in the united states district court for the northern ... · 7/17/2020 · case 3:20-cv-00393-d...

PLAINTIFF’S RESPONSE TO ORDER TO DEMONSTRATE GOOD CAUSE RE: SERVICE

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

THOMAS L. TAYLOR III, solely in his capacity as Court-appointed temporary receiver for Breitling Energy Corporation, et al., Plaintiff, v. REYMOND TREVINO, EAGLE RIO ENERGY COMPANIES, INC., DEREK TAYLOR, ALDEN ADAMS, LLC, NATHAN MADU, and OKOTO OKPO, Defendants.

§ § § § § § § § § § § § § §

Civil Action No. 3:20-cv-00393-D

PLAINTIFF’S RESPONSE TO ORDER TO DEMONSTRATE

GOOD CAUSE RE: SERVICE OF PROCESS

Plaintiff Thomas L. Taylor III (“Receiver”), solely in his capacity as court-appointed

temporary receiver in the case styled SEC v. Faulkner, et al., Case No. 16-cv-1735-D (N.D. Tex.

2016), files this Response (“Response”) to the Court’s June 11, 2020 Order (“Order”) to

demonstrate good cause, in accordance with Rules 4(m) and 6(b) of the Federal Rules of Civil

Procedure (“Rules”), for failing to effect service on defendants Derek Taylor, Alden Adams LLC,

and Nathan Madu (“Defendants”) within 90 days of filing the Complaint. ECF No. 16.1

I. FACTUAL BACKGROUND

The above-styled action was initiated on February 18, 2020. ECF No. 1. The Receiver

commenced with service of the defendants on February 20, 2020, engaging Easy-Serve, LLC

1 To the extent relief under Rule 6(b) requires a motion, the Receiver asks the Court to construe this Response as a motion seeking an extension of time to effect service of process on defendants Derek Taylor, Alden Adams LLC, and Nathan Madu.

Case 3:20-cv-00393-D Document 17 Filed 07/01/20 of 6 PageID 93Case 3:20-cv-00393-D Document 17 Filed 07/01/20 Page 1 of 6 PageID 93

PLAINTIFF’S RESPONSE TO ORDER TO DEMONSTRATE GOOD CAUSE RE: SERVICE PAGE 2

(“ES”) to effect service of process on all individual defendants. Declaration of Kelly Cornelison,

attached hereto as Exhibit 1 (“Cornelison Decl.”), ¶3. Defendants Reymond Trevino, Eagle Rio

Energy Companies, Inc., and Okoto Okpo were timely served and filed their Answer to the

Receiver’s Complaint on May 7, 2020. ECF No. 14.

With respect to Defendant Derek Taylor (“Taylor”), attempts at service were made on

February 27 and 29, 2020. The occupant of the home where service was attempted stated that

Taylor no longer lived at that address but gave his telephone number to the ES process server. The

ES process server spoke by phone with a man that claimed to be a different Derek Taylor than the

defendant Taylor in this case, who gave a purported year of birth (1987) in support of his assertion.

Cornelison Decl. ¶4. The Receiver does not know Taylor’s birth year and if he did he would not

be able to ascertain the truthfulness of the man who spoke by phone to ES, whether or not the birth

years matched. The Receiver’s personnel have instructed ES to attempt service on Taylor at a

newly identified potential address, and are awaiting the outcome of that attempt(s). Id.

With respect to Defendant Nathan Madu (“Madu”), attempts at service were made on

February 22 and 25, 2020 and on April 17, 2020 at separate addresses. Cornelison Decl. ¶5. Based

upon information uncovered by a third-party investigator engaged by ES, additional attempts were

made by ES on June 8, 22, 25 and 27, 2020 at a third address. Id. ¶6. ES’s efforts to serve Madu

based upon the findings of the investigator are ongoing. Id.

With respect to Defendant Alden Adams, LLC (“AA”), the Receiver’s personnel mailed

all relevant documents, including the summons and complaint, to AA’s registered agent by U.S.

