Plaintiff's Objections and Responses to
Defendant's First Request for Production

Beginning of Legal Text

CAUSE NO. 199 596 97

PLAINTIFF'S OBJECTIONS AND RESPONSES
TO DEFENDANT'S FIRST REQUEST FOR PRODUCTION

TO: Defendant Evan Brown, by and through his attorneys of record, Richard A. Sayles, Esq. and Eric D. Pearson, Esq., Sayles & Lidji, P.C., 1201 Elm Street, Suite 4400, Dallas, Texas 75270

Plaintiff DSC Communications Corporation ("DSC") files these objections and responses to Defendant Evan Brown's ("Brown") First Request for Production, pursuant to Rule 167, Texas Rules of Civil Procedure. DSC will produce all documents which are in its possession, custody, or control, and which are responsive to Brown's specific requests for production to which DSC has not objected, at the offices of its counsel, Lynn Stodghill Melsheimer & Tillotson, L.L.P., 750 North St. Paul Street, Suite 1400, Dallas, Texas 75201, at a date and time that is mutually agreeable to the par-ties.

1. GENERAL OBJECTIONS

1. DSC objects to Brown's First Request for Production of Documents on the grounds that the requests seek information that is protected by the attorney-client privilege or the attorney work product privilege.

2. DSC objects to Brown's request to produce documents at the offices of Sayles & Lidji, P.C. 4400 Renaissance Tower, 1201 Elm Street, Dallas, Texas 75270. because same is not a reasonable place, time, and manner for making inspection and performing the requested copying. Subject to and without waiving this objection. DSC will produce for inspection and or copying the requested documents and tangible things to which DSC has not objected at a mutually convenient time and place to the parties involved.

3. DSC objects to the "Definitions" contained in Brown's First Request for Production to the extent they seek to expand or modify the breadth and scope of the Texas Rules of Civil 'Procedure or to seek to increase DSC's duties under those Rules. Subject to and without waiving the objections set forth herein, DSC will produce non-privileged documents as set forth in its responses as such documents are kept in the ordinary course of business. Such documents will be made available for inspection and copying on a mutually agreeable date subject to reasonable notice and the entry of an appropriate protective order with respect to those documents containing confidential and proprietary information.

4. DSC objects to Brown's use of the term "Idea" in this Request for Production on the grounds that such term, in the context of this litigation, is unnecessarily confusing. DSC will respond to these requests using this term "Solution," as defined by the Court in the June 30, 1997 Temporary Injunction Order.

5. Because much of the information contained in the documents to be produced in response to Defendant's First Request for Production is confidential, propriety or trade secrets, DSC will not produce any documents until an appropriate protective order is in place. To the extent the parties cannot agree upon such a protective order, DSC hereby moves for a protective order limiting disclosure of or dissemination of any documents produced by DSC in this lawsuit.

2. REQUESTS FOR PRODUCTION OF DOCUMENTS

REQUEST NO. 1:

Please produce each and every Invention Disclosure Form which relates to an invention similar to the Idea.

RESPONSE:

DSC objects to this Request on the grounds that it seeks information that is confidential, proprietary, and a trade secret. See Tex.R.Civ.P. 507. DSC further objects to this Request on the grounds that it is vague and ambiguous in that Defendant has, in violation of the Court's order, refused to disclose the Solution to DSC. Without such disclosure of the Solution. DSC cannot identify all efforts to develop a similar program.

Subject to and without waiving this objection, DSC will produce all non-privileged documents, if any, within its possession, custody, or control that are responsive to this specific request, but only after a satisfactory protective order is entered in this case.

REQUEST NO. 2:

Please produce each and every document relating to DSC's efforts to develop a software reverse engineering program such as the Idea.

RESPONSE:

DSC objects to this Request on the grounds that it seeks information which is protected from discovery by the attorney-client, attorney work product, party communications, and consulting expert privileges. DSC further objects to this Request on the grounds that it seeks information that is confidential, proprietary, and a trade secret. See Tex.R.Civ.P. 507. DSC further objects to this Request on the grounds that it is over broad and unduly burdensome. DSC further objects to this Request on the grounds that it is vague and ambiguous in that Defendant has, in violation of the Court's order, refused to disclose the Solution to DSC. Without such disclosure of the Solution, DSC cannot identify all efforts to develop a similar program.

