Black Dragon Resource Companies Inc (BDGR)

[watchnsee]

Both are being sued Lanza, Black Dragon and others. The court case name is OMDA Oil and Gas Inc. v. Lanza et al and Black Dragon Resource Companies Inc. (Pink Sheets:
BDGR) The case is being heard in Harris County Texas. (See Below)

And here is the incestuous part of Black Dragon, CADDO, and PetroLind Drilling.

Petrolind Drilling is owned by CADDO International. Who is CADDO International and PetroLind Drilling. According to the news postings in April & May 2009 Caddo is in... Oil City, LA Tel: [phone] Email: CONTACT: Mario Lanza, [phone].

On June 1, 2009:

Caddo International Inc. announced the appointment of Mr. David Taylor as the acting President taking the place of Mario Lanza. Mr. Mario Lanza recently resigned due to personal obligations in the family, however he will still work diligently with Mr. Taylor on a variety of current and future projects for Caddo. Mr. Taylor's professional background includes: accounting, well diverse with heavy equipment, President of an oil & gas company which traded on the Nasdaq over the counter bulletin board, and seasoned veteran both in the public and private sectors. Mr. Taylor has been responsible for heavy equipment.

On 09/29/2009 Caddo International‘s Stock Registration Revoked

The registration of the securities of Petro Industries, Inc. (Caddo International, Inc.) has been revoked. The company had failed to file required annual and quarterly reports with the Securities and Exchange Commission for almost four years. Thus, it violated a crucial provision of the federal securities laws that requires public corporations to publicly disclose current, accurate financial information so that investors may make informed decisions. The revocation was ordered in an administrative proceeding before an administrative law judge.

All I have to say is WAY TO GO LANZA FAMILY. It's hard to find such a family with such a consistant record of being crooks. Hopefull Dr. Bailey is not cut out of the same cloth.

Here is some info on the court case......


NO. 2005-23020
OMDA OIL AND GAS, INC., ' IN THE DISTRICT COURT OF
'
PLAINTIFF, '
'
v. '
'
JOE A. LANZA, JAYNE LANZA, MORGAN J. '
WILBUR, III, RICHARD I. MICHAEL, '
INDIVIDUALLY, AND AS TRUSTEE '
OF THE 007 TRUST, THE '
REPRESENTATIVE OF THE ESTATE ' HARRIS COUNTY, T E X A S
MONTE ANDERSON, TOM NEELEY, '
DAVID TAYLOR, BLACK DRAGON '
RESOURCE COMPANIES, INC., '
FOUR STAR OIL COMPANY, FOUR STAR '
PRODUCTIONS, INC., PETROL '
INDUSTRIES, INC., WOOLDRIDGE '
PRODUCTION COMPANY, Ltd, '
PARTERNSHIP NO.1, WOOLDRIDGE '
PRODUCTION CO., Ltd., WOOLDRIDGE '
PRODUCTION, LLC, LANZA LAND '
MANAGEMENT, LLC, SHWJ OIL & GAS '
CO. INC., AND SHWJ OIL & GAS COMPANY, A ' 215TH JUDICIAL DISTRICT
PARTNERSHIP, '
'
DEFENDANTS. '


M. DEWAYNE VARNADORE, P.C., ' IN THE DISTRICT COURT OF
'
INTERPLEADER, '
'
v.. '
'
OMDA OIL AND GAS, INC., ' HARRIS COUNTY, T E X A S
OMDA OIL & GAS MANAGEMENT, '
INC., AND OMDA OIL & GAS SERVICES, INC., '
'
DEFENDANTS. ' 215TH JUDICIAL DISTRICT


OMDA OIL AND GAS, INC.’S FIFTH AMENDED PETITION ADDING ADDITIONAL PARTIES, REQUEST FOR DECLARATORY JUDGMENT, REQUEST FOR EQUITABLE RELIEF AND REQUEST FOR DISCLOSURE

TO THE HONORABLE JUDGE OF SAID COURT:

NOW COMES plaintiff, OMDA Oil and Gas, Inc. (“OMDA”), filing its Fifth Amended Petition Adding Additional Parties, Request for Declaratory Judgment, Request for Equitable Relief and Request for Disclosure (“Petition”), against the defendants, Joe A. Lanza (“Lanza”), Jayne Lanza, Morgan J. Wilbur, III (“Wilbur”), Richard I. Michael (“Michael”), individually, and as Trustee of the 007 (“007 Trust”), the Representative of the Estate of Monte Anderson, deceased (“Anderson”), Tom Neeley (“Neeley”), David Taylor (“Taylor”), Black Dragon Resource Companies, Inc. (“Black Dragon”), Four Star Oil Company (“Four Star”), Four Star Productions, Inc. (“Four Star Productions”), Petrol Industries, Inc. (“PTLD”), Wooldridge Production Company, Ltd., Partnership No. 1 (“Wooldridge Partnership”), Wooldridge Production Co., Ltd. (“Wooldridge Production”) Wooldridge Production, LLC (“Wooldridge Production, LLC”), Lanza Land Management, LLC (“LLM”), SHWJ Oil & Gas Co, Inc. (“SHWJ”), SHWJ Oil & Gas Company, a Partnership (“SHWJ Partnership”) and responding to the Interpleader filed by M. Dewayne Varnadore, P. C., (“Varnadore”), states as follows:
A. DISCOVERY CONTROL PLAN

