091614 letter to brahmas

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R. LAURENCE MACON 1.+1 210.281.7222/fax: +1 210.224.2035 [email protected] September 16, 2014 Via Email – [email protected] And Certified Mail Christopher B. Trowbridge, Esq. Bell Nunnally 3232 McKinney Avenue, Suite 1400 Dallas, Texas 75204 RE: Cause No.: DC-13-05044 - Western Professional Hockey League, Inc. d/b/a Central Hockey League and WPHL Texas Holdings, Inc (“Plaintiffs”) v. Top Shelf, L.L.C., Douglas Miller, Rapid City Professional Hockey LLC, ECHL, Inc. and Scott Mueller. (“Defendants”) (the “Litigation”) Mr. Trowbridge: I am shocked to receive your letter dated September 15, 2014, on behalf of your client, the Texas Brahmas, a team that ceased operations after the 2011-2012 season, threatening to seek a temporary restraining order in this Litigation because your client learned that Plaintiffs and Defendants in the Litigation, together with Central Partners (collectively, the “Parties”), the current owners of the Central Hockey League, are in the process of settling all disputes between the Parties, a very unique, complex and admirable task to accomplish. Undoubtedly, your client is seeking to capitalize on the Parties hard work by threatening to seek a temporary restraining order in the Litigation in order to extort money from the Parties. You have no good faith basis to seek a temporary restraining order and, by copy of this letter we are advising the Honorable Judge Tobolowsky and all counsel involved, of your meritless plan. FILED DALLAS COUNTY 9/16/2014 2:56:25 PM GARY FITZSIMMONS DISTRICT CLERK

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Letter from attorneys representing WPHL, Inc. to the Texas Brahmas.

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R. LAURENCE MACON 1.+1 210.281.7222/fax: +1 210.224.2035 [email protected]

September 16, 2014

Via Email – [email protected] And Certified Mail Christopher B. Trowbridge, Esq. Bell Nunnally 3232 McKinney Avenue, Suite 1400 Dallas, Texas 75204

RE: Cause No.: DC-13-05044 - Western Professional Hockey League, Inc. d/b/a Central Hockey League and WPHL Texas Holdings, Inc (“Plaintiffs”) v. Top Shelf, L.L.C., Douglas Miller, Rapid City Professional Hockey LLC, ECHL, Inc. and Scott Mueller. (“Defendants”) (the “Litigation”)

Mr. Trowbridge: I am shocked to receive your letter dated September 15, 2014, on behalf of your client, the Texas Brahmas, a team that ceased operations after the 2011-2012 season, threatening to seek a temporary restraining order in this Litigation because your client learned that Plaintiffs and Defendants in the Litigation, together with Central Partners (collectively, the “Parties”), the current owners of the Central Hockey League, are in the process of settling all disputes between the Parties, a very unique, complex and admirable task to accomplish. Undoubtedly, your client is seeking to capitalize on the Parties hard work by threatening to seek a temporary restraining order in the Litigation in order to extort money from the Parties. You have no good faith basis to seek a temporary restraining order and, by copy of this letter we are advising the Honorable Judge Tobolowsky and all counsel involved, of your meritless plan.

FILEDDALLAS COUNTY

9/16/2014 2:56:25 PMGARY FITZSIMMONS

DISTRICT CLERK

Should you attempt to seek an ex-parte temporary restraining order, you are hereby

advised that each of Parties to this Litigation and settlement are represented by counsel and you must provide notice as required by the Dallas County Local Rules as each of the counsel involved in the Litigation and settlement wish to attend.

Sincerely,

AKIN, GUMP, STRAUSS, HAUER & FELD, LLP

_____________________________________

R. Laurence Macon cc: Judge Tobolowsky Eric Pinker Jay Madrid Richard Anigian Pete Hartweger Becky Snyder