Subject to and without waiving these objections, DSC will produce all non-privileged documents, if any, within its possession, custody, or control that relate to DSC's efforts to develop technology similar to the Solution, as DSC currently understands that term.

REQUEST NO. 3:

Please produce all documents relating to any occasion on which DSC has asserted that an invention made or conceived by an employee of DSC was property of DSC due to a written agreement between the employee and DSC such as, but not limited to, the Agreement.

RESPONSE:

DSC objects to this Request on the grounds that it is over broad and unduly burdensome and contains no time restriction. DSC further objects to this Request on the grounds that it seeks information which is not relevant or reasonably calculated to lead to the discovery of admissible evidence.

REQUEST NO. 4:

Please produce all documents relating to any litigation in which DSC has asserted that an invention made or conceived by an employee of DSC was property of DSC due to a written agreement between the employee and DSC such as, but not limited to, the Agreement.

RESPONSE:

DSC objects to this Interrogatory on the grounds that it is over broad and unduly burdensome and contains no time restriction. DSC further objects to this Interrogatory on the grounds that it seeks information which is not relevant or reasonably calculated to lead to the discovery of admissible evidence. Subject to and without waiving these objections, DSC identifies the following lawsuits:
1. DSC Communications Corporation and DSC Technology v. Next Level Communications, et al., United States District Court for the Eastern District of Texas, Case No. 4:95CV96.

2. DSC Communications Corporation v. DGI Technologies, Inc., United States District Court for the Northern District of Texas, Case No. 3:94-CV-1047-X.

3. DSC Communications Corporation v. Samsung Information Systems America, Inc., et al., District Court Dallas County, Texas, 193rd Judicial District, Case No. 96-08262-L

REQUEST NO. 5:

Please produce Evan Brown's personnel file.

RESPONSE:

DSC will produce all non-privileged documents, if any, within its possession, custody, or control that are responsive to this specific request.

REQUEST NO. 6:

Please produce all documents relating to the negotiations between Brown and DSC relating to "a prospective agreement for the development of a code conversion system" as referenced in Chris Cole's February 10, 1997 memorandum to Evan Brown.

RESPONSE:

DSC objects to this Request on the grounds that it seeks information which is protected from discovery by the attorney-client, attorney work product, party communications, and consulting expert privileges. Subject to and without waiving this objection, DSC will produce all non-privileged documents, if any, within its possession, custody, or control which are responsive to this specific request.

REQUEST NO. 7:

Please produce all documents relating to the reason or reasons why DSC "elected to discontinue the negotiations with [Evan Brown] regarding a prospective agreement for the development of a code conversion system" as referenced in Chris Cole's February 10, 1997 memorandum to Evan Brown.

RESPONSE:

DSC objects to this Request on the grounds that it seeks information which is protected from discovery by the attorney-client, attorney work product, party communications, and consulting expert privileges. Subject to and without waiving this objection, DSC responds that it has no non- privileged documents responsive to this Request.

REQUEST NO. 8:

Please produce all documents which support your allegation that the Idea is "along the lines of the business, work or investigations of [DSC] or of companies which it owns or controls."

RESPONSE:

DSC objects to this Request on the grounds that it is over broad and unduly burdensome. DSC further objects to this Request on the grounds that it seeks information which is protected from discovery by the attorney-client, attorney work product. party communications, and consulting expert privileges. DSC further objects to this Request on the grounds that it seeks information that is confidential, proprietary, and a trade secret. See Tex.R.Civ.P. 507. DSC further objects to this Request on the grounds that it is vague and ambiguous in that Defendant has, in violation of the Court's order, refused to disclose the Solution to DSC. Without such disclosure of the Solution, DSC cannot identify all efforts to develop a similar program.

Subject to and without waiving these objections, DSC will produce all non-privileged documents, if any, within its possession, custody, or control that are responsive to this specific request, based on DSC's present understanding of the Solution.

REQUEST NO. 9:

Please produce all documents which support your allegation that the Idea resulted from or was suggested by any work Evan Brown did on behalf of DSC.

RESPONSE:

DSC objects to this Request on the grounds that it is over broad and unduly burdensome. DSC further objects to this Request on the grounds that it seeks information which is protected from discovery by the attorney-client, attorney work product, party communications, and consulting expert privileges. DSC further objects to this Request on the grounds that it seeks information that is confidential, proprietary, and a trade secret. See Tex.R.Civ.P. 507. DSC further objects to this Request on the grounds that it is vague and ambiguous in that Defendant has, in violation of the Court's order, refused to disclose the Solution to DSC. Without such disclosure of the Solution, DSC cannot identify all efforts to develop a similar program.

