Doc1031 pay day for lynn tillotson pinker & cox $189,945.99

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#4814-6499-0756
Jeffrey M. Tillotson, P.C. (jmt@lynnllp.com)
Texas Bar No. 20039200
Eric W. Pinker, P.C. (epinker@lynnllp.com)
John Volney (jvolney@lynnllp.com)
LYNN TILLOTSON PINKER & COX, L.L.P.
2100 Ross Avenue, Suite 2700
Dallas, Texas 75201
(214) 981-3800 Telephone
(214) 981-3839 Facsimile
ATTORNEYS FOR MATTHEW D. ORWIG, LIQUIDATING TRUSTEE
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
In re: § Chapter 11
§
FIRSTPLUS FINANCIAL GROUP, INC., § Case No. 09-33918-HDH
§
Debtor. §
______________________________________________________________________________
FOURTH APPLICATION OF LYNN TILLOTSON PINKER & COX, LLP FOR
ALLOWANCE OF COMPENSATION AND FOR REIMBURSEMENT OF EXPENSES
INCURRED FROM MAY 1, 2014 THROUGH MAY 31, 2015
______________________________________________________________________________
NO HEARING WILL BE CONDUCTED ON THIS APPLICATION UNLESS A
WRITTEN RESPONSE IS FILED WITH THE CLERK OF THE UNITED
STATES BANKRUPTCY COURT, 1100 COMMERCE STREET, SUITE 1254,
DALLAS, TEXAS 75242, BEFORE 5:00 P.M. PREVAILING CENTRAL TIME
ON JULY 7, 2015, (THE “OBJECTION DEADLINE”), WHICH IS AT LEAST
TWENTY-FOUR DAYS AFTER THE DATE OF SERVICE OF THIS
APPLICATION.
ANY RESPONSE MUST BE IN WRITING AND FILED WITH THE CLERK,
AND A COPY MUST BE SERVED UPON THE UNDERSIGNED COUNSEL
PRIOR TO THE DATE AND TIME SET FORTH ABOVE.
IF A RESPONSE IS TIMELY FILED, A HEARING MAY BE HELD WITH
NOTICE ONLY TO THE OBJECTING PARTY. IF NO RESPONSE TO THIS
APPLICATION IS TIMELY FILED, THE RELIEF SOUGHT HEREIN SHALL
BE DEEMED TO BE UNOPPOSED, AND THE COURT MAY ENTER AN
ORDER GRANTING SUCH RELIEF.
Case 09-33918-hdh11 Doc 1031 Filed 06/11/15 Entered 06/11/15 12:36:39 Page 1 of 19

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#4814-6499-0756
Lynn Tillotson Pinker & Cox, LLP (“LTPC,” the “Firm” or the “Applicant”), special
litigation counsel to Matthew D. Orwig, the liquidating Trustee (“Trustee”) for the estate of
FirstPlus Financial Group, Inc. (the “Debtor”), files this Fourth Application of Lynn Tillotson
Pinker & Cox, LLP for Allowance of Compensation and for payment of Expenses Incurred from
May 1, 2014 through May 31, 2015 (this “Application”).
I. SUMMARY OF APPLICATION
By this Application, LTPC seeks approval for payment of its attorney’s fees in the
amount of $183,333.33, which reflects LTPC’s one-third contingency fee interest in the
Trustee’s settlement with Buckno Lisicky & Company, P.C. and Anthony Buczek, which has
been filed for approval by this Court pursuant to Bankruptcy Rule 9019. [Docket No. 1029]. In
addition to its contingency fee, LTPC requests reimbursement of its expenses incurred from
May 1, 2014 through May 31, 2015 (the “Application Period”) in the amount of $6,542.66. The
total amount sought by LTPC in this Application is $189,875.99. For the reasons set out below,
LTPC respectfully requests that the Court grant this Application.
II. JURISDICTION AND VENUE
1. The Court has jurisdiction over the relief requested in this Application pursuant to
28 U.S.C. § 1334(a) and (b). Venue is proper in this District pursuant to 28 U.S.C. §§ 1408 and
1409(a).
2. The statutory predicates for the relief requested herein are 11 U.S.C. §§ 327-328
and 330 and Fed. R. Bankr. P. 2016.

