Finally, Mr. Mustard speaks. Here is his Answer to the accusations that were lodged against him by Ralph Yarro, Darcy Mott and Brent Christensen in their Complaint in the Yarro et al v. Kreidel et al litigation, which just settled. Our thanks go to belzecue,
cybervegan, and
Chris Lingard for the transcript and the HTML. This is one of the two cases that just settled, so this is for history -- and for us to get a feel for the man now heading up Canopy Group, the parent company of SCO.
****************************
David B. Watkiss, Esq. (#3401)
Anthony C. Kaye, Esq.
(#8611)
James W. Stewart, Esq. (#3959)
Boyd L. Rogers
(#l0095)
BALLARD SPAHR ANDREWS & INGERSOLL, LLP
[address, phone, fax]
Attorneys for Intervenor-Defendant The Canopy
Group, Inc.,
Defendants Raymond J. Noorda and Lewena Noorda, as
Trustees of the
Noorda Family Trust and as individuals, and
William Mustard
________________________
IN THE
FOURTH JUDICIAL DISTRICT COURT
UTAH COUNTY, STATE OF UTAH
_______________________
RALPH J.
YARRO III, an individual,
DARCY G. MOTT, an individual,
BRENT
D. CHRISTENSEN, an individual,
Plaintiffs,
-vs-
VAL NOORDA KREIDEL, an
individual,
TERRY PETERSON, an individual,
WILLIAM MUSTARD,
an individual,
THE NOORDA FAMILY TRUST, a Trust,
RAYMOND J.NOORDA, an individual,
and a trustee of the Noorda
Family Trust,
LEWENA NOORDA, an individual and
a
trustee of the Noorda Family Trust, and
JOHN DOES 1 THROUGH 10,
Defendants,
-and -
THE
CANOPY GROUP, INC.,
Intervenor-Defendant.
_____________________
ANSWER OF DEFENDANT WILLIAM
MUSTARD
JURY TRIAL DEMANDED
Civil No. 050400205
Honorable Anthony W. Schofield
_____________________
Defendant William Mustard
("Mr. Mustard"), by and through counsel,
Ballard Spahr
Andrews & Ingersoll,
LLP, hereby responds to the Amended Complaint and Jury
Demand
("Complaint") of
Plaintiffs Ralph J. Yarro I11 ("Yarro"),
Darcy G. Mott ("Mott"), and Brent
D.
Christensen ("Christensen") (collectively, "Plaintiffs")
as
follows:
FIRST DEFENSE
The Complaint fails to state a
claim against Mr. Mustard upon which relief can
be
granted.
SECOND
DEFENSE
Mr. Mustard responds to the specific allegations of the
Complaint as follows:
The Parties
Mr. Mustard admits that
Yarro served as President and Chief Executive Officer
of
the Canopy Group, Inc.
("Canopy"), that Yarro's employment was
at-will, that Yarro's
employment was
terminated on December 17,2004, and that such termination was for
cause.
Mr.
Mustard further admits that Yarro is one of the three members of the Board
of
Directors
("Board") of Canopy. Mr. Mustard lacks sufficient information to
state
the truth or falsity of the
remaining allegations of this paragraph, and
therefore denies the same
(hereinafter "Denied for
lack of
information").
2. Mr. Mustard admits that Mott served as Canopy's Vice
President, Chief
Financial
Officer and Treasurer, that Mott's employment was
at-will, that Mott's
employment was
terminated on December 17,2004, and that
such termination was for cause. Mr.
Mustard denies
the remaining allegations of
2 for lack of information.
3. Mr. Mustard admits that Christensen
served as Canopy's Vice President,
Corporate Counsel, and Assistant Secretary,
that Christensen's employment was
at-will, that
Christensen's employment was
terminated on December 17,2004, and that such
termination was
for cause. Mr.
Mustard denies the remaining allegations of 3 for lack
of
information.
4. Admitted.
5. Denied for lack of
information.
6. Admitted.
7. Admitted.
8.
Admitted.
9. Denied.
Jurisdiction and Venue
10.
Mr. Mustard states that insofar as the allegations of 10 state a
legal
conclusion,
no response is necessary.
11. Mr. Mustard states
that insofar as the allegations of 11 state a legal
conclusion,
no response is
necessary.
General Allegations
12. Denied for lack of
information.
13. Denied for lack of information.
14.