1. Discovery is being conducted under Level 2 of Texas Rule of Civil Procedure 190.3.
B. SUMMARY
2. OMDA is a Delaware corporation engaged in the oil and gas business through its three subsidiaries, OMDA Oil & Gas Management (“Management”), OMDA Oil & Gas Services, Inc. (“Services”) and SHWJ (hereafter referred to collectively as the "Subsidiaries"). OMDA Management, OMDA Services, and SHWJ are all Texas corporations. Prior to September 9, 2003, OMDA was controlled by Lanza. A convicted felon, Lanza used a series of cronies, or “frontmen,” including, but not limited to, Jayne Lanza, Wilbur, Michael, Anderson, Neeley and Taylor, to carry out what amounted to a corporate Ponzi scheme.
3. On or about September 1, 2001, Varnadore was hired as attorney to represent OMDA in corporate oil and gas related matters. Despite the fact that Lanza could not be a director or officer of OMDA due to his felony conviction and a Consent Judgment rendered against him by the SEC , Varnadore received all of his instructions from Lanza pertaining to services to be completed on behalf of OMDA. On or about December 10, 2001, Varnadore drafted and filed certificates of incorporation with the Texas Secretary of State to form Management, Services, and SHWJ. Unlike OMDA, the stock of Management, Services and SHWJ was not publicly traded, but rather was issued to “Monte Anderson, David Taylor, DeWayne Varnadore, as Trustees for the benefit of [OMDA].”
4. Lanza subsequently instructed Varnadore to prepare a Declaration of Trust on behalf of OMDA (the “Trust”). Taylor, Anderson, and Varnadore were named as “Trustees” to hold the stock of Management, Services, and SHWJ for the benefit of OMDA. Varnadore has confirmed that the settlor of the trust was OMDA, and that it was Lanza’s intention that OMDA would act as a holding company for the Subsidiaries’ stock and assets.
5. Varnadore assisted Lanza, through OMDA and its wholly-owned subsidiary, Management, in the purchase of certain oil and gas properties located in Anderson and Milam Counties, Texas, and in Caddo and Claiborne Parishes, Louisiana. Lanza and his wife, Jayne Lanza, issued a number of press releases announcing the acquisition of the Texas and Louisiana oil and gas properties. In addition, in correspondence to Varnadore, Lanza repeatedly referred to “OMDA Oil & Gas, Inc. the parent of OMDA Oil & Gas Management.”
6. Based upon the various representations made by Lanza and his frontmen, Adam Barnett (“Barnett”) began buying shares of OMDA on the over-the-counter bulletin board (“OTCBB”) or Pink Sheet Exchanges. Barnett and his partner visited Lanza in Oil City, Louisiana, and subsequently entered into a consulting agreement with Lanza that paid them in OMDA stock.
7. On or about September 9, 2003, Barnett became the majority stock holder of OMDA and, as permitted under Delaware law, took control of OMDA. Barnett immediately replaced Lanza and his frontmen in their positions of authority within the company.
8. Upon Barnett’s takeover of OMDA, Lanza, through his frontmen, began looting the Subsidiaries of their respective oil and gas assets. Now claiming that Management, Services, and SHWJ were never wholly-owned subsidiaries of OMDA, Lanza sold most of the oil and gas assets held by Management to friends, family members and frontmen. Through a series of transactions, a number of the Louisiana oil and gas leases and wells ended up in the possession of Black Dragon. Not surprisingly, Lanza has become the President of Black Dragon. On information and belief, other Louisiana oil and gas leases and wells ended up in the possession or under the control of Lanza’s frontmen or Lanza-controlled companies, including, but not limited to: Wilbur, Michael, Anderson, Neeley, Taylor, his wife, Jayne Lanza, his son, Mario Lanza, his daughter, Dei Lanza, Four Star, 007 Trust, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, SHWJ, SHWJ Partnership and LLM.
9. In the present suit, OMDA seeks five (5) broad categories of relief: (1) a declaration that Barnett was the majority owner of the outstanding shares of OMDA on or about September 9, 2003; (2) a declaration that, at all times relevant, OMDA owned the Subsidiaries and that neither Lanza, his family nor frontmen, had the legal authority to transfer the Subsidiaries’ assets without the consent of OMDA; (3) a declaration invalidating fictitious debt created for the benefit of Lanza, his family and frontmen purportedly owed by OMDA; (4) recovery of all of OMDA’s assets improperly and illegally transferred including, but not limited to, all lost oil and gas revenue therefrom, and all assets acquired with the proceeds from those assets; and (5) actual, special and punitive damages, as well as, the disgorgement of profits from Lanza, his family and frontmen for their various illegal and nefarious acts.
10. On February 21, 2007, this Court entered an Order invalidating all of OMDA’s Series “D” of Voting Cumulative Convertible Preferred Stock (“Class “D” Stock”) that Lanza claims would have given him a majority of OMDA free trading shares. In doing so, this Court has granted OMDA a portion of the first broad category of relief.
C. PARTIES
11. Plaintiff OMDA is a Delaware corporation with its principal place of business located in Harris County, Texas.
12. The three Texas corporations that OMDA maintains are its wholly-owned subsidiaries are:
i. Management, a Texas corporation having its principal place of business located in Harris County, Texas;

ii. Services, a Texas corporation having its principal place of business in Harris County, Texas; and

iii. SHWJ, a Texas corporation whose registered office is in Smith County, Texas.

13. Defendant Lanza, a/k/a Anthony Joseph Lanza, a/k/a Joe A. Lanza, a/k/a Joe Lanza, is an individual who has previously appeared and filed a responsive pleading in the present suit.
14. Defendant Wilbur is an individual who has previously appeared and filed a responsive pleading in the present suit.
15. Defendant Michael is an individual who has both been sued in his capacity as an individual and as the trustee of the Trustee of “007 Trust.” Michael, in his capacity as a trustee of the OO7 Trust, has previously appeared and filed a responsive pleading to the present suit. Michael, in his individual capacity, may be served with process at his usual place of business, 1714 Fortview Road, Suite 106, Austin, Texas 78704.
16. Defendant Anderson is an individual who has previously appeared and filed a responsive pleading in the present suit. Recently, OMDA learned that Anderson died. Accordingly, the administrator of the estate of Monte Anderson, decedent, may be served with process. OMDA’s counsel has contacted Anderson’s counsel in an effort to discern the identity of the administrator of Anderson. To date, Anderson’s counsel has failed to respond to OMDA’s counsel’s request.
17. Defendant Taylor is an individual who has previously appeared and filed a responsive pleading in the present suit.
18. Defendant Neeley is an individual who has previously appeared and filed a responsive pleading in the present suit.
19. Defendant Black Dragon is a Delaware corporation with its principal place of business located in Austin, Texas. Black Dragon has previously appeared and filed a responsive pleading in the present suit.
20. Defendant Jayne Lanza is an individual who may be served with process at her abode, 10992 Sanctuary Way, Shreveport, Louisiana 71106-7772.
21. Defendant Four Star is a foreign corporation organized and existing under the laws of the State of Louisiana, whose principal office is located at 100 North Land Ave., Caddo Parish, Oil City, State of Louisiana, and may be served with process by serving the Texas Secretary of State, 1019 Brazos Street, Austin, Texas 78701, as its agent for service because Four Star engages in business in Texas but does not maintain a regular place of business in this state or a designated agent for service of process, and this suit arises out of Four Star’s business in Texas.
22. Defendant Four Star Productions is a Texas corporation whose registered office is 801 E. Abram, #102, Arlington,Texas 76010, may be served either by its registered agent, Frank R. Jelinek at 801 E. Abram, #102, Arlington,Texas 76010 or by serving the Texas Secretary of State, 1019 Brazos Street, Austin, Texas 78701, as its agent for service because Four Star Productions engages in business in Texas but is not currently in good standing, and this suit arises out of Four Star Productions’ business in Texas.
23. Defendant PTLD is a foreign corporation organized and existing under the laws of the State of Louisiana, whose principal office is located at 100 North Land Ave., Caddo Parish, Oil City, State of Louisiana, and may be served with process by serving the Texas Secretary of State, 1019 Brazos Street, Austin, Texas 78701, as its agent for service because PTLD engages in business in Texas but does not maintain a regular place of business in this state or a designated agent for service of process, and this suit arises out of PTLD’s business in Texas. Pleading in the alternative, Defendant PTLD is a foreign corporation organized and existing under the laws of the State of Nevada, whose principal office is located in Reno, Nevada, and may be served with process by may be served either by its registered agent, CT Corporation, 350 N. St. Paul Street, Dallas, Texas 75201 or by serving the Texas Secretary of State, 1019 Brazos Street, Austin, Texas 78701, as its agent for service because PTLD engages in business in Texas but is not currently in good standing, and this suit arises out of PTLD’s business in Texas.
24. Defendant Wooldridge Partnership is a foreign partnership whose principal office is located at State Line Plaza, Box 8030, Texarkana, Arkansas, who may be served by one of its partners, Joseph Lanza at 100 North Land Avenue, Oil City, Louisiana 71061 because the Wooldridge Partnership engages in business in Texas.
25. Defendant Wooldridge Production is a foreign corporation organized and existing under the laws of the State of Arkansas, whose principal office is located at 113 N. Kerley Avenue, Caddo Parish, Oil City, State of Louisiana and may be served with process by serving the Texas Secretary of State, 1019 Brazos Street, Austin, Texas 78701, as its agent for service because Wooldridge Production engages in business in Texas but does not maintain a regular place of business in this state or a designated agent for service of process, and this suit arises out of Wooldridge Production’s business in Texas. Wooldridge Production has also been represented to be a wholly-owned subsidiary of SHWJ, a Texas corporation.
26. Defendant Wooldridge Production, LLC, is a foreign corporation organized and existing under the laws of the State of Louisiana, whose principal office is located at 100 North Land Avenue, Caddo Parish, Oil City, State of Louisiana and may be served with process by serving the Texas Secretary of State, 1019 Brazos Street, Austin, Texas 78701, as its agent for service because Wooldridge Production, LLC engages in business in Texas but does not maintain a regular place of business in this state or a designated agent for service of process, and this suit arises out of Wooldridge Production LLC’s business in Texas.
27. Defendant LLM is a foreign corporation organized and existing under the laws of the State of Louisiana, whose principal office is located at 100 North Land Avenue, Caddo Parish, Oil City, State of Louisiana and may be served through its registered agent, Mario Lanza, 100 North Land Avenue, Caddo Parish, Oil City, Louisiana 71061.
28. Defendant SHWJ is a is a Texas corporation whose registered office is P.O Box 458, Oil City, Louisiana 71061, may be served through its registered agent, M. DeWayne Varnadore, 6101 South Broadway #590, Tyler, Texas 75703.
29. SHWJ Partnership is a foreign partnership whose principal office is located at 100 North Land Avenue, Oil City, Louisiana 71061 who may be served by one of its partners, Joseph Lanza, at 100 North Land Avenue, Oil City, Louisiana 71061 because the Wooldridge Partnership engages in business in Texas.
30. Interpleader Varnadore is a Texas Professional Corporation with its principal place of business located in Smith County, Texas. Varnadore was formerly the attorney for OMDA and its Subsidiaries, and has interpleaded two boxes of documents containing the corporate, financial and lease records of OMDA and its Subsidiaries into the registry of this court.