Certified Mail, Return Receipt Requested on or about February 21, 2020. Cornelison Decl. ¶7.

However, the return receipt could not be located in a search conducted following entry of the

Court’s Order; most likely it was misplaced due to the abnormal working conditions experienced



by the Receiver’s personnel following self-isolation at the beginning of the COVID-19 pandemic.

Id. ¶8.

Although there is no reason to doubt that the summons and complaint were delivered to

AA’s registered agent shortly after February 21, 2020, out of an abundance of caution the

Receiver’s personnel mailed new copies on June 18, 2020 by U.S. Certified Mail, Return Receipt

Requested (Tracking No. 7015-1730-0002-1240-1123), anticipating delivery confirmation before

this Response to the Order was filed. Tracking information shows that that envelope is still “in

transit” today -- 13 days later -- having been routed through Coppell, TX to Oklahoma City, OK

and back to North Texas. Id. ¶9.

The outbreak of the SARS-CoV-2 virus was declared a global pandemic by the World

Health Organization on March 11, 2020. World Health Organization (WHO), Twitter: @WHO,

March 11, 2020 (accessed on July 1, 2020 at https://twitter.com/WHO/

status/1237777021742338049). Governor Greg Abbott declared a statewide disaster for all

counties in the state of Texas on March 13, 2020. Walters, Edgar (March 13, 2020), Texas

governor declares statewide emergency, says state will soon be able to test thousands, The Texas

Tribune (accessed July 1, 2020 at https://www.texastribune.org/2020/03/13/texas-coronavirus-

cases-state-emergency-greg-abbott/). Also, on March 13, the Northern District of Texas continued

all civil and criminal bench and jury trials scheduled to begin through May 1, 2020. Special Order

No. 13-5 (N.D. Tex. 2020) (accessed July 1, 2020 at http://www.txnd.uscourts.gov/

sites/default/files/documents/COVID19.pdf) (subsequently amended). Like all Texans, the

Receiver, his personnel, and his counsel are experiencing the disruption of everyday life due to the

COVID-19 pandemic and various state and local “stay-at-home” orders, including the closings of

schools and childcare providers. See Scherer, Jasper (March 24, 2020), Here are all the businesses



exempted from Harris County's stay-at-home order, Houston Chronicle (accessed July 1, 2020 at

https://www.houstonchronicle.com/news/houston-texas/houston/article/Here-are-all-the-

businesses-exempted-from-Harris-15154736.php). Indeed Defendants (including AA’s registered

agent) may also be experiencing disruptions of everyday life due to the COVID-19 pandemic,

including the possibility that they are staying at a residence other than their home (such as with

family).

II. ARGUMENT AND AUTHORITY

Rule 4(m) requires a court either to “order that service be made within a specified time”

or “dismiss the action without prejudice against that defendant” “[i]f a defendant is not served

within 90 days after the complaint is filed.” FED. R. CIV. P. 4(m). A court “must extend the time

for service for an appropriate period” “if the plaintiff shows good cause for the failure.” Id.

(emphasis added). Rule 6(b) permits a court, “for good cause, [to] extend the time” in which “an

act … must be done.” FED. R. CIV. P. 6(b).

“Demonstrating good cause requires ‘at least . . . some showing of good faith on the part

of the party seeking an enlargement and some reasonable basis for noncompliance within the time

specified.’” Coach, Inc. v. CM Retail LLC, Civil Action No. 3:09-CV-2215-D, at *2-3 (N.D. Tex.

May 5, 2010) (Fitzwater, J.) (quoting Lambert v. United States, 44 F.3d 296, 299 (5th Cir. 1995)

(internal quotation marks omitted)).

