Motion for Stay

fyi
---------------------- Forwarded by Richard B Sanders/HOU/ECT on 11/09/99
08:10 AM ---------------------------

"Kathy D. Patrick" <Kpatrick@Gibbs-Bruns.com< on 11/08/99 09:44:05 PM
To: Richard B Sanders/HOU/ECT@ECT
cc: Scarlett Collings <Scollings@Gibbs-Bruns.com<, "Kathy D. Patrick"
<Kpatrick@Gibbs-Bruns.com<
Subject: Motion for Stay

Richard:

As you know, Glidden filed a motion for stay of proceedings today.
Scarlett is working on an initial draft of a response. I will be in
Austin tomorrow at Graves Dougherty, but she will fax the draft to me
there, I will edit it and we will get something over for you to look at
tomorrow evening.

As we anticipated, what prompted this was our insistence on the
appointment of the third appraiser--so there is no need to reevaluate
our strategy at this stage. We will simply proceed as planned to file a
response in opposition to a stay of the appraisal proceeding and,
simultaneously, a plea in abatement/motion for stay asking the judge to
stay Intrust's common law claims pending the resolution of the appraisal
proceeding.

I will call you to check in with you about mid-day to get your thoughts.
I will also have my cell phone with me, (713) 249-2677, and you can
reach me there if need be.

Thanks,

KP

P.S. - Could I trouble you to forward this on to Gene Humphrey and Mark
Lay? I'd like for them to know the drafting schedule, but I don't have
their e-mail addresses.