D. JURISDICTION
31. This Court has jurisdiction over the subject matter and the parties. Furthermore, the Court has personal jurisdiction over all of the defendants under the Texas Long-Arm Statute insofar as they have conducted business in Texas, committed torts in Texas, and have purposefully availed themselves of the privilege of conducting activities in Texas.
32. Moreover, this Court has jurisdiction, under Section 17.003 of the Texas Civil Practices and Remedies Code, because OMDA has set forth a cause of action against one or more foreign defendants for the purpose of establishing title to property in the state of Texas.
E. VENUE
33. Venue is proper in Harris County, Texas, under Texas Civil Practice and Remedies Code section 15.002, because all or a substantial part of the events or omissions giving rise to the claim have occurred in Harris County, Texas.
34. In the alternative, venue is proper in Harris County, Texas, under the permissive venue statute, Texas Civil Practice and Remedies Code Section 15.035. Defendants Wilbur, Michaels and the 007 Trust, claim to have rights under a written contract with OMDA to issue them shares of common stock of OMDA. The written contract upon which they rely requires them to make demand upon OMDA at its corporate offices, which are in Harris County, Texas.
35. Venue is further proper in Harris County, Texas, because the records and documents of OMDA and its Subsidiaries were interpleaded into the registry of the Court in Houston, Texas.
36. Venue is proper in Harris County, Texas against all Defendants, under Texas Civil Practices and Remedies Code Section 15.005, because OMDA has established proper venue against one defendant, and the claims and actions against all remaining defendants arise out of the same transaction, occurrence, or series of transactions or occurrences.
F. FACTUAL BACKGROUND
i. Lanza’s Modus Operandi
37. Lanza is a professional con man. He has become a master at pumping a stock on the open market while siphoning away its resources to various companies owned either by him, his family, or frontmen. Typically, Lanza’s modus operandi is to establish a public company offering shares on the OTCBB or Pink Sheet exchanges. As soon as shares of the public company began trading on the open market, Lanza, his family members, or one of his companies run by his frontmen, would enter fictitious “consulting agreements” creating an account payable on the public company’s books. Lanza would then, through a variety of methods, pump the public company’s stock, attempting to entice unwitting investors to purchase the public company’s, usually worthless, stock. Once the company received funds, however, Lanza would insist that it be used to first repay him, his family members or frontmen. Oftentimes, since the public company had no cash to pay these fabricated debts, Lanza would instruct the company to issue stock in lieu of payment. If the stock price rose, Lanza, his family members or his frontmen stood to gain 200% to 1000% of their “investment” for doing little or nothing to enhance the company’s value.
38. Lanza is also a convicted felon. On April 2, 1997, he was convicted of tax evasion. Lanza was incarcerated for nearly a year at the Nellis Federal Penitentiary Center in North Las Vegas, Nevada.
39. Lanza’s activities have not gone unnoticed by the SEC. On October 19, 2000, Lanza entered into a Consent Judgment with the SEC for making “false and misleading statements in the course of recommending the purchase of Members [Service Corporation] stock.” He was required to disgorge $265,214 plus prejudgment interest of $239,085. Payment was waived, however, when Lanza provided an affidavit claiming that he was financially insolvent. The Commission’s Complaint alleged that the majority of the money was funneled to Lanza’s wife, Jayne Lanza. Lanza was permanently enjoined from violating Sections 5(a), 5(c), and 17(a) of the Securities Act, and Section 10(b) and rule 10b-5 of the Securities Exchange Act.
ii. The History Of OMDA
40. OMDA is a Delaware corporation with its principal place of business located in Houston, Texas, whose common shares are publicly traded on the OTCBB under the symbol OMOG. OMDA has more than 5,000 shareholders. OMDA and its Subsidiaries are engaged in the oil and gas business.
41. From July 30, 1996 until September 9, 2003, Lanza controlled OMDA through a series of frontmen, including, but not limited to, Jayne Lanza, his son, Mario Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Gary Goldman (“Goldman”), and Wes Edwards (“Edwards”), in order to prevent his criminal conviction and SEC judgment from becoming known to the investing public. From time to time, however Lanza represented that he held various offices within OMDA. Although OMDA was initially incorporated under the name Maesa Gaming Management, Inc., Lanza caused OMDA to change its corporate name with the Secretary of State of Delaware, as set forth below :
Date Filed In the office of the
Name of Entity Action Secretary of State of Delaware

Maesa Gaming Management, Inc. Domestication July 30, 1996
Mako Capital, Inc. Name change September 1, 1998
O. Media, Inc. Name change April 21, 1999
Original Media, Inc. Name change December 30, 1999
OMDA Oil and Gas, Inc. Name change June 5, 2002

