 judicial expulsion order.

43.Contemporaneous October 2022 communications show that Shaneyfelt was still working on CAHB’s books after the date those entries purported to record.

44.Defendants produced two irreconcilable versions of CAHB’s 2022 general ledger. The insured’s production included a Cash Sale GL reflecting $239,800 in cash sales, while the filed return reported $149,900. Additionally, CAHB Operating’s QuickBooks GL existed in the insured’s production but was not maintained in the primary system used to prepare returns. Shaneyfelt ultimately acknowledged that the operative ledger work and audit trail were in QuickBooks. The existence of dual, conflicting ledger versions was not disclosed to Lamb.

45.Shaneyfelt admitted the entries could have been entered in November 2022 or even recorded as late as October 2023. (Depo. pp.113-114.)

46.A substantial volume of transactions between CAHB and entities affiliated with Lamb’s Former Business Partner were not reflected in the general ledger Defendants maintained. Defendants never disclosed this pattern to Lamb.

47.Forensic reconstruction has identified at least 286 transactions totaling more than $10 million in gross volume flowing through four line-of-credit accounts on CAHB’s books, resulting in a net drain of approximately $1.85 million.

48.Of those 286 transactions, at least 21 totaling approximately $1.24 million were completely unrecorded in the general ledger, and at least 7 totaling approximately $369,000 were relabeled as ordinary LOC or HELOC activity rather than recorded as related-party transfers. Defendants never disclosed this pattern to Lamb.

49.Neither CAHB nor CAHB Operating held any line of credit. The LOC accounts on CAHB’s books were used to record the personal debt of Lamb’s Former Business Partner as company liabilities. Defendants never disclosed this mechanism to Lamb.

50.On or about December 1, 2022, Shaneyfelt certified in writing that CAHB’s trial balances were in “excellent condition.” He later admitted under oath that this characterization was “just guessing.”

51.Internal LSM communications reflect that firm personnel identified commingling of CAHB funds with entities affiliated with Lamb’s Former Business Partner. That finding was not disclosed to Lamb. No corrective action was taken. Defendants continued to prepare and transmit returns and K-1s based on the commingled records.

52.Defendants produced dual, conflicting general ledger versions, internally identified commingling, and failed to disclose either fact to Lamb. Lamb could not reasonably have discovered the deficiencies from the face of the records alone.

53.Shaneyfelt acknowledged that an audit trail should exist and agreed it could be retrieved. A subpoena duces tecum was served on LSM. Defendants moved to quash. The Court denied that request. The subpoena was re-served. As of filing, the audit trail has not been produced.

54.CAHB’s 2022 K-1 reported $1,046,322 in distributions to Lamb.

55.He admitted he “had to make it balance” and would “just divide it” rather than deriving the figure from verified records. (Depo. pp.166-167.)

56.Shaneyfelt’s own files — including internal distribution schedules, bank statements, and general ledger records — contained materially different figures for Lamb that were far lower than the amount ultimately reported on the K-1.

57.CAHB’s 2021 K-1 likewise reported distributions to Lamb far in excess of what bank records show he actually received.

58.Shaneyfelt nevertheless transmitted tax work product presenting those figures as professionally prepared returns and K-1s.

59.In January 2024, Relyance Bank was reviewing Lamb’s loan application and encountered figures on the CAHB returns that could not be explained.

60.Lamb confronted Shaneyfelt in writing about transfers between CAHB and entities in which Lamb held no ownership interest.

61.Lamb stated plainly that he held zero ownership in these entities, and related lines of credit involved in those transfers.

62.Shaneyfelt responded, “Crystal.”

63.When Lamb pressed him on the legality of the intercompany transfers, Shaneyfelt replied, “Forget the legality angle. I’m done for today.”

64.Two days later, when Lamb followed up about a loan denial caused by figures on the returns, Shaneyfelt replied, “No comment.”

65.At deposition, Shaneyfelt acknowledged that “intercompany” denoted common ownership, that Lamb had no ownership interest in the entities receiving the money, and that the “intercompany” label was being used as a storage account: “You store it until you can figure out what you need to do with it.”

66.He also admitted that he could not reconcile those transfers.

67.On July 30, 2024, Shaneyfelt was deposed under oath.