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#4814-6499-0756
III. BACKGROUND
3. On June 23, 2009, FirstPlus Financial Group, Inc. (“Debtor”) filed its petition for
relief under Chapter 11 of the United States Code.
4. On July 24, 2009, the Court entered its Order appointing Matthew D. Orwig as
the Liquidating Trustee for the Debtor.
5. On April 29, 2011, the Trustee filed an application to employ LTPC as special
counsel to the Trustee in this Bankruptcy Case. [Docket No. 565].
6. On May 12, 2011, the Court entered its order granting the application and
authorizing employment of LTPC. [Docket No. 572]. As relevant to this Application, the
Court’s Order authorized the Trustee to employ LTPC as Special Litigation Counsel to evaluate
and pursue claims against the former professionals, fiduciaries and others affiliated with Debtor.
The Order provided that LTPC would be paid (1) a reduced hourly rate up to a total of $25,000
to evaluate the potential claims and then (2) one-third of any net monetary recovery by the Estate
pursuant to a standard contingency fee arrangement if claims were pursued. The Order further
provided that LTPC would credit the estate for any payment made pursuant to the reduced hourly
arrangement in the event that LTPC recovered under the contingency fee arrangement, which
credit was taken when the Court approved LTPC’s Second Application. [Docket No. 572].
Under the Court’s order, all compensation for fees and expenses were made subject to Court
approval under section 330 of the Bankruptcy Code, the federal and local rules of bankruptcy
procedures, and other applicable guidelines and case law. LTPC’s Application is supported by
the Affidavit of John Volney attached as Exhibit A.

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#4814-6499-0756
A. Summary of Work Performed and Results Achieved.
7. In June 2011, the Trustee (represented by LTPC) filed Adversary Proceeding
No. 11-03397 against former professionals and others affiliated with Debtor, including Buckno
Lisicky & Company, P.C. and Anthony Buczek. Mr. Buczek and Buckno Lisicky & Company,
P.C. answered the lawsuit and filed motions to dismiss and to withdraw the reference in January
2015. After responding to the various motions filed by the referenced defendants, the Trustee
negotiated and reached a monetary settlement with Buckno Lisicky & Company, P.C. and
Anthony Buczek in the amount of $550,000.00. On May 6, 2015, the Trustee filed his motion
for order approving the settlement. [Docket No. 1029].
B. Summary of Expenses Incurred.
8. In providing professional services to the Trustee, LTPC has incurred actual and
necessary expenses in satisfaction of which LTPC has advanced and disbursed funds, and for
which LTPC now requests reimbursement. As set forth in the invoice attached as Exhibit B, the
actual and necessary expenses incurred by LTPC on behalf of the Trustee during the Application
Period amount to $6,542.66. The expenses incurred by LTPC are charged at the actual cost by
LTPC on a pass-through basis, with no mark-up or profit by LTPC. The expenses sought to be
reimbursed include the following categories:
• Transcripts from Crim. Trial $3,571.50
• Westlaw/Internet Search Service $1,005.86
• Copies/Duplication Costs $ 4.20
• Postage $ 175.34
• Court Parking $ 8.00
• Travel Expenses for Attendance at Criminal Trial $1,777.76
Total: $6,542.66
The Invoice sets forth the date the expense was incurred or billed and the nature and
amount of the expense. No request is made for overhead expenses. The bulk of the expenses

