6600 LBJ Freeway, Suite 183
Dallas, Texas 75240
Phone: 972-284-0731
Fax: 972-239-9968
Second, I received an e-mail from you on February 19, 2014 at 8:46 PM. Like the document
attached to the e-mail of February 18, 2014, the document attached to this e-mail has significant
concerns and issues as well. The document appears to be signed by you in your capacity as a
director of CITP, Ltd. This is yet another entity that has never before contacted me. Nothing in
this e-mail or the documents attached provide any documentation to identify who you are, the
source of CITP Ltd’s purported authority to act in any capacity which it purports to act, and other
basic information that you as a barrister & solicitor would require before you took any action on
behalf of your client, let alone an action such as withdrawing a pleading, when withdrawing that
pleading might reasonably be construed as an action against the best interest of a client and a
violation of fiduciary duties owed to that client. With respect to handling of the federal
proceedings, you should be aware that in Texas a lawyer should assume responsibility for the
means by which the client's objectives are best achieved; thus, a lawyer has very broad discretion
to determine technical and legal tactics.
Third, on Friday February 19, 2014 and again on Saturday February 20, 2014, I spoke with
Leonard Simon. I expressed my concerns that no one has provided me with the necessary
documentation to demonstrate the authority of CITP Ltd and/or RPV to act. I also advised him
that I had called you but had not received a return call. Perhaps incorrectly, I assumed he would
communicate these concerns to you as well. Mr. Simon also asked me to submit invoices to you
for my time and expenses so that arrangements could be made to get them paid.
Fourth, on Sunday February 21, 2014, Mr. Leonard sent me an e-mail suggesting “As a showing
of good faith, please file a notice of withdrawal of the Reply you filed on 2/18/2014, Document
No. 1360.” He attached the same resolutions as included in your e-mail of February 19, 2014
with the same defects, issues and concerns as those contained in your e-mail. Receiving this e-
mail from him did not cure these defects, issues and concerns. Moreover, Mr. Simon does not
purport to represent the LLCs, and has not yet been authorized to substitute in as counsel in the
federal court. I seriously doubt that you would accept such documents if they came from a
foreign country as the basis for taking any action which might be construed as against the interest
of your client without authenticated documentation and far more information than has been
provided to me. With no disrespect intended, I do not believe the entities you represent hold the
authority they are purporting to exercise. However, while it is not clear which, if any, parties you
are representing as counsel, I am happy to look at whatever documentation you may provide.
As counsel for Novo Point LLC and Quantec LLC I have a fiduciary duty to both of these
companies. I fully intend to discharge these responsibilities to the best of my abilities and am
not about to take any action which I believe might likely harm the companies. I will also not be
threatened into taking an action that I believe is in violation of my fiduciary duties to the LLCs
and/or cannot verify is genuinely requested of me by someone who is authorized and actually
understands the potential consequences of such actions.
I need, as a preliminary matter, documentation that can be authenticated and which evidences the
authority of the entities your represent to take the actions reflected in the documents you sent me.
That will allow me to determine what actions should be taken, if any, in light of the substance of
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