68.He admitted that he calculated the 2022 K-1 allocation by making figures balance — testifying “I had to make it balance... just divide it” — rather than deriving them from verified records. (Depo. pp.166-167.)

69.He admitted that he personally made at least some of the disputed journal entries and acknowledged that the operative ledger work and the associated audit trail were in QuickBooks.

70.He admitted that he did not comply with generally accepted accounting principles and attempted to minimize that admission by describing his role as “just doing a tax return.” (Depo. pp.130-131.)

71.He admitted the books lacked controls, were not auditable in the form maintained, and could not be fully reconciled.

72.When describing the state of the books after discovering transfers, he said it was “like a dumpster fire that I was trying to fix.” (Depo. p.152.)

73.He agreed that no jury should consider the financial data he prepared in awarding damages in this case. (Depo. p.170.)

74.He admitted that, during active litigation, he removed debt from CAHB’s books based on representations from Lamb’s Former Business Partner’s Spouse without verifying assumption or payment and without consulting Lamb or the receiver. (Depo. pp.154, 157.)

75.He acknowledged the conflict problem and admitted he chose to continue working for Lamb’s Former Business Partner rather than Lamb, and in hindsight probably should have withdrawn.

76.He admitted that his records “should not be relied upon by those investors or the company in determining what loan obligations exist.”

77.He admitted that he was never able to properly account for all monies of CAHB and had never been able to do so. (Depo. p.88.)

78.He admitted that all work on CAHB’s books after the dispute was done at the request of Lamb’s Former Business Partner and his Spouse, without having consulted Matthew Lamb and without consulting the court-appointed Receiver. (Depo. p.133.)

79.When asked on cross-examination by Defendants’ counsel whether it would surprise him to learn that Matt Lamb was responsible for the accounting functions of the company, Shaneyfelt responded, “Yeah, it would surprise me.” He confirmed he dealt almost exclusively with the Spouse and “rarely” with Lamb. (Depo. p.182.)

80.He admitted that the “intercompany” label used on transfers between CAHB and entities affiliated with Lamb’s Former Business Partner was a misnomer because Lamb held no ownership interest in those entities, and that the label was being used as a “storage account” — a place to park entries “until you can figure out what you need to do with it.”

81.He admitted that CAHB had no internal controls and that he never disclosed that deficiency to Lamb.

82.When questioned about a $1 million transfer from CAHB to an entity in which Lamb held no ownership interest, Shaneyfelt stated, “I thought he didn’t know about it, though.” (Depo. p.152.)

83.He admitted that the accounting information he relied upon for CAHB came from Lamb’s Former Business Partner and his Spouse and that if Lamb had disagreed with that data he probably would not have known.

84.On March 2, 2023, Lamb notified Shaneyfelt in writing that he was terminating LSM’s engagement for Lamb’s personal returns and Matthew Lamb LLC. Lamb did not terminate LSM’s engagement with CAHB; that engagement continued under the court-appointed receiver (Kelley Commercial Partners/Maggie Hogan), who retained LSM for CAHB’s accounting work. By that date, Lamb had reason to suspect that Shaneyfelt had favored Lamb’s Former Business Partner in professional judgment. That suspicion did not reveal — and could not have revealed — the concealed accounting mechanics described herein: backdated journal entries, unsupported K-1 balancing, undisclosed debt removal, dual conflicting ledger versions, and the withheld QuickBooks audit trail.

85.Lamb did not sign the 2021 returns. Shaneyfelt filed them without Lamb’s authorization. Lamb did not then know, and could not reasonably know from the face of the returns alone, that Defendants had backdated major restructuring entries, used unsupported figures to build K-1 allocations, removed debt without verification, or maintained books Shaneyfelt would later admit were unauditable and unworthy of jury reliance. He did not know, and could not have known: that the September 30, 2022 dates on JS129 and JS130 were not the actual creation dates; that the 2022 K-1 allocation was derived by making figures balance rather than from verified records; that the QuickBooks Audit Trail — the system-generated log recording when each entry was actually created — had been withheld and remains unproduced to date; or that Shaneyfelt had consciously chosen the Spouse of Lamb’s Former Business Partner over Lamb and would later admit under oath that he “probably should have” withdrawn.

