Trone et al v. Peanut Corporation of America

Filing 24

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Trone et al v. Peanut Corporation of America Doc. 24 Att. 1 Dockets.Justia.com MARK CUBAN ARBITRATION DON NO 1310016794 NELSON la Counterrespondent vs DALLAS DALLAS BASKETBALL LIMITED dba CIVIL ARBITRATION PENDING BEFORE JAMS MAVERICKS Respondent laimant 10 ORAL AND VIDEOTAPED MARK DEPOSITION OF CUBAN 12 13 14 15 16 17 18 19 20 21 22 23 24 January 18th 2008 ANSWERS AND VIDEOTAPED of the DEPOSITION of on MARK the of CUBAN 18th taken of at the instance Plaintiff the day January AD in 2008 the of in between above Fish hours and 942 am Main and cause 432 at styled numbered 1717 the offices Richardson Street Suite 5000 Cal Dallas Dallas RDR State and County Texas before Jerry in laway for the Rules Certified of Shorthand pursuant stated on Reporter to and Texas provisions the Arbitration the the record 2148555300 UARS 8004457718 MARK CUBAN 094158 094158 THE January time is VIDEOGRAPHER Todays date on is 094204 the 2008 We be are the record on The the video Will 094207 942 all am their Please advised be while 094211 record Counsel microphones will recording for the Steve audio record we or 094213 state appearances 094216 MR represent Basketball 10 11 12 13 14 ODG and LL Dal Stodgh 094218 the Defendant las Mavericks is Dal las 094222 Limited in which also 094227 counterclaimant producing Robert the Mark lawsuit Cuban and weve got is we are 094230 witness general Jeff today Present Mark Cuban 094235 Hart counsel for the partner 094238 companies Richardson and at Fish 094242 094244 MR 16 17 18 19 20 DAVENPORT and Im Ryan Mark Davenport represent 094246 along Don with Don Col leluori McComber 094250 Nelson MARK CUBAN testified as having been first duly sworn follows EXAMINATION BY 094303 21 22 23 24 25 MR DAVENPORT Please Mark state your 094303 name 094307 Cuban Cuban just met you few for minutes 094308 Mr Im Mark ago 094311 Davenport Im the lawyer Mr Nelson 855 UARS 8004457718 MARK CUBAN 094314 rn going to ask Do you you some questions who today am about and who this 094317 arbitration understand 094320 represent Yes Have 094321 sir you done this 094321 before 094322 Yes Okay you know you sir So 094323 dont oath need to go through all the 094326 are under stuff 094327 Yes 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 sir Since tell 094328 Okay before let me we havent little to worked bit together how take not to ask here 094333 you here about 094335 depositions to not trick badger you here you 094341 ask you questions And can Im if not ask me you 094344 question that you thats unfair question answer and 094348 dont of the think way you give truthful you stop 094350 because then worded the it wi me 094353 will repeat question 094354 Sure Is 094354 that fair enough And you will have to 094357 answer 094367 Yes me sir with Let me 094358 yes hand and are or no Exhibit which turn over is 094402 you if our the 094404 Notice back of of Deposition since we you wi on 094408 it suing company weve asked 2148555300 UARS 8004457718 MARK CUBAN 37 102055 Do you see that 55h 102056 Yes Now being terms on sir lets say that 7th 2002 We this and for was agreement it came under into its 102102 February 1997 okay it expired 102107 June 30th Okay hypothetical 102114 question it know its amended had not But been is assuming amended it 102118 had expired not that of under terms on and 102122 and had been removed Nelson June have 30th been 2002 free not 102125 fact 10 11 12 13 Mr would to become 102128 the coach another you team are asking in 102131 Again conclusion prepared to on do me to and come to legal 102133 contract 1997 Im just not 102136 that you for of hypothetical legal 102137 14 15 16 17 18 19 20 21 22 23 24 25 Im Im not asking you question and am 102140 asking conclusion agreement as asking of 102143 for your the Mavs understanding is the you president 102145 that is what am are president 102146 What You it the president honcho Just the 102148 are head 102152 MR am HART owner 102153 just the owner Just the 102154 BY MR Yeah Who is DAVENPORT owner 102155 102155 the president 102157 Terdema right UARS 2148555300 8004457718 MARK CUBAN 112 121208 first We round down and it was one of the first best two and and by 40 comebacks games won two we at ever home 121212 went we then in 20 we lost loosing went game we to in the 121216 Then and back game then we game which Houston games came in 121219 Houston Houston So then 121221 and was it is beat points that then we 121226 incredible it from and 121229 perspective