42. Jayne Lanza, Mario Lanza, Taylor, Anderson, Neeley, Goldman, and Edwards assisted Lanza by serving as directors of OMDA on and off from 1996 through mid-2003. Lanza also utilized several corporate entities, known as Topnet, Inc. a/k/a Top2net, Inc., Indian Wells Investment Company, Inc. (“IWIC”), Mardyne, Inc. (“Mardyne”) and the 007 Trust, to hold shares of OMDA on his behalf.
iii. OMDA Forms Three Texas Subsidiaries In 2001.
43. In the fall of 2001, Lanza, on behalf of OMDA, negotiated with a Texas partnership, SHWJ Oil Company , to purchase oil and gas properties in Anderson County, Texas. Lanza, through his wife Jayne Lanza, publicized the results of these negotiations in a series of press releases. Other OMDA press releases issued during this period identified Anderson as President and Jayne Lanza, Edwards, and Taylor as Directors of OMDA.
44. Upon information and belief, Lanza caused OMDA to enter into contracts for the purchase of other oil and gas properties throughout the states of Texas and Louisiana. Due to Lanza’s refusal to turn over all of the documentation to confirm the above, OMDA has been required to spend a vast amount of resources to determine what oil and gas assets it owns throughout the two States. To date, OMDA has discovered that it may also own oil and gas assets in Smith, Navarro, and Milam Counties, Texas, and Caddo and Claiborne Parishes, Louisiana. OMDA reserves the right to seek the recovery of additional oil and gas assets as their locations can be ascertained.
45. On September 1, 2001, Lanza hired Varnadore to represent OMDA in oil and gas related matters. Varnadore received all of his instruction from Lanza pertaining to legal services to be completed on behalf of OMDA. Varnadore prepared contracts for OMDA’s purchase of oil and gas properties located in Anderson County, Texas. These contracts were finalized on or about December 10, 2001. On the same day, Varnadore filed Articles of Incorporation for Management and Services with the Texas Secretary of State.
46. On January 22, 2002, Varnadore, once again as instructed by Lanza, filed Articles of Incorporation for SHWJ with the Texas Secretary of State.
47. The initial board of directors for Management, Services and SHWJ were listed as Lanza and his frontmen, Anderson and Taylor.
iv. Lanza Creates A Trust Holding The Stock Of The Subsidiaries For The Benefit Of OMDA
48. On or before February 1, 2002, Lanza instructed Varnadore to prepare a Declaration of Trust (“the Trust” or the “Trust”) to hold the stock of each of the Subsidiaries for the benefit of OMDA. Taylor, Anderson and Varnadore were initially named as the Trust’s trustees.
49. The Trust provided:
THIS DECLARATION OF TRUST is made this 1 day of Feb, 2002, by and between Monte Anderson, as Trustee, David Taylor, as Trustee, and M. DeWayne Varnadore, as Trustee (collectively, the “Trustees”), and Original Media, Inc., as Beneficiary (the “Beneficiary”).

WITNESSETH

WHEREAS, each of OMDA Oil & Gas Management, Inc. (“OMDA Management”), OMDA Oil & Gas Services, Inc. (“OMDA Services”) and SHWJ Oil & Gas Co., Inc. (“SHWJ, Inc.”) are recently organized Texas corporations, which were formed to participate in the oil and gas exploration, production and operation industry; and

WHEREAS, due to tax planning considerations and other business related organizational planning, the management of Beneficiary has requested that all of the issued and outstanding common stock (the “Stock”) of each OMDA Management, OMDA Services and SHWJ, Inc. (collectively, the “Corporations”) be held in Trust by the Trustees for the use and beneficial ownership of the Beneficiary.

I.

The Trustees do hereby declare that they stand seized, and now hold in trust for the use and benefit of Beneficiary the Stock of each of the Corporations.

II.

The Trustees do hereby declare that they do not now possess beneficial ownership of the Stock of each of the Corporations.

III.

Should at any time the Trustees be unable to unanimously agree to any matter which comes before the consideration of the Trustees relating to the Stock of each of the Corporations, the vote of two (2) of the Trustees shall be controlling.

IV.

The trust shall be construed and regulated in accordance with and pursuant to the laws of the State of Texas.

IN WITNESS WHEREOF, the parties hereto have executed this Declaration of Trust as of the date above specified.

50. Taylor, Anderson, and Varnadore executed the Trust as trustees. Taylor also executed the trust on behalf of OMDA in his capacity as a director of OMDA.
51. Lanza instructed Varnadore not to purchase corporate kits with printed stock certificates for the Subsidiaries because only a few certificates were to be issued. Instead, the Subsidiaries’ stock certificates were purchased at an office supply store and subsequently completed by Varnadore. Again at Lanza’s request, the Subsidiaries’ stock certificates were completed to match the wording of the Trust. The owner of each of the Subsidiaries’ stock certificate was listed as “Monte Anderson, David Taylor, DeWayne Varnadore, as Trustees for the benefit of [OMDA].”
52. The Trust operated to establish OMDA as the Subsidiaries’ holding company. Varnadore has confirmed that OMDA was the settlor of the Trust, and that the purpose of the Trust was to permit OMDA to raise money through various stock offerings to fund the Subsidiaries’ operations.
53. Lanza consistently used the sale of OMDA stock to raise money for the Subsidiaries’ operations.
54. In July 2002, Varnadore ceased his representation of OMDA and the Subsidiaries. Four (4) months later, he filed a lawsuit against Management to collect nearly $13,500.00 in unpaid legal fees incurred prior to September 9, 2003. Varnadore also resigned as a trustee under the Trust.
v. Defendants Repeatedly Represented That OMDA Owned The Subsidiaries.

55. Prior to September 9, 2003, Lanza, Jayne Lanza, and Lanza’s frontmen represented that the Subsidiaries were wholly-owned by OMDA.
56. On September 26, 2001, Lanza through Anderson issued a press release stating that OMDA had purchased the assets of an oil operating company and had acquired approximately 1,800 additional acres containing one hundred currently-producing wells. In addition, Anderson announced the retention of Varnadore who was to “establish two new wholly owned Texas subsidiary corporations to hold and operate the leases.” Anderson concluded by stating, “. . . that until all of the leases are in the name of the Company’s wholly owned subsidiary, no production figures would be released in order to ensure factual information to the public.” Clearly, the wholly-owned subsidiaries referred to in Anderson’s press release were Management and Services.
57. In addition, Lanza acted as if the Subsidiaries were wholly-owned by OMDA. In a letter dated July 25, 2002, IWIC, another Lanza-owned company, offered to purchase SHWJ from OMDA. If Lanza did not believe that SHWJ was OMDA’s wholly-owned subsidiary, he would not have offered to purchase it from OMDA.
58. On January 21, 2003, Lanza caused OMDA to issue the following statement:
Palm Springs, California – OMDA Oil and Gas, Inc. (OCT BB: OMOG) announces that its subsidiary company, OMDA Oil & Gas Management, Inc., has acquired 285 oil and gas wells in Oil City, Louisiana from Wooldridge Production Company, Ltd., for cash and notes based on production . . .
(emphasis added).
59. In a hand-written letter to Varnadore on July 9, 2003, Lanza confirmed that Management was a wholly-owned subsidiary of OMDA. Therein, he wrote:
Dear Dwayne
In June Gary Goldman, Tom Neeley became Directors of OMDA Oil + Gas Inc. the parent Co of OMDA Oil + Gas Mgmt . . . My Son Mario Lanza acting Sec. for OMDA for OMDA oil + gas mgmt. I hereby state at this time Mario has the right to sign for OMDA oil + gas mgmt![sic]
(emphasis added).
60. Finally, on July 9, 2003, Lanza faxed Barnett a document that Lanza purported to be a “current unaudited financial statement” of OMDA and its Subsidiaries. The document is entitled:
OMDA OIL & GAS, INC., AND SUBSIDIARIES
OMDA OIL AND GAS MANAGEMENT, INC.
OMDA OIL AND GAS SERVICES, INC.
PROFIT PUBLICATIONS, INC.