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#4814-6499-0756
sought to be reimbursed is related to obtaining transcripts of certain testimony from the parallel
criminal trial, which the undersigned counsel believed was necessary to successfully evaluate the
case for settlement. Travel expenses were incurred in connection with attending closing
arguments at the criminal trial. Copies were necessary to serve pleadings on various parties and
to disseminate documents to various interested parties. Throughout this case, pleadings have
been served on the parties in interest. A copy service was used when it could provide services
more cheaply than LTPC could provide the same services in-house. LTPC incurred postage
charges in connection with service of documents on certain defendants who are not subscribers
to the Court’s ECF system. Computerized research has been utilized only when a professional
believes that the benefits of computerized research outweigh the cost of such research and that
the costs will be less than those incurred in utilizing more traditional research methods.
Necessary computerized research was extensive.
IV. RELIEF REQUESTED
9. By this Application, LTPC respectfully requests that the Court allow
compensation for professional services rendered by LTPC during the Application Period
pursuant to 11 U.S.C. § 330. In total, this Application requests allowance of compensation in the
amount of $183,333.33, along with expenses incurred during the Application Period of
$6,542.66 , for a total requested allowance of $189,875.99.
10. The Bankruptcy Code specifically authorizes the bankruptcy court to approve the
employment and compensation of special counsel on a contingency fee basis. 11 U.S.C.
§ 328(a); Daniels v. Barron (In re Barron), 325 F.3d 690 (5th Cir.2003) (“Under 11 U.S.C.
§ 330, attorneys’ fees are reviewed for their reasonableness after representation has concluded.
In contrast, Section 328 ... allows an attorney seeking to represent a bankruptcy estate to obtain

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#4814-6499-0756
prior court approval of her compensation plan.”). As explained above, the Trustee (represented
by LTPC) filed suit against and then settled with Buckno Lisicky & Company, P.C. and Anthony
Buczek in cash. Upon approval of the settlement, the net monetary recovery to the Liquidating
Trust will be $550,000.00, with LTPC owed a contingent fee of $183,333.33.
11. To the extent that Court considers the factors listed in Johnson v. Georgia
Highway Express, Inc., 488 F.2d 714, 717–19 (5th Cir. 1974) (the “Johnson Factors”) in
evaluation LTPC’s requested contingent fee, those factors support the award.
12. The Time and Labor Required. LTPC’s fee was a contingent fee for the work
performed. LTPC provided its services efficiently to allow the Trustee to continue this
bankruptcy case without undue delay.
13. The Novelty and Difficulty of the Questions Presented. LTPC’s employment
required them to perform services within their area of expertise, namely litigating business tort
claims against Debtor’s former lawyer and his law firm.
14. The Skill Required to Perform the Services. LTPC believes that its skill in
litigating business tort claims such as the claims alleged against Buckno Lisicky & Company,
P.C. and Anthony Buczek contributed substantially to the settlement.
15. Preclusion of Other Employment Due to Acceptance of the Case. While
LTPC has devoted substantial time and effort to its representation of the Trustee in the adversary
proceeding, LTPC has not been precluded from accepting other employment.
16. The Customary Fee. The amount of compensation sought herein has been
computed pursuant to a customary contingent fee. The fee charged for LTPC’s services in this
case is equal to or less than the rates charged by other professionals of similar reputation.

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#4814-6499-0756
17. Whether the Fee is Fixed or Contingent. LTPC’s fee is set according to the
contingent fee agreement, as previously approved by the Court.
18. Time Limitations Imposed by the Client or Other Circumstances. The best
interests of the creditors were served by pushing the case and settlement forward in order to
minimize expenses.
19. The Experience, Reputation, and Ability of the Applicant. LTPC submits that
it is respected for its skill in litigating business disputes. It is the Applicant’s belief that its
reputation is recognized and respected.
20. The “Undesirability” of the Case. Working on behalf of the Trustee in this case
has not been undesirable. However, LTPC’s fee is subject to approval by the Court and is
contingent upon a recovery.
21. The Nature and Length of the Professional Relationship with the Client.
LTPC worked with the Trustee throughout the existence of the adversary proceeding. LTPC had
no prior dealings with the Debtor or the Trustee.
22. The Amount Involved and the Results Obtained. The amount of LTPC’s
contingent fee is calculated pursuant to the methodology previously approved by the Court.