Denied for lack of information.
15. Denied for lack of
information.
16. Denied for lack of information.
17
Denied for lack of information.
18 Denied for lack of
information.
19 Denied for lack of information.
20
Denied for lack of information.
21 Denied for lack of
information.
22Denied for lack of information.
Mr. Mustard
admits that Yarro accepted appointment as President and Chief
Executive Officer
of Canopy in or about August 1998, and states that such
employment was at-will
and was terminated for cause on December 17,2004. Mr. Mustard denies
the
remaining
allegations of 23.
24. Denied for lack of
information.
25. Mr. Mustard admits that Mott served as Chief
Financial Officer of Canopy, and states that such employment was at-will and was
terminated for cause on December 17, 2004.
Mr. Mustard denies the remaining
allegations of 25 for lack of information.
26. Denied for lack of
information.
27. Denied for lack of information.
28.
Denied for lack of information.
29. Denied for lack of
information.
30. Denied for lack of information.
(a)
Mr. Mustard states that insofar as the allegations of 30(a) refer to a
written
document which speaks for itself, no response is necessary. Mr.
Mustard
denies
the remaining allegations of 30(a) for lack of
information.
(b) Mr. Mustard states that insofar as the allegations
of q/ 30(b) refer to a
written document which speaks for itself, no response is
necessary. Mr. Mustard
denies
the remaining allegations of 30(b) for lack of
information.
(c) Mr. Mustard states that insofar as the allegations
of 7 30(c) refer to a
written document which speaks for itself, no response is
necessary. Mr. Mustard
denies
the remaining allegations of 7 30(c) for lack of
information.
31 Denied for lack of information.
32
Denied for lack of information.
33 Denied for lack of
information.
34 Denied for lack of information.
35
Denied for lack of information.
36 Denied for lack of
information.
Mr. Mustard admits that Mr. Christensen served as an
officer of Canopy, and
states that Christensen's employment was at-will and was
terminated for cause
on December 17,
2004. Mr. Mustard denies the remaining
allegations of 27 for lack of
information.
38. Denied for lack of
information.
39. Denied for lack of information.
40. Denied
for lack of information.
41. Denied for lack of
information.
42. Mr. Mustard admits that during 2002,2003, and 2004
Canopy's Board was comprised of Mr. Noorda, Mrs. Noorda, and Yarro. Mr. Mustard
denies the
remaining
allegations of 42 for lack of information.
43.
Denied for lack of information.
44. Denied for lack of
information.
45. Mr. Mustard denies Plaintiffs' allegation that he
"knew prior to December
17, 2004, that Mr. Noorda was incapacitated and
incompetent to make sound business and/or
financial decisions, and was otherwise
susceptible to being unduly influenced in
making
decisions." Mr. Mustard denies
the remaining allegations of 45 for lack
of information.
46
Denied.
47 Denied for lack of information.
48 Denied for
lack of information.
49 Denied for lack of
information.
50 Denied for lack of information.
51
Denied for lack of information.
52 Denied for lack of
information.
53 Denied for lack of information.
54
Denied for lack of information.
55 Denied for lack of
information.
56. Mr. Mustard admits that during 2 meeting of
Canopy's Board held on December
17,2004, the Board passed resolutions which
terminated the at-will employment of
Yarro, Mott,
and Christensen as officers of
Canopy, each for cause, and also passed a
resolution which elected
Mr. Mustard
as the President, Chief Executive Officer, and Treasurer of Canopy.
Mr.
Mustard
further admits that one of the six resolutions adopted during the
December
Meeting was a
resolution granting Mr. Noorda and Mrs. Noorda options to
purchase additional
Class A Voting
Common Stock and Class B Non-Voting Common
Stock in Canopy, and that an
additional
enabling resolution was passed during
that meeting. Mr. Mustard states that the
last sentence of
7 56 is a legal
conclusion and thus requires no response. Mr. Mustard denies
the
remaining
allegations of 56 for lack of information.
57.
Denied.
58. Denied.
59. Denied.
60. Mr. Mustard
denies that he was recruited by Ms. Kreidel or Mr. Peterson to
"assist in the
attempted take-over of Canopy." Mr. Mustard admits that
he was hired to
manage
Canopy after the terminations for cause of Yarro, Mott, and Christensen
on
December 17,2004.