The Receiver has established good faith efforts to effect service on the Defendants. As

demonstrated above, the Receiver initiated attempts to serve the Defendants the week he filed his

complaint. Moreover, the Receiver is continuing his diligence in effecting service on the

Defendants, with attempts currently ongoing with respect to new addresses identified for Madu



and Taylor, and the certified mail follow-up service on AA’s registered agent which appears to be

delayed by the U.S. Postal Service.

The Receiver also has provided reasonable bases for non-compliance with Rule 4’s 90-day

timeline. Although three defendants were quickly located and served, the three Defendants remain

unserved primarily due to out of date address information in Receivership records; delays and

working-condition irregularities related to the COVID-19 pandemic; and potentially purposeful

avoidance of service by Taylor and Madu. See Cornelison Decl. Exhibits B (former resident’s

claim to be a different Derek Taylor) and E (door tag left with contact information on June 22, had

been removed by June 25 attempt). “[A]n extension of time may be warranted if the defendant is

evading service.” Coach, Inc., at *3 (citing La Cantera Dev. Co. v. W. Rim Prop. Servs., 2010 WL

417409, at *2 (W.D. Tex. Jan. 29, 2010)) (finding reasonable inference of avoidance based in part

on contact information removed by the time the server returned for his next attempt).

The Receiver submits that good cause exists for the failure to serve Defendants within the

time limits of Rule 4, and requests that the Court enlarge the time to effect service on the

Defendants by 74 days (to Friday, July 31, 2020), by which date the Receiver will move for leave

to effect substitute service if service has not yet been accomplished.



Dated: July 1, 2020 Respectfully submitted, THE TAYLOR LAW OFFICES, PC Thomas L. Taylor III, Receiver Texas Bar: 19733700 [email protected] 245 West 18th Street Houston, Texas 77008 Tel: 713.626.5300 Fax: 713.402.6154 GOFORTH LAW, PLLC By: /s/ Andrew M. Goforth

Andrew M. Goforth Texas State Bar: 24076405 [email protected] 7614 Fairdale Lane Houston, Texas 77063 Tel: (713) 464-2263 Fax: (713) 583-1762 COUNSEL FOR RECEIVER

CERTIFICATE OF SERVICE

I certify that on July 1, 2020 I filed the foregoing document through the Court’s CM/ECF system, which delivered electronic notice to all counsel of record. /s/ Andrew M. Goforth

Andrew M. Goforth


DECLARATION OF KELLY CORNELISON

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

THOMAS L. TAYLOR III, solely in his capacity as Court-appointed temporary receiver for Breitling Energy Corporation, et al.,

Plaintiff,

v.

REYMOND TREVINO, EAGLE RIO ENERGY COMPANIES, INC., DEREK TAYLOR, ALDEN ADAMS, LLC, NATHAN MADU, and OKOTO OKPO,

Defendants.

§ § § § § § § § § § § § § §

Civil Action No. 3:20-cv-393-D

DECLARATION OF KELLY CORNELISON

I, Kelly Cornelison, do hereby declare under penalty of perjury, in accordance with 28

U.S.C. § 1746, that the following is true and correct, and that I am competent to testify to the

matters stated herein:

1. I am employed by The Taylor Law Offices, P.C. as an administrative assistant to

Thomas L. Taylor III.

2. Mr. Taylor (“Receiver”) has been appointed as receiver in the case styled SEC v.

Faulkner, et al., Case No. 16-cv-1735-D (N.D. Tex. 2016), and in his capacity as receiver is the

plaintiff in the above-styled case. I make this Declaration in support of the Receiver’s Response

(“Response”) to the Court’s June 11, 2020 Order (“Order”) for the Receiver to demonstrate good

cause, in accordance with Rules 4(m) and 6(b), for failing to effect service on defendants Derek

EXHIBIT 1

Case 3:20-cv-00393-D Document 17-1 Filed 07/01/20 Page 1 of 4 PageID 99Case 3:20-cv-00393-D Document 17-1 Filed 07/01/20 Page 1 of 4 PageID 99

DECLARATION OF KELLY CORNELISON PAGE 2

Taylor, Alden Adams LLC, and Nathan Madu within 90 days of filing his Complaint. ECF No.