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#4814-6499-0756
V. COMPLIANCE WITH FED. R. BANK. P. 2016(a)
23. LTPC does not now hold or represent, and has not held or represented at any time
during the Application Period or otherwise, any interest adverse to the Trustee or the Estate with
respect to the matters for which it has been employed. LTPC is now, and has at all times
material hereto been, a “disinterested person” as that term is used and defined in the Bankruptcy
Code.
24. This is LTPC’s Fourth Application for payment of attorney’s fees and
reimbursement of expenses. LTPC received $1,290,447.00 in attorney’s fees and expenses
pursuant to its First, Second, and Third Applications.
25. No agreement or understanding exists between the Applicant and any other entity
for sharing of compensation received or to be received for services rendered in or in connection
with this Bankruptcy Case. Applicant shall not share or agree to share with any other entity the
compensation awarded in connection with this Application, if any.
26. No agreement or understanding prohibited by 18 U.S.C. § 155 has been made, or
will be made, by LTPC.
VI. NOTICE
27. A copy of this Application, together with exhibits, is being transmitted, inter alia,
(i) electronically by the Clerk of Court through the CM/ECF system to all parties receiving such
notice in this Bankruptcy Case and (ii) to the Office of the United States Trustee. A copy of this
Application without exhibits is being sent via regular United States mail, postage prepaid, to the
parties appearing on the master mailing matrix for this case. Accordingly, all parties entitled to
receive notice of this Application have received such notice. LTPC respectfully submits that no
additional notice of this Application is necessary under the circumstances.

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#4814-6499-0756
28. Any party that was not served with a copy of the exhibits to this Application
may obtain a copy of such exhibits by mailing a written request to the undersigned counsel
on or before the Objection Deadline set forth on the first page of this Application.
VII. PRAYER
BASED UPON THE FOREGOING, LTPC respectfully requests that the Court enter an
order in substantially the form of that attached hereto as Exhibit C:
i. granting this Application;
ii. allowing compensation for professional services rendered by LTPC as
special counsel to the Trustee during the Application Period in the total
amount of $183,333.33;
iii. allowing reimbursement of LTPC’s expenses in the amount of $6,542.66;
and
iv. awarding Applicant such other and further relief to which it may be justly
entitled.
Date: June 11, 2015 Respectfully submitted,
/s/ John Volney
Dallas, Texas 75201
(214) 981-3800 Telephone
(214) 981-3839 Facsimile
ATTORNEYS FOR MATTHEW D. ORWIG,
LIQUIDATING TRUSTEE

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#4814-6499-0756
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the above and foregoing
document has been served either via ECF on counsel of record or via first class United States
mail, prepaid, on the attached Limited Service List on June 11, 2015.
/s/ John Volney
John Volney

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#4821-8596-0228
Dallas, Texas 75201
(214) 981-3800 Telephone
(214) 981-3839 Facsimile
ATTORNEYS FOR MATTHEW D. ORWIG, LIQUIDATING TRUSTEE
DALLAS DIVISION
§
§
Debtor. §
______________________________________________________________________________
AFFIDAVIT OF JOHN VOLNEY IN SUPPORT OF THE FOURTH APPLICATION OF
LYNN TILLOTSON PINKER & COX, LLP FOR ALLOWANCE OF COMPENSATION
AND FOR REIMBURSEMENT OF EXPENSES
______________________________________________________________________________
STATE OF TEXAS §
§
COUNTY OF DALLAS §
BEFORE ME, the undersigned authority, on this date appeared John Volney (“Affiant”)
and, after having been first duly sworn, stated as follows:
1. “My name is John Volney. I am over the age of twenty-one (21) and competent
in all respects to make this Affidavit. This Affidavit is being filed in support of the Fourth
Application of Lynn Tillotson Pinker & Cox, LLP for Allowance of Compensation and for
Reimbursement of Expenses (the “Application”) filed contemporaneously herewith.
2. I am making this Affidavit on behalf of Lynn Tillotson Pinker& Cox, LLP
(“LTPC”). I am a partner at LTPC and I am authorized to make this affidavit on behalf of LTPC.
3. Pursuant to the Court’s order of May 12, 2011, LTPC was retained by Matthew
D. Orwig, the Liquidating Trustee (the “Trustee”) for the estate (the “Estate”) of FirstPlus
Financial Group, Inc. (the “Debtor”) as Special Litigation Counsel pursuant to a reduced hourly
and contingent fee arrangement.
EXHIBIT A