Mr. Mustard admits that he has performed services for
entities other than Canopy
with respect to
pre-liquidation event services, asset
redeployment, implementation of strategies
for deployment
of corporate assets,
the leveraging of personal relationships to drive
redistribution of
business
assets through corporate action and otherwise, corporate
disposals,
liquidations, and spin-outs of
corporate assets. Mr. Mustard denies
the remaining allegations of 160.
61. Mr. Mustard admits that he met
with Canopy employees and presidents of
Canopy's portfolio companies after he
was appointed as Canopy's President, Chief
Executive
Officer, and Treasurer on
December 17,2004. Mr. Mustard admits that Ms. Val
Noorda Kreidel
("Ms. Kreidel")
attended certain of such meetings in her capacity as
an employee of Canopy.
Mr.
Mustard denies the remaining allegations of 61.
62.
Denied.
63. Mr. Mustard denies Plaintiffs allegation that he has in
any way
"threatened, intimidated and harassed Canopy employees." Mr. Mustard
further denies that
is currently or
has ever been an agent of or acted at the
direction of Ms. Kreidel. Mr. Mustard
denies that any
actions taken by him
played any role in the suicide of Robert Penrose. Mr.
Mustard further
asserts
that Plaintiffs have made this baseless accusation in bad faith and in
violation
of Utah R. Civ. P. 11. Mr. Mustard denies the remaining allegations of
63.
64. Mr. Mustard denies that is currently or has ever been an
agent of or acted
at the
direction of Ms. Kreidel. Mr. Mustard further denies
Plaintiffs' allegation that
he has "required
Canopy employees to sign, under
duress, documents back-dated to December
17,2004," and
states that on December
22,2004 he asked Canopy employees to sign and thereby
acknowledge
that they had
read a letter from Mr. and Mrs. Noorda dated December 17, 2004
which
advised
Canopy employees, among other things, that Yarro, Mott, and Christensen
had been
terminated
for cause and that Mr. Mustard was the President and Chief
Executive Officer of
Canopy. Mr.
Mustard denies the remaining allegations of
64.
65. Mr. Mustard admits that as of December 16,2004 Canopy had
twelve full-time
employees. Mr. Mustard further admits that following
Plaintiffs' terminations,
one Canopy
employee died and five others voluntarily
terminated their own employment. Mr.
Mustard
denies that any actions taken by
him played any role in the suicide of Robert
Penrose. Mr.
Mustard further
asserts that Plaintiffs have made this baseless accusation in bad
faith and
in
violation of Utah R. Civ. P. 11. Mr. Mustard asserts that those employees
who
terminated their
own employment following December 17,2004 did so
voluntarily and/or as a result
of Plaintiffs'
influence and/or encouragement.
Mr. Mustard denies the remaining allegations of
65.
66. Mr. Mustard
admits that Canopy and the Trust filed a Complaint (the
"Canopy
Complaint")
against Plaintiffs in this Court (Case No. 050400245) on
January 25, 2005
which
speaks for itself. Mr. Mustard denies the remaining allegations of
66.
First Claim for Relief
(Invalid Actions Purportedly Taken at the December
Meeting and Thereafter)
67. Mr. Mustard restates and incorporates by reference
his responses to 1-66
above, and 73 to 156 below.
68. Denied for
lack of information.
69. Mr. Mustard admits that on December 17,2004 a
resolution was passed by
Canopy's Board appointing him as President and Chief
Executive Officer of
Canopy. Mr.
Mustard further admits that three separate
resolutions were passed on December
17,2004 which
terminated the at-will
employment of Yarro, Mott, and Christensen as officers of
Canopy. Mr.
Mustard
further admits that an enabling resolution and a resolution granting Mr.
and
Mrs.
Noorda options to purchase additional Class A Voting Common Stock and Class
B
Nonvoting
Common Stock was passed during the December 17 Meeting. Mr.
Mustard
denies the
remaining allegations of 69.
70.
Denied.
71. Denied.
72. Denied.
Second Claim for
Relief
(Breach of Contract)
73. Mr. Mustard restates and incorporates
by reference his responses to 1-72
above, and 84 to 156 below.
74.
Denied for lack of information.
75. Mr. Mustard states that insofar
as the allegations of 75 refer to a written
document which speaks for itself,
no response is necessary. Mr. Mustard denies
the remaining
allegations of 75 for
lack of information.