16.1

3. This case was initiated on February 18, 2020 through the filing of the Complaint.

On February 20, 2020, I engaged Easy-Serve, LLC (“ES”) to effect service of process on the

defendants in this case at their last-known addresses based upon Receivership records. Exhibit A

to this declaration is a true and correct copy of an email from me to ES requesting they commence

service of process on the defendants.

4. ES attempted to serve defendant Derek Taylor (“Taylor”) on February 27 and 29,

2020 at 7253 Retriever Ln., Fort Worth, TX 76120. ES discovered that Taylor no longer lived at

that address. The current owner/occupant gave ES a telephone number for Taylor. A man claiming

to be a different Derek Taylor than the defendant Taylor in this case spoke by phone with the ES

process server and gave a purported year of birth (1987) in support of his assertion. See Declaration

of Carol Tharp of Due Diligence, a true and correct copy of which is attached to this declaration

as Exhibit B. I subsequently have instructed ES to attempt service on Taylor at a newly identified

potential address, and await the outcome of that attempt(s).

5. ES attempted to serve defendant Nathan Madu (“Madu”) on February 22 and 25,

2020 at 817 Clement Dr, Cedar Hill, TX 75104; and on April 17, 2020 at 4207 Live Oak St, Dallas,

TX 75204. See, respectively, Declaration of Mitchell Draeger of Due Diligence, a true and correct

copy of which is attached to this declaration as Exhibit C; Declaration of Guy Connelly of Due

Diligence, a true and correct copy of which is attached to this declaration as Exhibit D.

6. With my permission, ES subsequently contracted a third-party investigator to locate

Madu for the purpose of effecting service of process on him. Based upon that investigation, ES

1 Capitalized terms not defined herein have the same meaning given to them in the Response.



attempted, unsuccessfully, to serve Madu on June 8, 22, 25 and 27, 2020 at 7878 Marvin D. Love

Freeway #2301, Dallas, TX 75237. See Declaration of Mitchell Draeger of Due Diligence, a true

and correct copy of which is attached to this declaration as Exhibit E. ES’s efforts to serve Madu

based upon the findings of the investigator are ongoing.

7. With respect to service of defendant Alden Adams, LLC (“AA”), its registered

agent in the state of Texas is Melba A. Spence, whose address is 2831 Beverly Dr., Rockwall, TX

75032. Exhibit F to this declaration is a true and correct copy of the Texas Secretary of State

Business Organizations Entity page, registered agent tab, for AA, accessed July 1, 2020. On or

about February 21, 2020 I mailed all relevant documents, including the summons and Complaint,

to AA’s registered agent by U.S. Certified Mail, Return Receipt Requested.

8. After the Court entered its Order I searched for, but was unable to locate, the return

receipt of service to AA’s registered agent. After mailing the summons and complaint to AA’s

registered agent, I spent approximately 27 days self-isolating at home due to the COVID-19

pandemic. After my initial return to the office following self-isolation, I primarily have worked

from home and have regularly transported work papers between my home and the office. It is

likely that the return receipt was misplaced due to my abnormal working conditions since the

beginning of the pandemic.

9. Although I have no reason to doubt that the summons and Complaint were delivered

to AA’s registered agent shortly after February 21, 2020 (for example, they have not been returned

undelivered by the U.S. Postal Service), out of an abundance of caution I mailed new copies on

June 18, 2020 by U.S. Certified Mail, Return Receipt Requested (Tracking No. 7015-1730-0002-

1240-1123), anticipating delivery confirmation before the Receiver’s Response to the Order was

filed. Tracking information shows that that envelope is still “in transit” 13 days later, having been



routed through Coppell, TX to Oklahoma City, OK and back to North Texas. See Exhibit G to

this declaration, a true and correct copy the USPS Tracking webpage (accessed July 1, 2020).