Phoenix in was next this was great lost to 121233 the round is 121235 Now 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0405 the step events down are going as 121241 Yes We where sir that wi 121242 know to develop on 121248 Mr Nelson head coach March 121255 19th 2005 Yes Okay We were you 121256 sir Tel at me 121257 how that came about Tux to Tux be and 1213 02 our charity it event 121308 Tennies event Nellie most and And know Del was just going to me another that the be to 121311 then Harris came and said 121314 wanted out Nellie to was ready was to leave and to 121320 important And that thing if we Nellie continuing we from resign were him and 121323 paid get didnt been pay him going to 121327 exactly Would what we had getting him this 121330 date to consider letting continue 121334 pay him And 121335 said Where do sign You 2148555300 UARS 8004457718 MARK CUBAN 113 121339 know trying and will qualify and had that had changed getting His when been up think having to that and well am 121344 yeah Avery what 121347 conversations in point more was was 121349 talking to Avery he was was more 121353 comfortable meeting to my that ready And do so preparation when Del 121357 desperation like came 121402 me was Where see sign this is 121405 Okay strike 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 to Lets what well 121410 that Were you and at 121410 Mr Nelson beating each 121414 other up in the press was that point 121416 Nellie saying anything going in throwing in dont the go to recall my 121420 specific let press other than Hawaii And and 121423 wasnt going it to Nellie him the remember remember it if 121426 and telling year or that previous am dont 121428 was that year going think to am was 121431 that year saying to to in Look you work not fire not you going 33h 121436 amgoing pay you make go to this out And Hawaii at dont in remember Later what 121441 specifics than was the press but the am that point time 121447 that going yes on in dont press sure your remember the specifics 121449 121451 Okay petition have recol you read of the events little and 121453 Obviously lection are 121455 Mr Nelsons recollection of events bit 2148555300 UARS 8004457718 MARK CUBAN 118 121916 had some understanding our of of knew Avery knew And Avery our actual would ly 121919 players and talked good to players our Avery who felt 121922 some players do 121925 job So 121926 March step of 05 not then make Mr big Nelson says he will 121935 graciously He down use scene yes yeah 121940 didnt those words to me but 121942 that was my understanding he 121942 When 10 11 12 13 stepped the down club to let Mr honor Avery the step terms in of 121947 you his assured him that would 121951 contract correct believe 121954 dont believe know specifically the 121956 exact words When but he so yes in sir you never told 121958 14 stepped not in down March 122003 him that 16 17 18 19 20 21 22 23 he would kick receive his consultant is salary 122013 that would on 19 back of 1st 2006 that correct 122018 Thats Okay Looking him and at correct Now amount at good to 122025 my earlier that the question club was he 122028 the money paying 122030 looking doing fact good your allegations looking had today at that 122033 wasnt and the job and Johnson your al legati ons 122037 that Mr been he had been coming 122040 pretty shape to me we mean again are you why thought you to was 122043 24 25 along explain wouldnt terminate have you just for 122046 said Mr Nelson going 2148555300 UARS 8004457718 MARK CUBAN 121 122255 with the press couldnt Was he 122255 speak to that Randy They dont know Galloway buddies highly ask of 122256 popular with 122258 Yeah Why yeah yeah were so to 122301 did Mr Galloway think have stuff him 122304 dont know But Youd nice Randy him wouldnt 122306 hed write about 122308 he My 10 11 12 13 122308 understanding is they are drinking buddies 122311 yes The peop Was he 122311 was Mr Nelson with popular with and other the 122315 popular the players 122317 coaches Some coaches players some the 122318 14 15 16 17 18 19 20 21 22 23 24 25 yes some players Some in no the Some organization by 122320 yes in coaches no 122323 yes some organization So no deal It varied person 122327 All right couldnt the was say across the would not 122329 You board make he couldnt by 122332 was just wellliked about you everybody 122335 that statement Do Nellie are 122336 you have think no wellliked by everybody 122339 idea 122340 As of you March say to if 2005 you your then step he steps down as head we 122348 coach wi and aside and graceful let