CONSOLIDATED FINANCIAL STATEMENT
(Unaudited)

April 30, 2003, January 31, 2003 and 2002
vi. Lanza Caused OMDA To Purchase Interests In Several Oil And Gas Leases Located Throughout Texas And Louisiana
61. From June 1, 2001, to September 9, 2003, Lanza used money generated by the sale of OMDA stock to acquire interests in various oil and gas interests located throughout Texas and Louisiana. On several occasions, Lanza purchased the interests through Management using OMDA’s funds.
62. Due to the lack of documentation provided by Lanza and his frontmen, it is difficult to discern exactly what oil and gas interests were owned by OMDA and its Subsidiaries on September 9, 2003. However, through its ongoing investigation, OMDA has been able to identify that, on September 9, 2003, at a minimum, it owned oil and gas interests in Anderson County, Texas (the “Concorde Dome Properties”) and Caddo Parish, Louisiana (the “Caddo Parish Properties”).
63. The Caddo Parish Properties were purchased by Management on January 6, 2003 from Wooldridge Production Company, Ltd. – Limited Partnership #1, GMW Minerals, Inc., and Gyron Mark Wooldridge for $600,000. Considering Management had no assets, it is clear that OMDA funded the purchase of the Caddo Parish Properties through the sale of its stock. The agreement was executed by Taylor on behalf of Management. On the signature block, Taylor identified himself as a “Director.”
64. Upon information and belief, on September 9, 2003, OMDA and its Subsidiaries also owned oil and gas interests in Smith, Milam, and Navarro Counties, Texas, and Claiborne Parish, Louisiana. OMDA asserts ownership over all of the oils and gas interests, or for that matter, all assets, held by OMDA or its Subsidiaries on September 9, 2003, and any assets acquired with those assets or their proceeds – wherever they may be found.
65. Lanza appointed SHWJ Partnership to operate the wells in Texas. Upon information and belief, Lanza caused Services to purchase the name SHWJ Partnership from the former operators of the Concorde Dome Properties in order to avoid the cost of obtaining another bond to satisfy the requirements of the Railroad Commission of Texas. Accordingly, Services did business under the name SHWJ Partnership, though it was actually OMDA’a wholly-owned subsidiary.
66. Under the terms of a previous “Operating Agreement” allegedly executed between Management and SHWJ on March 15, 2001, SHWJ was appointed as the operator of some or all of the Caddo Parish Properties.
67. Neither Lanza, his family nor henchmen have accounted for any of the proceeds from the sale of any oil and gas from any of the Concorde Dome Properties or the Caddo Parish Properties.
vii. Barnett Begins To Buy OMDA Stock And Obtains Assurances From Lanza That He Will Not Dillute OMDA’s Stock
68. In reliance upon press releases that Lanza and his front men caused OMDA to issue, Barnett began to purchase common shares of OMDA.
69. Seeing potential in the oil and gas interests held by OMDA and its subsidiaries, Barnett contacted Lanza and visited him in Oil City, Louisiana. Barnett entered into a Consulting Agreement with OMDA on May 30, 2003, whereby he received 50,000,000 shares of OMDA stock in return for assisting Lanza with promoting OMDA to various investors.
70. During his visit, Lanza assured Barnett that, with an infusion of cash, OMDA, through its subsidiary, Management, he could rework several wells, bringing them into production in short order.
71. Lanza represented to Barnett on several occasions that OMDA had never issued any shares of preferred stock.
72. In reliance upon Lanza’s representations, Barnett continued buying shares of OMDA on the open market. In addition, Barnett paid invoices on behalf of OMDA to rework the Concorde Dome Properties. As Barnett’s holdings neared a majority of OMDA’s stock, Barnett became concerned that Lanza would simply issue more stock, thereby diluting his percentage ownership of OMDA’s stock. In addition, Barnett’s efforts in attempting to attract new investors to buy OMDA’s stock would be significantly hampered if Lanza were to further dilute the stock.
73. On or before June 19, 2003, Barnett requested that Lanza convince the OMDA’s board of directors to pass a resolution agreeing not to further dilute OMDA’s stock for six (6) months.
74. Lanza agreed and had OMDA’s then-Directors execute a document entitled:
OMDA OIL & GAS, INC.
UNANIMOUS WRITTEN CONSENT OF THE DIRECTORS