I declare under penalty of perjury that the foregoing is true and correct.

Executed by electronic signature on July 1, 2020.

/s/ Kelly Cornelison Kelly Cornelison


1

Andrew M. Goforth

From: Kelly Cornelison <[email protected]>Sent: Thursday, February 20, 2020 3:00 PMTo: Info@easy-serveCc: Andrew M. Goforth; Thomas L. Taylor IIISubject: Service of Summons in Dallas/Forth WorthAttachments: Trevino Summons and Papers.pdf; Eagle Rio Energy Summons and Papers.pdf; Taylor Summons and

Papers.pdf; Madu Summons and Papers.pdf; Okpo Summons and Papers.pdf

Hello!

I need some people served in the Dallas/Fort Worth area. I have included the packet to be served for each person and entity.

1. Okoto Okpo to be served at:3704 MiramarDenton, Texas 76210

2. Nathan Madu to be served at:817 Clement Dr.Cedar Hill, TX 75104

3. Derek Adam Taylor to be served at:7253 Retriever Ln.Fort Worth, TX 76120

4. Reymundo Saenz Trevino3705 Bryce Ave.Fort Worth, Texas 76107

5. Eagle Rio Energy Companies to be served on Reymundo Trevino at:3705 Bryce Ave.Fort Worth, Texas 76107

On the skip trace I have for Trevino, it shows his last known address at Bryce Avenue. I recently mailed something to him and it was returned to sender with no reason, so I’m not sure if he is still at this address and just not accepting it, or if he no longer lives there.

None of these recipients are friendly, as they have refused to answer any of our letters threatening suit. Please let me know if you need anything further.

Thank you,

Kelly CornelisonThe Taylor Law Offices, P.C. �� !�� EXHIBIT A


2

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CAUSE NO. 3:20-CV-00393-D

THOMAS L TAYLOR III, SOLELY IN HIS CAPACITY AS RECEIVER FOR BREITLING ENERGY CORP., ET ALPLAINTIFF

VS.

REYMOND TREVINO, ET ALDEFENDANT

§§§§§§§§§§

IN THE US District Court, Northern District of Texas

DECLARATION OF Carol Tharp OF DUE DILIGENCE

ON Friday, February 21, 2020 AT 9:36 AMSUMMONS IN A CIVIL ACTION, PLAINTIFF'S NOTICE OF ERRATA, PLAINTIFF'S ORIGINAL COMPLAINT, PLAINTIFF'S CERTIFICATE OF INTERESTED PARTIES, PLAINTIFF'S NOTICE OF RELATED CASE for service on DEREK TAYLOR came to hand.

My name is Carol Tharp. I am over the age of eighteen and am not a party to this case. I declare under penalty of perjury that the foregoing is true and correct.

/S/ Carol Tharp

Carol TharpProcess Server1201 Louisiana, Suite 370Houston, TX 77002

On Thursday, February 27, 2020 at 5:44 PM, at 7253 RETRIEVER LN, FORT WORTH, TX 76120, Went to stated address, knocked on door, no answer. Left card, no return call.

On Saturday, February 29, 2020 at 5:45 PM, at 7253 RETRIEVER LN, FORT WORTH, TX 76120, Went to stated address, knocked on door, no answer. Left card. Received call from Pete Xagoraris - 408-661-2156 -- who stated he purchased this residence in August, 2019. He also stated Taylor does notlive here and he does not know where Taylor lives, but had phone contact with him as he was theprevious tenant of this residence. Received call from Derek Cole Taylor - 817-471-8569 - who stated hedoes not live at above address, and that he is the wrong Derek Taylor. He provided his full name andyear of birth of 1987 - and his phone number - 817-471-8569.

3:20-cv-00393-D

Doc ID: 271317_3

EXHIBIT B




VS.