ly 122352 continue honor contract Avery 2148555300 UARS 8004457718 MARK CUBAN 122 122355 start coaching and team and he did that as to 122357 MR Yes sir STODGHILL Objection form 122358 122359 BY MR Mr head What Nelson coaching else did That DAVENPORT you he Now what did you expect away his 122400 since had was effectively helping taken the 122405 duties you was with draft 122409 122409 before No that was before Huh 122410 10 11 12 13 When while he he was helping with for the draft that was 122414 was Why still employed March both positions 122416 post 19 2005 122418 Right what To be he 122418 14 15 16 17 18 19 20 21 22 23 24 25 did you expect when we Mr had Nelson to do or 122420 available was best and questions had the that 122423 we felt that of prepared to not or We greatest there 122426 amount would would and experience issues that help issues and knew that 122429 be but that Avery we had Del 122432 have questions and to you ley and know and be although as 122434 Donny him were very the Larry be Ri others avai resource resource Nellie situations be we 122438 wanted There be there lable as is 122441 certain effective benefit was he you know and Nellie in can 122444 coach of that certain could if 122447 having knowledge to of value 122449 So available you you needed him 2148555300 UARS 8004457718 MARK CUBAN 156 135739 MR Thats attorneys STODGHILL legal Objection as to form with my 135740 discussion would have 135742 dont BY MR know specifically 135743 DAVENPORT on dont 15th like want the to hide the 135745 ball from of you pun but the hide you ball thats around 135748 kind the right how The about on Maybe dancing 135751 question that the 135754 15th the Mavs and we did not make 135758 that 10 11 12 13 14 15 16 17 18 19 20 21 22 23 payment at so Mr Nelson in contends contend had 135801 that that the instant time the Mavericks first we 135805 breached are contract you understand thats what 135807 claiming understand 13 5807 it but have no 135809 Okay 135809 dont Okay then know the legal go definition to of breach 135811 Now lets back the exhibit 135815 13 58 18 MR MR MR BY MR it page STODGH LL Which exhibit 135821 DAVENPORT STODGH Exhibit 11 135822 LL Okay If 13 5823 DAVENPORT going to go can pick back up on at 135832 Okay of this am to Wednesday look 135841 135843 24 25 Okay See if 135844 we can pick this up July 2148555300 iA 8004457718 MARK CUBAN 157 135851 2006 preparing that found Okay for the We dont in Ill and tell you in 135854 deposition reviewing to our the emai we Is 135858 youall produced no response was request on 135901 communication between the that produced showed almost this and 135906 subject one so ones ye just So you the or 135909 starting July 26th thats month 135917 135917 Correct where 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 135917 we cant find is anything July Nellie So the first oyd 135919 thing Jahner check we see on this topic got call the 26 2006 135925 wrote and the from not regarding in his 135930 200000 He we did that include not his in 135934 compensation the negotiations if states at this was his discussed He 135939 the of time of this in departure Then 135944 asked asking turning talk you we had he any writing he when to 135947 what should to do next briefly told him with alluded him In 135952 this over his me attorney to call would case his to 135956 to you to He asked back 140000 want is discuss and this directly Nellie you want new 140003 number such such Tell me how 140005 proceed So when 140007 Mr he Nelson did didnt call receive Floyd his 140012 payment the first thing and say was Jahner 140016 whats up 140018 Uhhuh 2148555300 UARS 8004457718 MARK CUBAN 158 140016 Why this was you And want you not me didnt and to do and get Jahner how my is payment now And he states what do 140022 asking me you to 140025 do you want you proceed to 140028 call lets see what call said that You 140032 said What Have does his attorney and state his case 140035 that Because Nellie step on 140035 agreed with me am sorry 140037 didnt mean Have to you told lawyer apologize 140039 his Have as by you the Mr cal Jahner me said state hes his you 140043 10 got lawyer This is and 140046 case 12 13 of July 26th that 2006 the month contract at after 140050 had been told and in Mr you Jahner had hadnt your own 140053 changed after already looked that 140067 14 15 16 17 18 19 20 21 22 23 24 25 email hadnt which you had confirmed than the contract we 140100 changed rather we saying Mr the say Jahner made 140106 terrible immediately cal mistake cut him his breached contract tell 