Subject to and without waiving these objections, DSC will produce all non-privileged documents, if any, within its possession, custody, or control that are responsive to this specific request, based on DSC's present understanding of the Solution.

REQUEST NO. 10:

Please produce all documents relating to any projects, work, investigations, research or other efforts by DSC to develop a software reverse engineering program such as the Idea, including but not limited to the "several occasions" on which DSC "investigated assembly language convertor systems, software, and ideas" as referenced in Dave Hinshaw's July 16, 1997 [sic] memorandum to Evan Brown.

RESPONSE:

DSC objects to this Request on the grounds that it seeks information which is protected from discovery by the attorney-client, attorney work product, party communications, and consulting expert privileges. DSC further objects to this Request on the grounds that it seeks information that is confidential, proprietary, and a trade secret. See Tex.R.Civ.P. 507. DSC further objects to this Request on the grounds that it is vague and ambiguous in that Defendant has, in violation of the Court's order, refused to disclose the Solution to DSC. Subject to and without waiving this objection, DSC will produce all non-privileged documents, if any, within its possession, custody, or control which are responsive to this specific request, based on DSC's present understanding of the Solution.

REQUEST NO. 11:

Please produce all documents which identify any other corporations or individuals of which you are aware that are developing or attempting to develop a software reverse engineering program such as the Idea.

RESPONSE:

DSC objects to this Request on the grounds that it seeks information which is protected from discovery by the attorney-client, attorney work product, party communications, and consulting expert privileges. DSC further objects to this Request on the grounds that it is vague and ambiguous in that Defendant has, in violation of the Court's order, refused to disclose the Solution to DSC. Subject to and without waiving this objection, DSC will produce all non-privileged documents, if any, within its possession, custody, or control which are responsive to this specific request, based on DSC's present understanding of the Solution.

REQUEST NO. 12:

Please produce all documents supporting DSC's claim for reasonable and necessary attorney fees.

RESPONSE:

DSC objects to this Request on the grounds that it seeks information which is protected from discovery by the attorney-client, attorney work product, party communications, and consulting expert privileges. Subject to and without waiving this objection, DSC will produce copies of its attorneys' time records.

REQUEST NO. 13:

Please produce all documents relating to the contract mentioned by Wayne Jones in his voice mail message to Evan Brown on January 13, 1997 (a copy of that message is set forth below for your reference in defining this contract).

Message four from "Wayne Jones" at extension 93465 was received at 5:40 p.m., January 13

WJ: Hey, Evan Brown, this is Wayne Jones. Hey, I've got a contract here for you. Hey, congratulations, sounds like you guys finally worked most of this out. Um, just in case those general lawyers are putting you off, I think the delay is they put it on my desk, and so I'm trying to look at it and make sure it makes sense to weird guys like me. So, I just want to let you know it's on my desk, I'm looking at it, I had some talks today, and hopefully tomorrow I'll be -- get it off my desk, cos I've gotta get it out of the way of all this other junk. I'll see ye, Evan. Give me a call if you want, but it'll be hard to reach me, but you can try if you want. Bye-bye.

RESPONSE:

DSC objects to this Request on the grounds that it seeks information which is protected from discovery by the attorney-client, attorney work product, party communications, and consulting expert privileges. Subject to and without waiving this objection, DSC will produce all non-privileged documents, if any, within its possession, custody, or control which are responsive to this specific request.

REQUEST NO. 14:

Please produce all documents relating to the contract referenced by Chris Cole in his voice mail message to Evan Brown on January 23, 1997 (a copy of that message is set forth below for your reference in defining this contract). Message five from "Chris Cole" at extension 96828 was received at 2:20 p.m. January 23.