OMDA OIL AND GAS MANAGEMENT, INC.
UNANIMOUS WRITTEN CONSENT OF SOLE STOCKHOLDER

75. Therein, OMDA was acknowledged as the sole stockholder of Management. However, Management was inadvertently described as a Delaware corporation rather than a Texas corporation. This was a scrivener’s error as no company named OMDA Oil & Gas Management, Inc. has ever been registered with the Delaware Secretary of State. Edwards, Neeley, Taylor, and Goldman signed the document as directors of OMDA, and Lanza signed the document for OMDA, which was designated as the sole stockholder of Management.
viii. Barnett Obtains Control Of OMDA
76. Sensing that he was about to lose control of his “cash cow,” Management, Lanza began taking steps to divest OMDA of its ownership before Barnett took over the company. Lanza began by shuffling the management structure of the Subsidiaries, installing Mario Lanza as Management’s “acting secretary.” Lanza drafted a prospectus offering subscriptions for the purchase of “units” of the Caddo Parish Properties for $25,000. In the prospectus, Lanza indicated that the lease would be held in Management’s name, with a subsidiary of SHWJ, Wooldridge Production, reworking the wells. Moreover, the prospectus suggested that 260 units had been sold, leaving only twenty-one (21) units available for purchase. If true, then Lanza raised nearly $6.5 million dollars through the sale of Management’s assets that has never been accounted for. More likely, this was yet another scam that Lanza used to line his own pockets as no record of any sale of Management’s oil and gas interests in the Caddo Parish Properties occurring prior to September 9, 2003, has been found.
77. All of Lanza’s efforts to divest OMDA of its ownership of the Subsidiaries – and their valuable oil and gas interests – were too late. Relying on the representations made by Lanza, Jayne Lanza, and Lanza’s frontmen, Barnett continued purchasing OMDA shares on the open market. On or about September 9, 2003, Barnett became the majority shareholder of OMDA. Barnett’s ownership of fifty-two percent (52%) of OMDA’s outstanding voting stock was subsequently confirmed by OMDA’s transfer agent. Exercising his authority under Delaware law, Barnett assumed the management of OMDA. He removed Lanza’s frontmen from OMDA’s Board of Directors and appointed Mark Barnes (“Barnes”) and himself as directors. When Barnett assumed control of OMDA, under the terms of the Trust, the Subsidiaries remained under OMDA’s ownership and control.
78. In a letter to OMDA’s transfer agent dated September 24, 2003, Lanza claimed that Barnett did not own a majority of OMDA’s stock and that “my wife has voting control of the company through Special Voting Preferred.” Lanza was referring to OMDA Class D Stock allegedly negotiated by Lanza to various individuals and business entities, that had not been registered with the Delaware Secretary of State. Lanza also claimed that he was “still a consultant for OMDA” and instructed the transfer agent to provide no more information to Barnett or his attorney without written approval from either an OMDA director or a Lanza-controlled OMDA attorney. Shortly thereafter, an attorney for OMDA responded to Lanza’s September 24, 2003, letter by informing the transfer agent that OMDA’s management had changed hands and that Lanza’s instructions must be ignored because he had no authority to act on OMDA’s behalf. The transfer agent took no more action at the behest of Lanza and his frontmen.
ix. Lanza Hatches Scheme to Divest OMDA of its Subsidiaries
79. Once he realized that he had lost control of OMDA, Lanza hatched a scheme to divest OMDA of its Subsidiaries. Though he had repeatedly stated that the Subsidiaries were wholly-owned by OMDA, Lanza began to create a fictitious paper trail, attempting to muddy the waters regarding OMDA’s ownership of the Subsidiaries.
80. Lanza began by thwarting Barnett’s attempts to gather the corporate documentation pertaining to all of the assets owned or controlled by OMDA and its Subsidiaries. Barnett initially requested from Lanza the Subsidiaries’ stock certificates, accounting records, lease agreements, and bank statements. Barnett subsequently sought from Lanza all of the corporate records kept on behalf of OMDA and its Subsidiaries.
81. Lanza initially claimed that no stock certificates for the Subsidiaries existed and, therefore, he could not deliver them to Barnett. Lanza knew that this representation was false because he had instructed Michaels to retrieve the Subsidiaries’ stock certificates from Varnadore. Michaels is an attorney who had previously represented OMDA in Texas litigation matters. Lanza sought to erase all evidence that the Subsidiaries’ stock had been held in trust for the benefit of OMDA. On June 30, 2004, Michaels contacted Varnadore, who provided him the originals of the Subsidiaries’ stock certificates. Fortunately, Varnadore maintained copies of the documents he provided Michaels.
82. Although Lanza eventually provided some of the requested documentation, he continually gave far-fetched excuses why the majority of the requested documents were not available. Lanza went so far as to send Barnett’s partner, Robert G. Peterson (“Peterson”), on a wild goose chase to a storage facility in Palm Springs, California where Lanza’s daughter, Dei Lanza, was to provide him access to the requested documentation. Dei Lanza, however, never appeared.
83. As he continued to dodge Barnett’s demands to turn over the Subsidiaries’ corporate documentation, Lanza entered into an uneasy working relationship with Barnett. Indeed, Barnett permitted Lanza’s service companies, SHWJ and SHWJ Partnership, to refurbish some of the wells located on the Concorde Dome and Caddo Parish Properties. As Lanza brought additional wells into production, he was to be compensated in OMDA stock. Contrary to Lanza’s representations, however, neither SHWJ, nor the SHWJ Partnership, appear to have brought any additional wells into production. Moreover, Lanza cannot account for any of the monies invoiced by SHWJ or the SHWJ Partnership and paid by OMDA allegedly to do so.
84. On March 23, 2004, Barnett and OMDA’s new management demanded that Lanza and the Lanza-controlled companies, SHWJ, SHWJ Partnership, Wooldridge Production, and the Wooldridge Partnership, account to OMDA for all oil and gas revenues attributable to the operation of the Caddo Parish Properties under the March 15, 2001, Operating Agreement. When they failed to do so, OMDA terminated the March 15, 2001, Operating Agreement on April 16, 2004. OMDA commenced an investigation to determine the status of its oil and gas properties.
85. Unbeknownst to Barnett and OMDA’s new management, Lanza was actively working to wrest control of the Subsidiaries away from OMDA. For example, on or about November 9, 2004, IWIC, a Lanza-owned and controlled corporation, registered in the office of the Secretary of State of Texas under the assumed name of OMDA Oil and Gas Services, Inc. OMDA had not consented to this assumption. Rather, this was yet another attempt by Lanza and his frontmen to confuse the public as to the true ownership of OMDA’s wholly-owned subsidiary, Services.