76. Mr. Mustard states that insofar as the
allegations of 76 refer to a
written
document which speaks for itself, no
response is necessary. Mr. Mustard denies
the remaining
allegations of 76 for
lack of information.
77. Mr. Mustard states that insofar as the
allegations of 77 refer to a
written
document which speaks for itself, no
response is necessary. Mr. Mustard denies
the remaining
allegations of 77 for
lack of information.
78. Denied.
79.
Denied.
80. Denied.
81. Denied.
82.
Denied.
83. Denied.
Third Claim for Relief
(Breach of
Fiduciary Duty-Joint Shareholders and Directors of Closely
Held
Business)
84. Mr. Mustard restates and incorporates by reference
his responses to 1-84
above, and 90 to 156 below.
85.
Admitted.
86. Mr. Mustard states that insofar as the allegations of
86 appear to be
directed at
parties other than Mr. Mustard and state a legal
conclusion, no response is
necessary. Mr.
Mustard denies the remaining
allegations of 86 for lack of information.
87. Mr. Mustard states
that insofar as the allegations of 87 appear to be
directed at
parties other
than Mr. Mustard, no response is necessary. Mr. Mustard denies
the
remaining
allegations of 87 for lack of information.
88.
Denied.
89. Denied.
Fourth Claim for Relief
(Breach of
Directors and Officers Statutory Standard
of Conduct-Utah Code 5
16-1Oa-8403
90. Mr. Mustard restates and incorporates by reference
his responses to 1-89
91. Mr. Mustard states that insofar as the
allegations of 91 appear to be directed
parties other than Mr. Mustard, no
response is necessary. Mr. Mustard denies the
remaining allegations of 91 for
lack of information.
92. Mr. Mustard states that insofar as the
allegations of 92 appear to be
directed at
parties other than Mr. Mustard, no
response is necessary. Mr. Mustard denies
Plaintiffs'
allegation that current or
former Canopy employees have been mistreated in any
manner after
December
17,2004. Mr. Mustard denies the remaining allegations of 92 for
lack
of
information.
93. Mr. Mustard states that insofar as the
allegations of 93 appear to be
directed at
parties other than Mr. Mustard, no
response is necessary. Mr. Mustard denies
Plaintiffs'
allegation that current or
former Canopy employees have been mistreated in any
manner after
December 17,
2004. Mr. Mustard denies the remaining allegations of 93 for
lack
of
information.
94. Denied.
95. Denied.
96.
Denied.
Fifth Claim for Relief
(Breach of Fiduciary Duties and
Standards of Conduct-By Arrogated Directors)
97. Mr. Mustard
restates and incorporates by reference his responses to 1-96
above, and 106 to
156 below.
98. Denied.
99. Denied.
100.
Denied.
101. Denied.
102. Denied.
103.
Denied.
104. Denied.
105. Denied.
Sixth Claim for
Relief
(Temporary Restraining Order/Preliminary and Permanent
Injunction)
106 Mr. Mustard restates and incorporates by reference
his responses to l-l
05
above, and 118 to 156 below.
107. Denied for
lack of information.
108. Denied.
109. Mr. Mustard admits
that subsequent to the terminations of Plaintiffs on
December
17,2004 he advised
Canopy employees both orally and in writing that Plaintiffs
had been
terminated
as officers of Canopy for cause and that Canopy employees were not to
take
direction
from Plaintiffs respecting Canopy.
110.
Admitted.
111. Denied.
112. Denied.
113.
Denied.
114. Denied.
115. Denied.
116. Mr.
Mustard states that insofar as the allegations of 116 appear to be
directed
at
parties other than Mr. Mustard, no response is necessary.
117. Mr.
Mustard states that insofar as the allegations of 117 appear to be
directed
at
parties other than Mr. Mustard; no response is necessary
Seventh
Claim for Relief
(Breach of Covenant of Good Faith and Fair
Dealing)
118. Mr. Mustard restates and incorporates by reference his
responses to
1-117
above, and 123 to 156 below.
119. Mr. Mustard
states that insofar as the allegations of 113 appear to be
directed at
parties
other than Mr. Mustard, no response is necessary. Nonetheless, Mr.
Mustard
denies the
allegations of 119.
120. Mr. Mustard states that insofar
as the allegations of 120 appear to be
directed at
parties other than Mr.
Mustard, no response is necessary. Nonetheless, Mr.
Mustard denies
the
allegations of 120.