140109 check case you his lawyer to to 140112 and state What What case was he supposed 140115 state were we you expecting as him to said state in 140117 Well we agree that hadnt my we email didnt not to 140120 hadnt we really discussed pay the it but It 140124 would then 200000 said we we was 140126 discussed And then deal my And Nellie didnt discuss discuss it so 140129 response with okay didnt it 140133 lets it 2148555300 UARS 8004457718 MARK CUBAN 159 140136 You contract On on hadnt July discussed it you had entered into 140138 2003 19th we 140142 March you didnt discuss it it in 140145 Well contract you discussed you Nelson your said will the to 140148 told him and Mr with testify that This 140151 this and contract its consistent doesnt change the Fifth email the 140154 its unaffected 140157 contract Amendment 140200 Right 10 11 12 13 140200 Okay obligated the The Mavs Fifth Amendment to make that contractual ly 140203 payment as to 140205 MR will ILLh to my Objection lawyers Do on form 140206 defer that me to 140208 14 15 16 17 18 19 20 21 22 23 24 25 BY MR this to DAVENPORT you want read 140209 you would still 140210 defer to my lawyers will 140214 MR everything THE ILLh WITNESS DAVENPORT him to That change 140215 140216 Thats Okay call why So pay state his them his 140218 BY MR when you said case 140223 tell and state case 140226 Right what did you want 140226 him to beg for his 140228 money Basically 140228 2148555300 UARS 8004457718 MARK CUBAN 160 140230 MR ILL DAVENPORT had overpaid Objection as to form you were 140231 BY MR mad thought you it Basically him It 140232 before was just that him talk all 140234 No long wasnt finals that and it wasnt this your shit 140237 after the havi ng Ii 140240 about us beg So So was ke okay state 140243 case 140244 when lost you or say the finals the fact that 140248 youall 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 had what he had 140249 The which fact that had to badmouthed him the removed all us every he 140252 way and have because the was 140255 badmouthing no just all spec ifica Ily you wanted him to things 140258 one th ing So 140301 beg for his money 140303 Yep Did 140304 that just make you feel good 140306 Yep Werent the contract by 140307 you not concerned paying to my had that you had breached 140309 him lawyers on all 140310 deferred that stuff 140313 mean this an was on like mentioned with to you earlier He 140315 this was it going It dialogue Floyd that we brought 140319 up to me wasnt it something something that had and had It 140321 specifically specifically wasnt in Nellie 19th 140324 discussed March meeting 2148555300 UARS 8004457718 MARK CUBAN 161 140326 was very then pay brief Floyd him his meeting showed blood am to me and it was one where and you 140331 know damn the emails said 140333 money going to 140335 But am first get say 26 at when you said had 140338 going and to that his July money 402 Nellie 140342 cal led asked where was Uhhuh 140344 And my 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 he said you What is am going his want We to turn this over call to 140346 lawyer his And say have attorney him to and 140348 state case here did you say that 140352 Mr 15th Cuban my case you to have me not written payment paying you on 140355 contract that You requires the make by the 140359 breached to sue you contract it and havent 140401 Im paid going for that have money since 140405 me Would that convinced you as to 140407 MR Say that ILLh again DAVENPORT you at Objection form 140412 140413 BY MR his Well when beg you you say state money his 140414 case you if know are he wanted him to but when says we for the state 140416 because if mad calls him case 140419 he lawyer our on Is okay have You you Mr Cuban you 140422 here you say state case the that contract breached wanted the 140427 didnt make contract so payment pay 15th what 140432 me him to 140437 say 2148555300 8004457718 MARK CUBAN 162 37h 140438 MR STODGHILL Objection as to form an dont know expectation him to what and as really him see it didnt say the have 140440 wanted you can which simply wanted 140443 beg by emai from where 140446 correspondence are we for is what 140452 at BY MR From 140453 DAVENPORT Its to 140454 July by 26 that we 402 eveni July 26 by 759 1000 were him to days had him 140501 responding 10 11 12 13 so 932 had oclock going beg 140505 that pay very same So it night said we to his 140508 him it wasnt what It like like when waited told three night 140511 case to call wasnt and for him 140514 beg him his was by that said 140519 14 15 16 17 