CC: Evan, it's Chris Cole. Uh, update. I think what I have here is a final draft of a document. There's been contributions by a number of people. The attorney that I had actually write -- do the first draft is out of town, but I found it on his directory, and I have edited it myself and put the changes into it. So, I have what I think is gonna be the final draft. It needs to go by George, because it's gone through some tweaking since the first version that he saw. He should be here in the morning. I know he's attending our GDI trial that's ongoing right now, so. But, uh, just to let you know, I've interfaced with a lot of people to get this done. I can -- I know you can appreciate this is no small matter. So, but I -- I think I have all of the input from people who have to give such, and I've incorporated all those things into the document, so ... subject to George's final, so. He may be in later this afternoon, but I doubt it. I expect to see him in the morning. So that's the status report. So we're getting dangerously close. Thanks, bye.

RESPONSE:

DSC objects to this Request on the grounds that it seeks information which is protected from discovery by the attorney-client, attorney work product, party communications, and consulting expert privileges. Subject to and without waiving this objection, DSC will produce all non- privileged documents, if any, within its possession, custody, or control which are responsive to this specific request.

REQUEST NO. 15:

Please produce all documents relating to the contract referenced by Chris Cole in his voice mail message to Evan Brown on January 28, 1997 (a copy of that message is set forth below for your reference in defining this contract).

Message six from "Chris Cole" at extension 12400 was received at 3:20 p.m., January 28.

CC: Evan, it's Chris Cole, I wanted to give you an update that, uh, draft is still sittin' on a desk for, uh, approval by the brass. I have limited influence on hurrying them along, so. But that's where it is. Wanted to keep you advised. I asked, um, Montry about it, I attended his staff meeting today, and he hasn't had time to review it, so, I'll keep on him every day to the extent that I can, so, but I'll keep you informed of anything I find out. All right? Talk to you later, bye.

RESPONSE:

DSC objects to this Request on the grounds that it seeks information which is protected from discovery by the attorney-client, attorney work product, party communications, and consulting expert privileges. Subject to and without waiving this objection, DSC will produce all non-privileged documents, if any, within its possession, custody, or control which are responsive to this specific request.

REQUEST NO. 16:

Please produce all product catalogs currently used by DSC.

RESPONSE:

DSC objects to this Request on the grounds that it is over broad and unduly burdensome. Subject to and without waiving this objection, DSC will produce a representative sample of its present product catalogs.

REQUEST NO. 17:

Please produce DSC's mission statement.

RESPONSE:

DSC does not have a "mission statement." DSC will produce its quality statement and its strategy

statement.

REQUEST NO. 18:

Please produce DSC's latest 10-K.

RESPONSE:

DSC will produce its latest 10-K.

REQUEST NO. 19:

Please produce DSC's latest 10-Q.

RESPONSE:

DSC will produce its latest 10-Q.

REQUEST NO. 20:

Please produce an exemplar of every agreement, including all drafts or versions thereof, between DSC and one of its employees which DSC alleges obligates the employee to disclose to DSC the substance of any inventions made or conceived by the employee while employed by DSC.

RESPONSE:

DSC objects to this Request on the grounds that it seeks information which is not relevant or reasonably calculated to lead to the discovery of admissible evidence. DSC further objects to this Request because it is over broad and unduly burdensome.

Subject to and without waiving these objections, DSC will produce all non-privileged documents, if any, within its possession, custody, or control that are responsive to this specific request, based on DSC's present understanding of the Solution.

REQUEST NO. 21:

Please produce all documents relating to any agreements, contracts, proposals or understandings between DSC and any third party for the conversion of any of DSC's computer code.

RESPONSE:

DSC objects to this Request on the grounds that it seeks information which is protected from discovery by the attorney-client, attorney work product, party communications, and consulting expert privileges. DSC further objects to this Request on the grounds that it seeks information that is confidential, proprietary, and a trade secret. See Tex.R.Civ.P. 507. Subject to and without waiving this objection, DSC will produce all non-privileged documents, if any, within its possession, custody, or control which are responsive to this specific request, based on DSCs present understanding of the Solution.

REQUEST NO. 22:

Please produce all estimates of the potential internal savings which could be realized by DSC by application of the Idea to any of DSC's computer code.

RESPONSE:

DSC is unaware of any such estimates at this time.

REQUEST NO. 23:

Please produce all estimates of the potential third party market for the Idea.

RESPONSE:

DSC is unaware of any such estimates at this time.

REQUEST NO. 24:

Please produce all documents relating to the ownership, marketing, development or use of the Idea.

RESPONSE:

DSC objects to this Request on the grounds that it seeks information which is protected from discovery by the attorney-client, attorney work product, party communications, and consulting expert privileges. DSC further objects to this Request on the grounds that it is vague and ambiguous in that Defendant has, in violation of the Court's order, refused to disclose the Solution to DSC.