§§§§§§§§§§


DECLARATION OF Mitchell Draeger OF DUE DILIGENCE

ON Friday, February 21, 2020 AT 9:36 AMSUMMONS IN A CIVIL ACTION, PLAINTIFF'S NOTICE OF ERRATA, PLAINTIFF'S ORIGINAL COMPLAINT, PLAINTIFF'S CERTIFICATE OF INTERESTED PARTIES, PLAINTIFF'S NOTICE OF RELATED CASE for service on NATHAN MADU came to hand.

My name is Mitchell Draeger. I am over the age of eighteen and am not a party to this case. I declare under penalty of perjury that the foregoing is true and correct.

/S/ Mitchell Draeger

Mitchell DraegerProcess Server129 FALLEN ROCK DR.

On Saturday, February 22, 2020 at 6:20 PM, at 817 CLEMENT DR, CEDAR HILL, TX 75104, No answer at the door. No answer at the neighbors. No vehicles in the driveway. I left a door tag.

On Tuesday, February 25, 2020 at 12:05 PM, at 817 CLEMENT DR, CEDAR HILL, TX 75104, I spoke with Chaneen Hampton, who said that the defendant does not live there, and hasn't for over a year, and does not have contact info for him. Again, no answer at neighboring residences.

3:20-cv-00393-D

Doc ID: 271317_4

EXHIBIT C




VS.


§§§§§§§§§§


DECLARATION OF Guy Connelly OF DUE DILIGENCE

ON Thursday, April 16, 2020 AT 3:19 PMSUMMONS IN A CIVIL ACTION, PLAINTIFF'S NOTICE OF ERRATA, PLAINTIFF'S ORIGINAL COMPLAINT, PLAINTIFF'S CERTIFICATE OF INTERESTED PARTIES, PLAINTIFF'S NOTICE OF RELATED CASE for service on NATHAN MADU came to hand.

My name is Guy Connelly. I am over the age of eighteen and am not a party to this case. I declare under penalty of perjury that the foregoing is true and correct.

/S/ Guy Connelly

Guy ConnellyProcess Server2701 W 15TH STREET SUITE 567PLANO, TX 75075

On Friday, April 17, 2020 at 10:55 AM, at 4207 LIVE OAK ST, DALLAS, TX 75204, This address is a secured apartment complex called the Vue, and no apartment number was provided. I went to the management office and spoke with Johnny, who checked his computer back to 2016 and said they have never had a resident by that name.

3:20-cv-00393-D

Doc ID: 271317_9

EXHIBIT D


DECLARATION OF Mitchell Draeger OF DUE DILIGENCE

On Thursday, June 4, 2020 at 06:55 AM

SUMMONS IN A CIVIL ACTION, PLAINTIFF'S NOTICE OF ERRATA, PLAINTIFF'S ORIGINAL COMPLAINT, PLAINTIFF'S CERTIFICATE OF INTERESTED PARTIES, PLAINTIFF'S NOTICE OF RELATED CASE for service on NATHAN MADU came to hand.

On Monday, June 8, 2020 at 04:10 PM, at 7878 MARVIN D. LOVE FREEWAY #2301, DALLAS, DALLAS COUNTY, TX 75237 No answer at the door. No answer at the neighbors. The leasing office is closed.On Monday, June 22, 2020 at 10:25 AM, at 7878 MARVIN D. LOVE FREEWAY #2301, DALLAS, DALLAS COUNTY, TX 75237 No answer at the door. No answer at the neighbors. The leasing office is closed due to virus. I left a door tag for someone to call me.On Thursday, June 25, 2020 at 07:50 AM, at 7878 MARVIN D. LOVE FREEWAY #2301, DALLAS, DALLAS COUNTY, TX 75237 No answer at the door. No lights on inside the apartment. No answer at the neighbors. I left a door tag for someone to call me.On Saturday, June 27, 2020 at 02:40 PM, at 7878 MARVIN D. LOVE FREEWAY #2301, DALLAS, DALLAS COUNTY, TX 75237 No answer at the door. My door tag was still attached. No return calls as of this update