121. Mr. Mustard states that insofar as the
allegations of 121 appear to be
directed at
parties other than Mr. Mustard, no
response is necessary. Nonetheless, Mr.
Mustard denies the
allegations of
121.
122. Denied.
Eighth Claim for Relief
(Promissory
Estoppel)
123. Mr. Mustard restates and incorporates by
reference his responses to
1-122
above, and 128 to 156 below
124.
Denied for lack of information.
125. Denied for lack of
information.
126. Denied.
127. Denied.
Ninth Claim for
Relief
(Constructive/Resulting Trust)
128. Mr. Mustard restates and
incorporates by reference his responses to
1-127
above, and 131 to 156
below.
129. Denied.
130. Denied
Tenth Claim for
Relief
(Declaration that Plaintiffs' Employment Was not
Terminated)
131. Mr. Mustard restates and incorporates by reference
his responses to 1-130
above, and 138 to 156 below.
132. Mr. Mustard
states that insofar as the allegations of 132 refer to a
written
document which
speaks for itself, no response is necessary. Mr. Mustard denies
the
remaining
allegations of 132.
133. Mr. Mustard states that insofar as
the allegations of 133 refer to a
written
document which speaks for itself, no
response is necessary. Mr. Mustard denies
the remaining
allegations of
133.
134. Mr. Mustard states that insofar as the allegations of 134
refer to a
written
document which speaks for itself, no response is necessary.
Mr. Mustard denies
the remaining
allegations of 134.
135. Mr. Mustard
states that insofar as the allegations of 135 refer to a
written
document which
speaks for itself, no response is necessary. Mr. Mustard denies
the
remaining
allegations of 135.
136. Denied.
137.
Denied.
Eleventh Claim for Relief
(Tortious Interference With Contract
and Existing Economic Relations,
and Tortious Interference with Prospective
Economic Relations)
138. Mr. Mustard restates and incorporates by
reference his responses to 1-1
27
above, and 148 to 156 below.
139.
Mr. Mustard states that insofar as the allegations of 139 refer
to
written
documents which speak for themselves, no response is necessary. Mr.
Mustard
denies the
remaining allegations of 139.
140. Denied for lack of
information.
141. Denied for lack of information.
142. Mr.
Mustard states that insofar as the allegations of 142 appear to be
directed
at
parties other than Mr. Mustard, no response is necessary. Nonetheless,
Mr.
Mustard denies the
allegations of 142.
143. Mr. Mustard states
that insofar as the allegations of 142 appear to be
directed at
parties other
than Mr. Mustard, no response is necessary. Nonetheless, Mr.
Mustard denies
the
allegations of 143.
144. Mr. Mustard states that insofar as the
allegations of 144 appear to be
directed at
parties other than Mr. Mustard, no
response is necessary. Nonetheless, Mr.
Mustard denies the
allegations of
144.
145. Denied.
146. Denied.
147.
Denied.
Twelfth Claim for Relief
(Undue Influence)
148. Mr.
Mustard restates and incorporates by reference his responses to
1-147
above,
and 153 to 156 below.
149. Mr. Mustard states that insofar as the
allegations of 149 appear to be
directed at
parties other than Mr. Mustard, no
response is necessary. Nonetheless, Mr.
Mustard denies
Plaintiffs' allegation
that Ms. Kreidel, Mr. Peterson, and John Does 1-10
"knew of Mr. and
Mrs.
Noorda's dependant conditions and deteriorating health" for lack
of
information and denies the
remaining allegations of 149.
150. Mr.
Mustard states that insofar as the allegations of 150 appear to be
directed
at
parties other than Mr. Mustard, no response is necessary. Nonetheless,
Mr.
Mustard denies the
allegations of150.
151. Mr. Mustard states
that insofar as the allegations of 15l appear to be
directed at
parties other
than Mr. Mustard, no response is necessary. Nonetheless, Mr.
Mustard denies
the
allegations of 151.
152. Mr. Mustard states that insofar as the
allegations of152 appear to be
directed at
parties other than Mr. Mustard, no
response is necessary. Nonetheless, Mr.
Mustard denies the
allegations of
152.
Thirteenth Claim for Relief
(Aiding and Abetting Breach of
Fiduciary Duty)
153. Mr. Mustard restates and incorporates by
reference his responses to 1-1
52
above.
154. Denied.
155.