Subject to and without waiving this objection, DSC will produce all non-privileged documents, if any, within its possession, custody, or control which are responsive to this specific request, based on DSCs present understanding of the Solution.

REQUEST NO. 25:

Please produce all documents relating to the Idea.

RESPONSE:

DSC objects to this Request on the grounds that it seeks information which is protected from discovery by the attorney-client, attorney work product, party communications, and consulting expert privileges. Subject to and without waiving this objection, DSC will produce all non- privileged documents, if any, within its possession, custody, or control which are responsive to this specific request, based on DSC's present understanding of the Solution.

REQUEST NO. 26:

Please produce all documents which support your allegation that the Idea is property of DSC.

RESPONSE:

DSC objects to this Request on the grounds that it seeks information which is protected from discovery by the attorney-client, attorney work product, party communications, and consulting expert privileges. Subject to and without waiving this objection, DSC will produce all non-privileged documents, if any, within its possession, custody, or control which are responsive to this specific request, based on DSC's present understanding of the Solution.

REQUEST NO. 27:

Please produce all documents which support your allegation that Evan Brown breached the Agreement.

RESPONSE:

DSC objects to this Request on the grounds that it seeks information which is protected from discovery by the attorney-client, attorney work product, party communications, and consulting expert privileges. Subject to and without waiving this objection, DSC will produce all non-privileged documents, if any, within its possession, custody, or control which are responsive to this specific request, based on DSC's present understanding of the Solution.

REQUEST NO. 28:

Please produce all documents which support your claim for damages in this lawsuit or identify the method by which you calculated such damages.

RESPONSE:

DSC objects to this Request on the grounds that it seeks information which is protected from discovery by the attorney-client, attorney work product, party communications, and consulting expert privileges. Subject to and without waiving this objection, DSC will produce all non-privileged documents, if any, within its possession, custody, or control which are responsive to this specific request.

REQUEST NO. 29:

Please produce all documents relating to your decision to "discontinue the negotiations with [Brown] regarding a prospective agreement for the development of a code conversion system" as referenced in Chris Cole's February 10, 1997 memorandum to Evan Brown.

RESPONSE:

DSC objects to this Request on the grounds that it seeks information which is protected from discovery by the attorney-client, attorney work product, party communications, and consulting expert privileges. Subject to and without waiving this objection, DSC responds that there are no non-privileged documents responsive to this Request.

REQUEST NO. 30:

Please produce all releases, including all drafts or versions thereof, relating to the Idea, including but not limited to all drafts and versions of the June 10, 1996 release prepared by Victor Larry Sewell.

RESPONSE:

DSC objects to this Request on the grounds that it seeks information which is protected from discovery by the attorney-client, attorney work product, party communications, and consulting expert privileges. DSC is unaware of any non-privileged documents responsive to this Request.

REQUEST NO. 31:

Please produce all documents relating to DSC's Great Ideas Program.

RESPONSE:

DSC objects to this Request on the grounds that it is over broad and unduly burdensome. DSC further objects to this Request on the grounds that it is over broad, unduly burdensome, and is an improper "fishing expedition" prohibited by Loftin v. Martin, 776 SW.2d 145 (Tex. 1989), in failing to identify the specific category of documents requested. Subject to and without waiving these objections, DSC will produce a representative sample of documents relating to DSC's Great Ideas Program.

REQUEST NO. 32:

Please produce all Tools Group weekly status reports relating to software reverse engineering.

RESPONSE:

DSC objects to this Request on the grounds that it seeks information which is not relevant or reasonably calculated to lead to the discovery of admissible evidence. DSC further objects to this Request on the grounds that it seeks information that is confidential, proprietary, and a trade secret. See Tex.R.Civ.P. 507. Subject to and without waiving this objection, DSC will produce all non-privileged documents, if any, within its possession, custody, or control that are responsive to this specific request, based on DSC's present understanding of the Solution.

REQUEST NO. 33:

Please produce all status reports relating to software reverse engineering.

