IN THE CIRCUIT COURT OF THE THIRTEENTH DISTRICT
DEKALB COUNTY, TENNESSEE
SHERRY SMITH, individually and as next of
kin of LAUREN TAYLOR AGEE, Deceased,
Plaintiff,
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)
)
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v. )
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AARON LILLY, BRIXNER HEYDRICH )
GAMBRELL, HANNAH NICOLE PALMER, )
CHRISTOPHER LEO STOUT, )
JOHN DOES 1-10, and JANE DOES 1-10, )
)
Defendants.
DECLARATION OF CHRIS BROWN
Chris Brown after being duly sworn according to law, deposes and says as follows:
1, Tam a resident of Sumner County, Tennessee. I have personal knowledge of the
statements in this declaration, I am over eighteen years old and I am competent to give the
following testimony.
2. I am a small business owner from Hendersonville, Tennessee, and I have
information which I believe is relevant to the death of Lauren Agee.
3. On the we
end of July 25, 2015, my wife, daughter, daughter's boyftiend, and I
were at the Pates’s Ford Marina in DeKalb County, Tennessee, We were staying in a cabin near
the Sligo Boat Dock and had come to Pate’s Ford Boat Dock by boat with some friends, We
were waiting on the dock for our friends to come pick them up in their boat to go back to Sligo.
4, Right at midnight, my family and 1 walked out onto the dock toward the very end
of the dock. I was shocked to see a white male swimming toward the dock. I saw this young man
climb up on the dock. ‘The young man appeared extremely distraught and worn out. He was
(o1s19614.1)spitting up water for several minutes. The young man told us that he had almost drowned when
he swam from the area of the bluff to the marina dock. The young man stated that he had been
searching for his friends,
3. The young man was white, with long brown hair. He was wearing a bandana and
‘American Flag shorts, The young man eventually went into the marina restaurant, and I did not
ever see any of the other people that were allegedly camping out with the young man,
6. I did not think any more about the incident until I saw the news report of the
discovery of the body of a young woman floating in the lake near the bluff. [ put two and two
together and immediately thought that the young man that I saw may be involved in some way. I
‘was especially affected by the discovery of the body of the young woman because my daughter
is about the same age.
7. The week after Wakefest, I called the DeKalb County Sheriff's Office to report
what I had seen, The DeKalb County Sheriff's Office advised me that if it became of interest
they would contact me back. I never was contacted again by their office.
8, Recently, I was getting my hair cut by a young woman who is in the same age
{group as the victim and other campers, The topic of Lauren’s death came up and I told the young
‘woman what I had seen that night. She did an Instagram search and found pictures of Aaron Lily
‘wearing the American Flag shorts that I had described.
9, Tam sure that Lily is the young man that came up out of the water that night. The
very tip of the marina dock is the closest point I saw to the bluff where they are alleging that the
young girl fell into the water, but it was still a very long distance for someone to swim,
especially at midnight,
01519614.) 2Further Declarant saith not. I declare (certify, verify or state) under penalty of perjury that the
foregoing is true and correct on this 221
{015196141} 3