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#4821-8596-0228
4. I am the professional designated by the Firm with responsibility for compliance
with the applicable Guidelines for Compensation and Expense Reimbursement of Professionals
promulgated by the Court and by the Office of the United States Trustee.
5. I have read the Application. To the best of my knowledge, information, and
belief, the compensation and expense reimbursement sought therein is in substantial and
satisfactory conformity with the Guidelines.
6. As relevant to this application, LTPC is to be paid a one-third contingency fee
based on the net monetary recovery that LTPC obtains for the Estate against former professionals
and fiduciaries of Debtor and others, less the amount previously paid to LTPC pursuant to its
reduced hourly fee arrangement. The amount previously paid to LTPC pursuant to its reduced
hourly fee arrangement was recouped in connection with LTPC’s Second Application and is
therefore not relevant to this Fourth Application.
7. LTPC assisted the Trustee in the matters described in the Application. The work
LTPC performed was reasonable and was necessary to comply with its representation of the
Trustee in Adversary Proceeding No. 11-03397. LTPC brought suit against (among others)
Buckno Lisicky & Company, P.C. and Anthony Buczek for alleged accounting malpractice,
conspiracy, and other claims. After Buckno Lisicky & Company, P.C. and Anthony Buczek
filed motions to dismiss, and after responses were filed on behalf of the Trustee, the Trustee
represented by LTPC had extensive settlement negotiations with those defendants, which
resulted in the parties’ reaching a negotiated settlement. On May 6, 2015, the Trustee filed his
motion seeking approval of his settlement with Buckno Lisicky & Company, P.C. and Anthony
Buczek. Upon approval of the settlement and payment of settlement proceeds, the net monetary
recovery to the Estate will be $550,000.00. LTPC’s contingent fee based on that recovery is
$183,333.33, which is one-third of the recovery.
8. The contingent fee LTPC charged in this matter is less than or equal to its
customary fees. I am generally familiar with the rates charged by other law firms for services
such as those that LTPC performed for the Trustee. The contingent fee LTPC charged in this
matter is less than or equal to those charged by comparable professionals for similar services.
9. Attached to the Application as Exhibit B is a true and correct copy of the Firm’s
invoice for expenses incurred during the Application Period in connection with its role as special
litigation counsel to the Trustee this case (the ‘Invoice’).

Attorneys and Counselors
2100 ROSS AVE., SUITE 2700
Dallas, TX 75201
214-981-3800
Invoice submitted to:
Jones Day
Attn. Matthew D. Orwig, Trustee
2727 N. Harwood St.
Dallas, TX 75201
June 10, 2015
Invoice #: 20150980
In Reference
To:
FirstPlus Financial Group, Inc. Trustee Action
Our Client/Matter No.: 02372-101.
Tax I.D.#: 75-2507536
TERMS: NET 30 DAYS
Additional charges:
Amount
5/31/2014 174.68Westlaw Research for May 2014.
6/9/2014 53.60Reimbursement paid to Mr. Volney for travel expenses for trial in New
Jersey ($40 airport parking, $13.60 for meal for Mr. Volney and B.
Ghorayeb, $10.00 in tolls).
6/22/2014 1,077.00Airfare for FirstPlus Criminal trial in PA, 5/30/14.
40.00Meal for Mr. Volney during FirstPlus Criminal trial in PA, 6/3/14.
300.46Hertz car rental during FirstPlus Criminal trial in PA, 6/4/14.
306.70Hotel fee for Mr. Volney during FirstPlus Criminal trial in PA, 6/5/14.
6/30/2014 4.20Copy charges.
84.62Postage fees.
7/31/2014 2.40Postage fees.
8/18/2014 1,500.00Reimbursement paid to Mr. Volney for Anthony Buczek transcripts.
8/31/2014 0.48Postage fees.
9/29/2014 2,071.50Fee for transcripts of David Roberts and Robert O'Neal made payable to Carl
Nami.
EXHIBIT B