Denied.
156. Denied.
157. Mr. Mustard specifically denies
each and every allegation of the Complaint
not
specifically admitted in 1-156
above.
THIRD DEFENSE
The Complaint is barred, in whole or in part, to
the extent Plaintiffs have
waived or are
estopped from asserting the claims
asserted therein.
FOURTH DEFENSE
Plaintiffs' claims are barred, in
whole or in part, by the doctrines of
laches,
and/or
acquiescence.
FIFTH DEFENSE
The allegations and claims
asserted in the Complaint, in each purported cause of
action
alleged therein,
have always been and continue to be frivolous, unreasonable,
and
groundless.
Plaintiffs brought this action in bad faith. See Utah Code Ann.
578-27-56.
SIXTH DEFENSE
Plaintiffs' claims are barred, in whole or
in part, because they are not
asserted by the real
party in
interest.
SEVENTH DEFENSE
The Complaint is barred, in whole or in
part, to the extent that the claims
asserted therein
are claims that belong to
Canopy.
EIGHTH DEFENSE
Plaintiffs have suffered no damages because
their employment at Canopy was
at-will and
was therefore terminable by Canopy at
any time for any reason or no reason.
NINTH DEFENSE
Plaintiffs have
failed to mitigate their damages, if any, and to the extent of
such failure
to
mitigate, any damages awarded to Plaintiffs should be reduced
accordingly.
TENTH DEFENSE
Plaintiffs' claims are barred, in whole or
in part, based on the doctrine of
unclean hands.
ELEVENTH
DEFENSE
Plaintiffs' request for a preliminary injunction is improper because
Plaintiffs
have failed
to show that they have suffered, or will continue to
suffer, irreparable harm in
the absence of
their requested
injunction.
TWELFTH DEFENSE
Plaintiffs' request for a preliminary
injunction is improper because Plaintiffs'
purported
options are invalid and do
not give them any substantive rights with regard to
the management
and/or
control of Canopy.
THIRTEENTH DEFENSE
Plaintiffs' request for a
preliminary injunction is improper because the
proposed
injunction is contrary
to the public interest.
FOURTEENTH DEFENSE
Plaintiffs' claims are
barred, in whole or in part, because the actions taken by
Mr.
Mustard were
proper and/or protected by the business judgment rule.
FIFTEENTH
DEFENSE
Plaintiffs' claims are barred, in whole or in part, because Plaintiffs
lack
standing.
SIXTEENTH DEFENSE
Mr. Mustard asserts and allege that
he has, or may have, additional affirmative
defenses
which are not yet known but
which may become known through future discovery. Mr.
Mustard
asserts each and
every defense as may be ascertained through future
discovery
herein.
DEMAND FOR JURY TRIAL
Pursuant to Utah R. Civ. P.
38, Mr. Mustard demands a trial by jury on all
issues raised
by the pleadings
and so triable.
WHEREFORE, Mr. Mustard respectfully requests that the Complaint
be dismissed
with
prejudice and that Plaintiffs take nothing thereby; that he be
awarded his
attorney's fees and
costs as provided by law; and that he be
awarded such other and further relief
as the Court
deems
warranted
DATED this 24th day of February 3005.
BALLARD SPAHR
ANDREWS & INGERSOLL, LLP
David B. Watkiss, Esq
Anthony C. Kaye, Esq.
Jarnes
W. Stewart, Esq.
Boyd L. Rogers, Esq.
Attorneys for Defendant William
Mustard
CERTIFICATE OF SERVICE
I hereby certify that a true and
correct of copy of the foregoing Answer of
Defendant
William Mustard was served
to the following
this 24th day of February 2005, in the manner set
forth
below:
[ ] Hand Delivery
[X] U.S. Mail, postage prepaid
[ ] Federal Express
[ ]
Certified Mail, Receipt No. ,return receipt requested
Stanley J. Preston,
Esq.
Michael R. Carlston, Esq.
Maralyn M. Reger, Esq.
SNOW, CHRISTENSEN &
MARTINEAU
[address]
Blake D. Miller, Esq.
MILLER & GUYMON,
P.C.
[address]
Blaine J. Benard, Esq.
Eric G. Maxfield,
Esq.
HOLME ROBERTS
& OWEN,LLP
[address]
Jeffrey S. Facter, Esq.
SHEARMAN & STERLING
LLP
[address]
|