My name is Mitchell Draeger. My address is 129 FALLEN ROCK DR.. I am a private process server authorized by and through the Texas Judicial Branch Certification Commission (PSC 7995, expires Friday, December 31, 2021). My e-mail address is [email protected]. My date of birth is April 29, 1961. I am in all ways competent to make this declaration, which is based on personal knowledge. I am not a party to this case, and have no interest in its outcome. I declare under penalty of perjury that the foregoing is true and correct. This declaration is made in conformity with Texas Civil Practice and Remedies Code § 132.001.

Executed in Waxahachie County, Texas on Saturday, June 27, 2020.

/S/ MITCHELL DRAEGER


IN THE US DISTRICT COURT, NORTHERNDISTRICT OF TEXAS

____________________ COUNTY, FD

THOMAS L TAYLOR III, SOLELY IN HIS CAPACITY AS RECEIVER FOR BREITLING ENERGY CORP., ET AL,PLAINTIFF

VS.

REYMOND TREVINO, ET AL,DEFENDANT

§§§§§§§§

DocID: 271317-012

Client Reference#: 3:20-cv-00393-D

EXHIBIT E


7/1/2020 BUSINESS ORGANIZATIONS INQUIRY - VIEW ENTITY

https://direct.sos.state.tx.us/corp_inquiry/corp_inquiry-entity.asp?spage=ra&:Spagefrom=&:Sfiling_number=802965521&:Ndocument_number=980289… 1/1

SOSDirect Session Extended

BUSINESS ORGANIZATIONS INQUIRY - VIEW ENTITY

Filing Number: 802965521 Entity Type: Domestic Limited Liability Company (LLC) Original Date of Filing: March 19, 2018 Entity Status: In existence Formation Date: N/A Tax ID: 32066586515 FEIN: Duration: Perpetual

Name: Alden Adams LLC Address: 494 CHANDLER CT

FATE, TX 75189-5066 USA

REGISTERED AGENT FILING HISTORY NAMES MANAGEMENT ASSUMED NAMES ASSOCIATED ENTITIES

Name Address Inactive Date Melba A Spence 2831 Beverly Dr

Rockwall, TX 75032 USA

Order Return to Search

Instructions: To place an order for additional information about a filing press the 'Order' button.

EXHIBIT F


https://direct.sos.state.tx.us/corp_inquiry/corp_inquiry-entity.asp?spage=ra&:Spagefrom=&:Sfiling_number=802965521&:Ndocument_number=980289050002&:Npgcurrent=1&:Norder_item_type_id=10

https://direct.sos.state.tx.us/corp_inquiry/corp_inquiry-entity.asp?spage=docs&:Spagefrom=&:Sfiling_number=802965521&:Ndocument_number=980289050002&:Npgcurrent=1&:Norder_item_type_id=10

https://direct.sos.state.tx.us/corp_inquiry/corp_inquiry-entity.asp?spage=names&:Spagefrom=&:Sfiling_number=802965521&:Ndocument_number=980289050002&:Npgcurrent=1&:Norder_item_type_id=10

https://direct.sos.state.tx.us/corp_inquiry/corp_inquiry-entity.asp?spage=mgmt&:Spagefrom=&:Sfiling_number=802965521&:Ndocument_number=980289050002&:Npgcurrent=1&:Norder_item_type_id=10

https://direct.sos.state.tx.us/corp_inquiry/corp_inquiry-entity.asp?spage=an&:Spagefrom=&:Sfiling_number=802965521&:Ndocument_number=980289050002&:Npgcurrent=1&:Norder_item_type_id=10

https://direct.sos.state.tx.us/corp_inquiry/corp_inquiry-entity.asp?spage=ae&:Spagefrom=&:Sfiling_number=802965521&:Ndocument_number=980289050002&:Npgcurrent=1&:Norder_item_type_id=10

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