Time: Wed Dec 10 08:21:59 1997
To: Brenda McCurdy <brendamc@admin.hilconet.com>
From: Paul Andrew Mitchell [address in tool bar]
Subject: plans per telecon

Dear Brenda,

I am writing to confirm the decisions
we made on the telephone last evening:

1.  you will motion the appeals court
    for an extension of time to file
    your appellate brief

    a.  you will send me a draft, via email,
        based on: holiday conflicts, new counsel
        needs time to prepare, and newly found

    b.  I will review and comment, then return
        same to you, via email

2.  you will follow this with a motion to
    stay proceedings, pending final resolution/
    judgment on fraud action against bank attorney

    a.  you will discuss with your father the
        need to commence this action, asap,
        because appeals court will need to know
        that this action has commenced

    b.  one alternative is to Notice the appeals court
        of his intent to sue the attorney, and to
        give the appeals court an opportunity to
        remand solely on the basis of that fraud

    b.  the ground for this new action/remand will
        be the attorney's fraud -- for writing
        to your father about a postponement,
        but failing to inform the court of same, and
        then proceeding with the original hearing

3.  you will discuss with your father the issues
    involved in bringing a larger case against
    all three banks for "serial collusion,"
    or comparable state conspiracy charge

4.  you will begin to investigate Zavala's
    standing with the State of Texas, banking
    commissioner (or equivalent agency)

That's about it for now.

Be well!

/s/ Paul Mitchell,
Counselor at Law


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