18 19 20 21 22 23 24 25 Damn pay We It money 140520 will see 140521 was more you know hypothetical have liked on on that to 140523 yeah would have of would have ked have him to would have Ga lot him beg would front have 140526 liked to been oway of his knees knees would 140529 seen Randy were 140532 Nellie but If There things 140533 liked 140533 he was on his knees he would still be 140536 taller than you he are 140537 No than wouldnt He is not that much bigger 140541 me UARS 2148555300 8004457718 MARK CUBAN 173 141717 would But you have to ask the accountants the Mavs comp on 141719 wouldnt paying the have been 141720 wouldnt 1st and would have 15th been unless him the deferred he the 141722 Mavs thought had earned it 141725 you Again Okay yeah So 141727 presume get into so not some negotiations ly 141730 you over going 141737 the give 10 11 12 13 sixth him in amended try to contract give with him those basical you are 141744 oneshot payment you you right are going 141747 and back connection negotiations iar 141751 and forth you were in you fami were doing 141755 them Were those negotiations 141756 No sir for Fifth 141758 14 15 16 17 18 19 20 21 22 23 24 25 141800 Oh for for what was were doing going to to be 141800 the Sixth lump 141805 Amendment the where you pay him sum on 141808 consulting contract 141809 No Do sir you remember the basis why no 141809 agreement was 141811 ever reached 141815 dont timeline remember exactly why not in terms of 141820 no Well the Is 141821 parties that it never was the its fair reading 141830 from these Mavericks not 2148555300 UARS 8004457718 MARK CUBAN 174 141835 Mr to Nelson who buy him out initiated rather let me the thought that by they wanted 141839 than just abide the in contract that we 141842 Well had had just put having these qualifier types of 141844 history He of negotiations he 141847 with ask Nellie for there of are multiple and times he So had would for 141850 acceleration of other to be payments with kind asked 141854 prepayments unusual things in us of this wasnt with 141858 for us this conversation 141900 him 10 11 12 13 141900 Okay 141900 MR move to DAVENPORT Object nonresponsive 141902 strike 141902 BY MR on DAVENPORT this is am going pretty of to stay right 141904 14 this one because In important if 141907 15 16 17 18 19 20 21 22 23 24 25 it this was you paid not track emails that am reading to 141909 correctly it Mr Jahner to per suggested 141915 Mr than He Nelson would the like negotiate month at something that we owe ess 141920 200000 it out you 141926 brought up Nelson yes 141929 Correct According According to his these 141929 emai Is yes Ill listen to do 141931 emails said 141932 Correct got to say if Nelson what sum you 141934 or well want negotiate to could lump 141938 payment you do you know and they were 2148555300 UARS 8004457718 MARK CUBAN 175 141941 negotiating right right know they never got to 141942 Thats But we 141942 reach agreement 141945 Correct All 141945 right Now August in going Give to 141950 come well lets stay August you order me the 141952 OConnor letter Do 4th John 141956 know OConnor 141957 No 10 11 12 13 sir you that ever met 141958 Have Not him 141959 know of Let me go 142047 MR minute THE DAVENPORT off the record 142049 142049 14 VIDEOGRAPHER Off the record at 142051 15 16 17 18 19 20 21 22 23 20 Recess THE The time is 142052 l6h minutes Back on 143611 VIDEOGRAPHER the record 143614 236 DAVENPORT After you him did him had to 143618 BY MR Mr you Jahner called had written 143623 the email instructing pay the as 143630 it blood instead to in money when of paying you like learn that 143634 Jahner had you him told for him lump 143638 decided was it go start negotiating with 143641 24 25 sum this email 143643 In the email yeah UARS 2148555300 8004457718 MARK CUBAN 176 143643 And communication say what then with did you did you you call have him any after that and 143645 him did or 143647 are you doing whats going on 143649 No You just figured someth ng if 143649 he could negotiate 143651 out that do You was all all the better via to 143653 No we communicating ever talk email 143656 Okay him what 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 So dont him just ask 143659 going on think 143700 dont Never Ive ever called him 143702 have cal led Jahner 143703 Nope Really Does the that he 143704 office near you 143705 Hes And at is Mavs where office you 143707 are 143709 Rarely You mostly out work of my 143709 out of home and several to 143712 work once home offices lets see of the 143717 Jahner you starts talking