RESPONSE:

DSC objects to this Request on the grounds that it is over broad and unduly burdensome. DSC further objects to this Request on the grounds that it seeks information which is not relevant or reasonably calculated to lead to the discovery of admissible evidence. DSC further objects to this Request on the grounds that it seeks information that is confidential, proprietary, and a trade secret. See Tex.R.Civ.P. 507. DSC objects to this Request on the grounds that it seeks information that is confidential, proprietary, and a trade secret. Subject to and without waiving these objections, DSC will produce all non-privileged documents, if any, within its possession, custody, or control that are responsive to this specific request.

REQUEST NO. 34:

Please produce all documents relating to Evan Brown.

RESPONSE:

DSC objects to this Request on the grounds that it is over broad and unduly burdensome. DSC further objects to this Request on the grounds that it lacks the particularity required by the Texas Rules of Civil Procedure. DSC further objects to this Request on the grounds that it is over broad, unduly burdensome, and is an improper "fishing expedition" prohibited by Loftin v. Martin, 776 SW.2d 145 (Tex. 1989), in failing to identify the specific category of documents requested.

REQUEST NO. 35:

Please produce all statements of Evan Brown as that term is defined by Rule 166b(2)(g) of the Texas Rules of Civil Procedure.

RESPONSE:

None.

REQUEST NO. 36:

Please produce all documents relating to software reverse engineering.

RESPONSE:

DSC objects to this Request on the grounds that it is over broad and unduly burdensome. DSC further objects to this Request on the grounds that it seeks information which is not relevant or reasonably calculated to lead to the discovery of admissible evidence. DSC further objects to this Request on the grounds that it seeks information that is confidential, proprietary, and a trade secret. See Tex.R.Civ.P. 507. DSC further objects to this Request on the grounds that it seeks information which is protected from discovery by the attorney client, attorney work product, party communications, and consulting expert privileges.

REQUEST NO. 37:

Please produce all documents relating to Lance Flores.

RESPONSE:

DSC objects to this Request on the grounds that it seeks information which is protected from discovery by the attorney-client, attorney work product, party communications, and consulting expert privileges. Subject to and without waiving this objection, DSC will produce all non-privileged documents, if any, within its possession, custody, or control which are responsive to this specific request, based on DSC's present understanding of the Solution,

REQUEST NO. 38:

Please produce all documents relating to Cyber Automation Systems.

RESPONSE:

DSC objects to this Request on the grounds that it seeks information which is protected from discovery by the attorney-client, attorney work product, party communications, and consulting expert privileges. Subject to and without waiving this objection, DSC will produce all non-privileged documents, if any, within its possession, custody, or control which are responsive to this specific request, based on DSC's present understanding of the Solution.

REQUEST NO. 39:

Please produce all documents relating to any meetings between DSC or its counsel and Lance Flores, including but not limited to all documents relating to the meeting between Lance Flores and Eric Pinker which occurred on July 14 or 15, 1997.

RESPONSE:

DSC objects to this Request on the grounds that it seeks information which is protected from discovery by the attorney-client, attorney work product, party communications, and consulting expert privileges. Subject to and without waiving this objection, DSC will produce all non-privileged documents, if any, within its possession, custody, or control which are responsive to this specific request.

Respectfully submitted,


LYNN STODGHILL MELSHEIMER & TILLOTSON, L.L.P.


By:______________________________
<< signature >>


Michael P. Lynn, P.C.
Texas Bar No. 12738500
Eric W. Pinker
Texas Bar No. 16016550
John T. Cox III
Georgia Bar No. 192530


750 North St. Paul Street
Suite 1400
Dallas, Texas 75201
(214) 981-3800 - Telephone
(214) 981-3839 - Telecopy


ATTORNEYS FOR PLAINTIFF
DSC COMMUNICATIONS CORPORATION

CERTIFICATE OF SERVICE

The undersigned hereby certifies that a true and correct copy of the above and foregoing document has been served upon all counsel of record, as identified below, on this the 14th day of August, 1997:

CM, RRR NO, Z 430 960 566 Eric D. Pearson, Esq. Sayles & Lidji, P.C. 1201 Elm Street, Suite 4400 Dallas, Texas 75270	CM, RRR NO, Z 430 960 568 Mr. Lance Flores 6514 Ridgecrest 222 Dallas, Texas 75231
CM, BRA NO, Z 430 960 567 Dale Drake, Esq. I 10 East Davis, Suite 200 Post Office Box 1662 McKinney, Texas 75070-1662

____________________________
<< signature >>
John T. Cox III

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