86. The next day, Lanza contacted Varnadore and requested that he sign an instrument entitled “Revocation of Trust” (the “Revocation”), purporting to dissolve the Trust retroactive to February 1, 2002. Lanza did not disclose to Varnadore that he was not a director, officer, employee, agent, or person in control of OMDA, nor that Barnett and his management team had assumed control of OMDA’s day-to-day affairs. Varnadore signed the Revocation despite the fact that he had resigned as a trustee of the Trust nearly two-and-a-half years prior. Taylor and Anderson had previously signed the Revocation despite the fact that they were no longer directors, officers, employees or agents of OMDA and had no authority to do so.
87. Prior to the filing of the present law suit, neither Lanza, Taylor, nor Anderson disclosed to Barnett or OMDA’s new management the existence of the Trust, much less the Revocation. Accordingly, OMDA, now under the stewardship of Barnett and Barnes, did not have an opportunity to replace the Trustees originally designated under the Trust.
x. Lanza Illegally Converts OMDA’s Assets
88. Prior to requesting Varnadore to execute the Revocation, Lanza represented to the president of Barnabas Capital Corporation (“Barnabas”), David Anderson (“Anderson”), that he owned Management and had the authority to transfer an undivided fifty-percent (50% ) working interest in the Concorde Dome Properties to Barnabas. On November 1, 2004, acting without the knowledge or consent of Barnett or OMDA Management, Lanza sold an undivided fifty percent (50%) working interest in the Concorde Dome to Barnabas for $320,000. Lanza also purported to transfer one hundred percent (100%) of the tangible equipment located on the Concorde Dome Properties to Barnabas for an additional $180,000.
89. Rather than instructing Anderson to pay the proceeds from the illegal sale of the Concorde Dome Properties and the equipment located thereon to Management, Lanza instructed Anderson to wire payment for the interest and the equipment to an account owned by “Wooldridge Production.” Upon information and belief, “Wooldridge Production” is actually Wooldridge Production, a Nevada corporation formed by Lanza following the purchase of the Caddo Parish Properties. Lanza has subsequently formed a number of business entities using the name “Wooldridge” therein, including, but not limited to, Wooldridge Partnership, Wooldridge Production, and Wooldridge Production, LLC.
90. Emboldened by the “sale” of the Concorde Dome Properties, Lanza subsequently orchestrated the transfer of the Caddo Parish Properties to himself, his family and frontmen through a series of illegal and fraudulent transfers. Using a series of “strawmen” including, but not limited to, Micheal Karon, Reni Varshi, Robert Lumm, Bill Dorvall, Craig Alexander, Tom Vozenilick, Neeley and his wife Diane, Anderson and his wife Gene, Leasco Aviation, Inc. (a Nevada corporation to whom Lanza owed a debt for the rental of an airplane), and the Lanza-owned entity, Tea Fusion, Inc., Lanza fraudulently and illegally transferred the Caddo Parish Properties out of Management’s ownership. The majority of the transfers occurred between April 16, 2004 and September 29, 2005. Remarkably, several of the transactions were completed after OMDA filed this suit on April 4, 2005, seeking confirmation of its ownership of Management and its valuable oil and gas assets..
91. Without the documentation requested from Lanza, Barnett and OMDA’s new management were operating blind as to Lanza’s actions in converting OMDA’s assets. They were helpless to prevent Lanza from looting OMDA’s oil and gas assets.
92. Not surprisingly, Lanza also began using Management to engage in tax fraud by selling tax losses. On November 20, 2004, Lanza, purportedly as “Secretary,” on letterhead of OMDA made demand upon Wilbur for payment of a “note due over 11 months,” and provided that the “writeoff” of “$3,000,000 must be reduced to $300,000.” Lanza’s letter to Wilbur indicated that it was made in accordance with the opinion of “Mr. Kalivas,” who was allegedly acting as an attorney for OMDA and OMDA’s wholly-owned subsidiary, Management. Lanza’s use of a company he did not own, Management, to violate the tax laws by selling abusive tax shelters could result in additional liability and losses for OMDA.
xi. Lanza Forms Black Dragon To Hide His Theft
93. In December 2004, Lanza acquired a defunct OTCBB company and rechristened it Black Dragon. The purpose of Black Dragon was to receive the oil and gas properties stolen from OMDA. Not surprisingly, Lanza initially installed Anderson, his son Mario Lanza, Michael and Barry McFarland as directors.
94. Lanza, Anderson, as former or reputed OMDA directors, and Michael, as OMDA’s former legal counsel, knew or should have known that Black Dragon had been organized to perpetrate a fraud upon OMDA and the investing public. Nevertheless, they conspired to permit Black Dragon to receive assets fraudulently and illegally transferred from OMDA’s wholly-owned subsidiary, Management.
95. For example, upon information and belief, Lanza obtained an assignment of OMDA’s oil and gas assets located in Navarro County, Texas, and Caddo Parish, Louisiana, from Jerome, Jed, and Phil Schlegel (“the Schlegels”), placing them in Black Dragon. Lanza had previously fraudulently and illegally transferred the assets to the Schlegels from OMDA’s wholly-owned subsidiary, Management.
96. After Black Dragon was added as a party to the present suit on April 27, 2006, Michael, then acting as Black Dragon’s president, issued a statement claiming that Black Dragon owned the assets that had been fraudulently and illegally transferred from OMDA’s wholly-owned subsidiary, Management. In his June 6, 2006, statement issued on behalf of Black Dragon, Michael stated:
“[t]he properties related to [OMDA’s Fourth Amended Petition] comprise less than 5% of the current properties owned by Black Dragon.”
97. On or before March 28, 2007, Lanza issued a press release wherein he stated that Black Dragon’s entire board of directors, save for Neeley, had resigned. In their place, Lanza had been nominated as a Black Dragon director and acting president. Although a convicted felon and the recipient of a Consent Judgment rendered against him by the SEC, Lanza, once again, was in control of the business entity purporting to own OMDA’s assets.
xii. Lanza, His Family and Henchmen Attempted to Convert Fraudulently Obtained Stock To Takeover OMDA
98. Despite Lanza’s representations to Barnett that no preferred class of stock remained outstanding prior to August 25, 2003, commencing in early 2005, several individuals and entities submitted stock certificates purporting to be for shares of a Class D Stock to OMDA’s transfer agent located in Houston, Texas. A brief description of the Class D Stock submitted for redemption is as follows:
a. ISSUER: ORIGINAL MEDIA, INC. (Signed by Taylor, Acting Secretary)
Number Issued To Dated Shares
1039 Indian Wells Investment Company 02/29/00 300,000
In trust of Gusty Reikos submitted by Martin F. Goldman, attorney