in 143742 Did negot at ons get involved any 143744 concerning this possible buyout 143747 No Al 143748 right you from Look John As at the letter of August Don August 4th 143752 addressed Exhibit to OConnor you 2006 the 143758 14 Dear Mark know claims 2148555300 8004457718 MARK CUBAN 190 145438 Well in you know that saw the that allegation 145443 this was counterclaim youalt in filed and reading the was the thats why email that first who 145447 particularly shows interested clearly sum 145450 traffic which brought had up that person not 145454 this lump payment to Mr Nelson it 145459 just wanted his contract be honored was 145502 Mr Jahner No dont you remember 145504 question when he 145504 did that definitely to deal he 145506 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Yeah but it he Floyd tried in brought with it it up 145508 was how Nellie me that he 145510 particularly was willing upset to that wanted get my it just to all at 145514 take than less just to And so once of 145516 sooner it rather later interpretation 145519 was just the But analogy the 15th gave first Nelson breached learned the only the about thing the he 145522 when July the Mavericks and 145524 contract breach said you on Mr 145528 when payment wasnt made my 145532 was why arent you honoring the contract Dont 145535 remember emai 145537 MR ILL ILLh can read Objection as to form Jahner 145537 BY MR said he sa DAVENPORT Thats what Mr 145539 145539 MR Wel we Objection as to form rather 145540 what Mr Jahner said 2148555300 UARS 8004457718 MARK CUBAN 252 163203 change your asked Judge ask answers you the have same As far as truthful at you and the the as you recall and if 163206 been correct time same we 163210 questions wi try this to if 163213 Ashworth you same If give is me answers 163217 the questions understand you that fair yes Okay Have been 163219 them 163221 If understand them 163223 courteous to you 163224 Yes 10 11 12 13 163225 Okay tness Fair enough Thank you Ill pass the 163228 163228 MR our questions the transcript as but to STODGHILL did want see if there We an is are going to reserve to look to at 163229 opportunity any part we 163233 14 15 16 17 18 19 20 21 22 23 24 25 want 163235 designate confidential 163237 MR anything with it DAVENPORT until Well do we wont do 163239 you that 163240 MR lets think ILLh we are done Id appreciate you have that And 163241 unIes anything 163243 se MR THE at 163243 DAVENPORT VIDEOGRAPHER We are We done are off am done record 163244 the 163246 432 2148555300 UARS 8004457718 MARK CUBAN 253 CHANGES AND DATE CHANGE SIGNATURE OF WITNESS PAGE MARK CUBAN LINE DEPO 1182008 REASON 10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 2148555300 8004457718 MARK CUBAN 254 MARK deposition true and and hereby CUBAN affix as have read the foregoing same is my signature noted that correct except above MARK THE STATE OF OF CUBAN COUNTY Before 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 me MARK or on this day personal to ly appeared oath CUBAN known to me or proved me under of through or description the person identity name is card other to document the they to be whose and subscribed to and foregoing executed therein instrument the same acknowledged purposes me that for the consideration expressed Given this day of under my hand and seal of office 2008 NOTARY THE PUBLIC OF IN AND FOR STATE 2148555300 UARS 8004457718 MARK CUBAN 255 COUNTY STATE OF OF DALLAS TEXAS Jerry Callaway and for the as RDR State certified of shorthand hereby caption reporter that are in Texas in do certify hereto the facts that stated came by by me before me the me the sworn true there who was the that aforementioned to named truth this person duly in testify the in concerning matters the controversy 10 11 12 13 cause by and examination under record was my of reduced to writing that computer transcription is supervision the testimony the by deposition the true given witness that to am or neither employed this am or not further attorney any of or certify nor 14 counsel parties is for to related in by 15 16 the the and of action further which deposition relative employed or by taken that 17 18 19 20 21 22 23 24 25 employee the in any attorney or counsel parties hereto financially interested the action under of my hand and seal Given of office on this the 23rd day January AD 2008 RDR CSR 948 Jerry Callaway Date 12312008 Expiration Firm Registration No 209 Tower 5220 Renaissance 1201 Elm Street Dallas Texas 75270 214 2148555300 8555300 UARS 8004457718

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