Paul:

My mother will be bringing a check to you tomorrow in partial payment of 
services rendered.  

I'd like to subpoena Jack's apartment lease and application for Pin Oak 
Estates.  Can you provide me with some form subpoena and I'll do whatever 
"leg work" needs to be done in order to minimize your time.  I know time is 
short for you with your vacation coming up.  I'm hoping Jack signed his lease 
(and possibly the application) post April 12.  However, I'm afraid he signed 
the application prior to the April 12 hearing date, but signed the lease post 
hearing date.  Is this of any significant relevance?

Secondly, after we receive the lease and application, I'd like to send out 
some requests for production.  It doesn't seem as though we're going to be 
able to settle this, so I thought we'd be best served by getting as much 
information from them as possible.  Let me know what you think about this 
idea.  Below, I have listed a few discovery requests  ----  let me know if 
you think these are adequate.

1.  Please produce your paycheck stubs from each full-time and part-time job 
you have had since January 1, 2000 until the present.
2.  Please produce your application for apartment lease at Pin Oak Estates 
Apartments.
3.  Please produce your lease agreement on your apartment located at Pin Oak 
Estates Apartments.
4.  Please produce your bank statements from Chase Bank (or any other banking 
facility you have) for the months of April and May 2000.
5.  Please produce your credit card statements for all credit cards in your 
name, both jointly with your wife and solely in your name.
6.  Please produce all statements of the stock account in your name with the 
brokerage firm, Datek, and any other stock brokerage firm.
7.  Please produce your 401K account statement from all such accounts both 
with your current employer and with your previous employers.
8.  Please produce a copy of your current W-2 as filed with your current 
employer(s).

Like I stated above, we need to get his lease agreement and application 
before we ask him to provide it, so he doesn't try to alter the date or 
anything else.

Also, I am happy to put these discovery requests in final form or do whatever 
you think is best.  I hope you understand my need to keep costs at a 
minimal.  Thanks for your advice.

Linda

P.S.  In light of your vacation, will there be anyone who can help me while 
you're gone?  Would you like me to ask my boss to step in as co-counsel?  I 
don't know if he's willing or not, but I can certainly ask.  After all, pride 
left me a long time ago.  Money is a factor, however, I need representation 
while you're away.  Let me know what you think.  Thanks.