Jones Day 2Page
Amount
9/30/2014 71.98Westlaw Research for September 2014.
10/31/2014 0.48Postage fees.
11/30/2014 469.78Westlaw research for November 2014.
1/20/2015 8.00Reimbursement for Mr. Volney for parking at courthouse for status
conference, 1/13/15.
2/28/2015 149.11Westlaw research for February 2015.
3/31/2015 45.03Westlaw research for March 2015.
5/31/2015 87.36Postage fees.
95.28Westlaw research for May 2015
Total costs $6,542.66
Lynn Tillotson Pinker & Cox, L.L.P. - Tax I.D. #: 75-2507536.

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#4851-3907-7924
DALLAS DIVISION
§
§
Debtor. §
ORDER ALLOWING FOURTH APPLICATION OF
LYNN TILLOTSON PINKER & COX, LLP FOR ALLOWANCE OF
COMPENSATION AND REIMBURSEMENT OF EXPENSES
FOR THE PERIOD FROM MAY 1, 2014 THROUGH MAY 31, 2015
Came on for consideration on July ___, 2015, the Fourth Application of Lynn Tillotson
Pinker & Cox, LLP for Allowance of Compensation and Reimbursement of Expenses (the
“Application”) filed on June 11, 2015 [Docket No. ____]. After due notice and hearing, this
Court having considered such Application, the representations of Lynn Tillotson Pinker & Cox,
LLP and all matters on file, the Court finds and concludes that the fees and expenses set forth in
the Application are reasonable and necessary and good cause exists for the allowance thereof.
EXHIBIT C

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#4851-3907-7924
The Court finds that all necessary parties were served with notice of the Application, that no
further notice need be given, and that no objection or responsive pleading was filed. It is
therefore,
ORDERED that Lynn Tillotson Pinker & Cox, LLP be and hereby is awarded Attorney’s
Fees in the amount of $183,333.33 representing its contingency fee interest of the Liquidating
Trust’s settlement with Buckno Lisicky & Company, P.C. and Anthony Buczek. It is further
ORDERED that Lynn Tillotson Pinker & Cox, LLP be and hereby is awarded
Reimbursement of Expenses in the amount of $6,542.66. It is further
ORDERED that the Trustee is hereby authorized to pay Lynn Tillotson Pinker & Cox,
LLP the amount of $189,875.99 as fourth interim payment.
### END OF ORDER###
Order drafted by:
Lynn Tillotson Pinker & Cox, LLP
Dallas, Texas 75201
(214) 981-3800 Telephone
(214) 981-3839 Facsimile
Attorney for Matthew D. Orwig,
Liquidating Trustee for the Estate of FirstPlus Financial Group, Inc.