86.Defendants filed the 2022 CAHB federal tax return on August 28, 2023 — five months after Lamb’s March 2, 2023 termination notice for personal work, but while LSM remained engaged by the receiver for CAHB — containing the unsupported K-1 allocation and the unsupported $986,689 distribution figure. Plaintiffs did not receive the 2019–2022 general ledgers until November 28, 2023. The full scope of the misconduct was disclosed only through document discovery, forensic review, and Shaneyfelt’s sworn testimony on July 30, 2024. Plaintiffs allege that fraudulent concealment tolls accrual of the applicable limitations period until that date.

87.Defendants’ concealment included one-sided control of information, continued filing and transmission of work product without corrective disclosure, withholding of the QuickBooks audit trail, and maintenance of books in a form that concealed the nature and timing of unsupported entries.

88.Even after the dispute between Lamb and his Former Business Partner had become active litigation and a court-appointed receiver was in place, Shaneyfelt continued to modify CAHB’s general ledger at the direction of Lamb’s Former Business Partner’s Spouse — removing debt from the books more than fourteen months after the lawsuit was filed, without consulting Lamb and without consulting the receiver.

89.More recently, in February and March 2026, after Lamb’s retained forensic accountant requested work papers and responses to identified overstatements in the 2022 return, Defendants refused to engage directly and did not produce the engagement files or work papers.

90.As a direct result of Defendants’ misconduct, Plaintiffs suffered unsupported tax liabilities, levy-related injury, remediation costs, forensic reconstruction costs, lender denials, fees paid for defective work, and related professional expenses.

91.Plaintiffs also suffered broader business harm because Defendants’ conduct concealed the ongoing diversion of funds, impaired Lamb’s ability to detect and stop it, distorted the financial picture presented to lenders and other third parties, and undermined CAHB’s and CAHB Operating’s borrowing capacity and acquisition pipeline.

92.Plaintiffs have since identified additional diversions of CAHB funds occurring in 2020 and 2021 that were not discoverable during the earlier litigation with Lamb’s Former Business Partner due to the condition of the records Defendants maintained. The full extent of those diversions has not yet been quantified because of the unreliable state of the books.

93.Plaintiffs contend that Defendants are liable for the direct harms they caused and for the share of broader business losses, including lost profits, that a jury finds was caused, prolonged, concealed, or magnified by Defendants’ conduct.

94.Defendants’ concealment of the unreliability of CAHB’s books was a but-for cause of Plaintiffs’ delayed discovery of the diversion of funds. Had Defendants disclosed the commingling their firm internally identified, disclosed that the books were unauditable, or withdrawn rather than continuing to serve while aligned with the adverse side, Lamb would have been in a position to detect and stop the diversion years earlier. Had Lamb seen accurate financial information about his own business, he could have made different management, acquisition, and financial decisions. Defendants’ independent professional misconduct is a concurrent cause of the resulting harm, and the existence of a third party’s misconduct does not relieve Defendants of liability for their own.

95.Plaintiffs’ direct damages include, among other things:

96.Plaintiffs’ broader allocable damages include lost acquisition-pipeline and lost-profit losses, impaired borrowing capacity, and other business losses the jury finds were caused, prolonged, concealed, or magnified by Defendants’ conduct. An independent lost-profits analysis prepared by Frost PLLC using a discounted cash flow methodology supports the lost-profit component of those broader allocable damages. Frost PLLC’s analysis addresses the lost-profits component only; the transfer, K-1, and general-ledger figures described elsewhere in this Complaint are derived from a separate forensic reconstruction of CAHB’s financial records.

97.Where a defendant’s own professional misconduct corrupts the records that would otherwise permit precise calculation of damages, the law does not require mathematical certainty. The wrongdoer cannot both corrupt the records and then claim the victim failed to prove damages with precision.

98.The QuickBooks audit trail — the system-generated log recording when each disputed journal entry was actually created — has not been produced despite requests. Defendants’ failure to produce or preserve this evidence, if established, may support an adverse-inference instruction.

128.Plaintiffs incorporate by reference Paragraphs 1 through 127.

129.Defendants acted with conscious indifference to the rights and financial interests of Plaintiffs, including by continuing to use unsupported entries, filing unreliable work product, concealing conflicts, proceeding despite acknowledged discomfort, and proceeding despite admitted indifference to accuracy.

130.Plaintiffs are therefore entitled to punitive damages in an amount sufficient to punish and deter.