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 Cc: Bcc: References: 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 evidence 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 http://supremelaw.com
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