James L. Schutza
7920 Belt Line Road, Suite 650
Dallas, Texas 75254
Prober & Raphael, A Law
Corporation
P. O. Box 4365
Woodland Hills, CA 91365-4365
FirstPlus Financial Group, Inc.
PO Box 142979
Irving, TX 75014
Aaron Michael Kaufman
George H. Tarpley
Cox Smith Matthews , Inc.
1201 Elm St., Ste. 3300
Dallas, TX 75270
Scott F. Mascianica
Sonnenschein Nath & Rosenthal
2000 McKinney Ave., Ste 1900
Dallas, TX 75201
Jo Christine Reed
SNR Denton US LLP
1221 Avenue of the Americas
New York, NY 10020
Erin Marie Schmidt
United States Trustee
1100 Commerce Street,
Room 976
Dallas, TX 75242
William Topp Maxwell
#71944-279
Federal Detention Center
P.O. Box 562
Philadelphia, PA 19106
Internal Revenue Service
Spec. Procedures – Insolvency
P.O. Box 21126
Hulse & Stucki
Attn: Jay R. Stucki
2912 West Story Road
Irving, TX 75038
James W. Puzey
Law Offices Of James W. Puzey
P.O. Box 70172
Reno, NV 89570
John Clarson
4200 Ranier Court
Fort Worth, TX 76109
Patrick John Hethcoat
1365 Wayne Way
San Mateo, CA 94403-1565
George H. Tarpley
Cox Smith Matthews Inc.
1201 Elm St., # 3300
Dallas, TX 75270
Eric A. Liepins
Eric A. Liepins, P.C.
12770 Coit Road, Suite 950
Dallas, TX 75251
Jerry C. Carter
Jenkins & Carter
501 Hammill Lane
Reno, NV 89511
Securities & Exchange
Commission
c/o Rose L. Romero, Reg. Dir.
Burnett Plaza, Suite 1900
801 Cherry Street, Unit 18
Arkadiy Grinshpun
7909 Bustleton Avenue
Firstline Mortgage v. Rutgers
c/o Robert Johnson Law Corp
34197 Pacific Coast Hwy,
Ste 100
Dana Point, CA 92629
Buckno Lisicky & Company
Attn: Tony Buckno
1524 Linden Street
Allentown, PA 18102-4251
Robert O’Neal
324 N . 23rd Street
Beaumont, TX 77707
Laurie Spindler
Huffman Linebarger, et al.
2323 Bryan Street, Suite 1600
Dallas , TX 75201
Michael A. McConnell
Kelly Hart & Hallman PC
201 Main Street, Suite 2500
Fort Worth, Texas 76102
Nathan Jenkins
Jenkins & Carter
501 Hammill Lane
Reno, NV 89511
Gary B. Freedman
7909 Bustleton Avenue
Patton Boggs
Attn: Cass Weiland, Esq.
2000 Mckinney Ave, Suite 1700
Dallas , TX 75201
Downey Brand LLP
427 West Plumb Lane
Reno, NV 89509
Secore &Waller, LLP
Attn: Wayne M. Secore
12222 Merit Dr., # 1350
Dallas, TX 75251
Rutgers Investment
3965 Phelan Blvd, # 209
Beaumont, TX 77707-2232
Angela Dodd
Securities And Exchange Comm.
175 W Jackson Blvd, Ste 900
Chicago, IL 60604
James P. Hanson
5824 Cold Water Drive
Castro Valley, CA 94552-1807
Ronald J. Miller
772 Westray Dr.
Westerville, OH 43081
Daniel J. Sherman
Sherman & Yaquinto, LLP
509 N. Montclair Avenue
Dallas, TX 75208
Lepercq Corporate Income Fund
David Staber/Clayton Ketter
Akin Gump, et al., LLP
1700 Pacific Ave., #4100
Dallas, TX 7520 1
SERVICE LIST

Daniel P. Elms/Heather Bell
Nunnally & Martin LLP
1400 One McKinney Plaza
3232 McKinney Avenue
Dallas, TX 75204-2429
Bowne of Dallas, L.P.
c/o Gail B. Price, Bronwen Price
2600 Mission St., # 206
San Marino, CA 91108
Justin L. Payne, Attorney
6777 Camp Bowie Blvd.
Suite 215
James Hanson
Sherman & Yaquinto, L.L.P.
509 N. Montclair Avenue
Dallas, TX 75208-5498
Derrel Luce
Law Office of Derrel Luce
4600 Bosque, Suite 2B
Waco, Texas 76710
All other parties on the electronic service list.

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