b. ISSUER: O. MEDIA, INC. (Signed by Taylor, Acting Secretary)
Number Issued To Dated Shares
1008 007 Trust 04-28-99 100,000
1013 007 Trust 08-20-99 68,000
1019 007 Trust 10-29-99 142,500
1016 007 Trust 9-22-99 100,000
Submitted by Michaels, as substitute trustee

c. ISSUER: O. MEDIA, INC. (Signed by Marcela Rivera, Secretary)
Number Issued To Dated Shares
1012 Indian Wells Investment Company 04/30/99 140,000
(Purportedly converted on 09/03/02 by IWIC, signed by Lanza, President, to Wilbur)
1024 Topnet, Inc. 09-30-99 345,800
(Purportedly converted on 09/03/02 by Topnet, Inc., signed by Mario Lanza President, to Wilbur, and transferred by instrument 11/11/2004)

99. On or about March 4, 2005, Wilbur presented Class D Stock certificates numbered 1012 and 1024, demanding their conversion to OMDA common shares via letter delivered to OMDA’s principal office located in Houston, Texas.
100. On or about January 16, 2005, Michael presented Class D Stock certificates numbered 1008, 1013, 1016, and 1019, demanding their conversion to OMDA common shares on behalf of an entity dubiously coined the 007 Trust via letter delivered to OMDA’s principal office located in Houston, Texas. Michael purported to be a substitute trustee for the 007 Trust; however, despite its numerous requests, OMDA has never been provided any documentation regarding the formation or existence of the 007 Trust. Based on the prior representation of Lanza, and upon information and belief, the beneficiaries of the 007 Trust are Lanza’s family members.
101. Martin Goldman, a California attorney, presented Class D Stock certificate number 1039, demanding its conversion to OMDA common shares. Class D Stock certificate number 1039 was initially issued to IWIC and purportedly transferred to Lanza’s former lawyers who handled his criminal case that resulted in his conviction for tax evasion in 1997. Goldman was obviously aware that Lanza was a con man and convicted felon by a simple reading of the indictment. Accordingly, he knew or should have known that any securities transferred to his clients by Lanza were at best, worthless, and at worst, fraudulent.
102. The claims for the conversion of the bogus Class D Stock certificates harmed OMDA by creating insecurity among OMDA’s stockholders as to the ownership and control of the company. Moreover, the Class D Stock certificates were allegedly convertible into several millions of shares of OMDA common stock. If the Class D Stock had been converted into OMDA common stock, then the ownership positions of the legitimate OMDA shareholders would have been significantly diluted. Clearly, Lanza and his frontmen were attempting to sabotage OMDA’s current management after it assumed control of OMDA’s day-to-day operations.
103. On July 29, 2005, counsel for OMDA filed a Motion for Partial Summary Judgment, asking this Court to declare each of the Class D Stock certificates void ab initio under the laws of the State of Delaware because the necessary corporate resolution approving issuance of the Class D Stock had not been filed with the Delaware Secretary of State.
104. On February 21, 2007, this Court granted OMDA’s Motion for Partial Summary Judgment and invalidated the Class D Stock certificates as void ab initio. In addition, this Court has not foreclosed OMDA’s ability to recover attorney’s fees for obtaining this portion of declaratory relief from the defendants.
xiii. Barnett Discovers Lanza’s Nefarious Acts and is Compelled to Enter into a Settlement Agreement with Barnabas
105. On or about the same time that various individuals and entities began presenting Class D Stock certificates to OMDA’s transfer agent, Barnett and OMDA’s new management learned that Lanza had been representing to various third parties that he owned the Subsidiaries and had the authority to negotiate the sale of their assets. Upon further investigation, Barnett and OMDA’s new management team discovered that Lanza, his family, and henchmen had been transferring OMDA’s oil and gas interests, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties, to various third parties.
106. Barnett and OMDA’s new management team severed all remaining ties with Lanza, his family, and henchmen and began the arduous task of determining the whereabouts of its assets. This process was made exceptionally difficult because, despite Barnett’s repeated requests, Lanza refused to turn over any of the documentation pertaining to OMDA and its wholly-owned Subsidiaries. To date, Lanza has not fully complied with OMDA’s discovery requests. It will likely require Court intervention to force him to do so. Until all of the documentation held by Lanza is produced, OMDA will not know the full extent of the damage done to it.
107. Shortly thereafter, Barnett and OMDA’s new management team initially learned of the transfer of the Concorde Dome Properties to Barnabas.
108. Counsel for Barnabas contacted OMDA and, in an effort to stave off OMDA’s expected legal action against Barnabas to recover its stolen assets, suggested a compromise arrangement whereby OMDA would receive a lower percentage working interest in the Concorde Dome Properties.
109. On May 20, 2005, OMDA executed a Settlement Agreement with Barnabas and Tengasco, Inc., as authorized agent for Hoactzin Partners, L.P., Barnabas’s principal investor.
110. OMDA continued to investigate Lanza’s dealings and discovered that he had also converted OMDA’s oil and gas assets located in Louisiana, including, but not limited to, the Caddo Parish Properties.
xiv. Lanza Begins His Elaborate Corporate Shell Game
111. On April 4, 2005, OMDA filed the present suit in an effort to resolve the ownership dispute regarding Lanza’s claim that he continued to own and control OMDA and to recover OMDA’s assets converted by Lanza.
112. Despite the filing of the present suit, Lanza, his family, and frontmen continued, and upon information and belief, still continue to transfer OMDA’s assets among and between a series of Lanza-owned or controlled entities. Often with the help of his wife, Jayne, and frontmen, Lanza has created numerous shell corporations and partnerships in an effort to further obscure the true ownership of OMDA’s assets. In some instances, he has used similar-sounding DBA’s to further confuse the investing public.
113. Upon information and belief, the following Lanza-owned or controlled companies have owned or received the benefits of the purported ownership of OMDA’s assets: Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ and SHWJ Partnership. Of course, without full and complete disclosure from Lanza, all of the entities that have owned or received the benefits of the purported ownership of OMDA’s assets remain uncertain. OMDA reserves the right to name additional recipients of Lanza’s ill-gotten gains as they become known.
114. Upon information and belief, Lanza, through his various Lanza-owned or controlled companies, has received the benefit of the sale of any oil and gas produced from OMDA’s converted oil and gas assets since September 9, 2003.
115. Upon information and belief, Lanza also funds his wife’s restaurant, Jayne Marie on Cross Lake, located in Shreveport, Louisiana, with proceeds from the sale of oil and gas produced from OMDA’s converted oil and gas assets.
116. Upon information and belief, Lanza, through his various Lanza-owned or controlled companies, routinely sells crude oil and pumped gas to Genesis Energy, LP, located in Houston, Texas. Accordingly, the conversion of OMDA’s oil and gas assets has been consummated in Harris County, Texas.
xv. OMDA Has Suffered Irepparable Harm
117. On November 1, 2004, OMDA common stock traded on the Pink Sheet exchange at a closing bid of $0.031 per share.
118. Most recently, OMDA common stock traded on the Pink Sheet exchanges at a closing bid of $0.0001 per share.
119. The market drop of $0.0309 per share was a direct and foreseeable consequence of the misappropriation of OMDA’s oil and gas assets. The amount of damage to OMDA is at least $50,000,000.
120. Every day that the convicted felon Lanza and the remaining defendants continue to hold themselves out to be persons in control of OMDA, or its Subsidiaries, and their respective assets, they inflict immeasurable damages to the business reputations and good will of both OMDA and its Subsidiaries.
121. Upon information and belief, neither Lanza nor the remaining defendants are in a financial position to pay the damages caused by their conduct described above.
xvi. The Investing Public Is Being Harmed
122. The conduct of Lanza and the remaining defendants, as described in the paragraphs above, has been a detriment to the investing public and should be enjoined to protect the investing public’s interest.
123. In particular, Lanza and the remaining defendants have purported to transfer OMDA’s assets to unwitting individuals who may not have been made aware that neither Lanza nor the remaining defendants had the authority to do so.
124. Upon information and belief, Lanza and the remaining defendants are currently representing that they own OMDA’s assets and continue try to transfer same without the authority to so.
125. The conduct of Lanza and the remaining defendants, as described in the paragraphs above, has operated to mislead and confuse the investing public so as to permit Lanza and the remaining defendants to receive the benefits of OMDA’s business reputation and good will.
126. The Court should enter a Temporary Restraining Order (“TRO”), Temporary Injunction, and Permanent Injunction barring Lanza, Anderson, Taylor, and each of the other Defendants and all former Lanza-affiliated directors of OMDA from holding themselves out to be agents or owners of any interest or stock in any of the OMDA Subsidiaries.

G. CAUSES OF ACTION
REQUEST FOR DECLARATORY RELIEF

(All Defendants)

127. A genuine controversy has arisen and now exists between OMDA and the defendants pertaining to the facts in controversy set forth above. Pursuant to the Texas Uniform Declaratory Judgments Act, Texas Civil Practice & Remedies Code Section 37.001 et seq., plaintiff OMDA requests the Court to make the following declarations in its favor:
a. Plaintiff OMDA is the sole shareholder of Management;

b. Plaintif, OMDA is the sole shareholder of Services;

c. Plaintiff OMDA is the sole shareholder of SHWJ;

d. Plaintiff OMDA, either directly or by and through its wholly-owned subsidiary, Management, is the owner of the Concorde Dome Properties;

e. Plaintiff OMDA, either directly or by and through its wholly-owned subsidiary, Management, is the owner of the Caddo Parish Properties;

f. Plaintiff OMDA, either directly or by and through its wholly-owned subsidiary, Management, is the owner of any and all assets on OMDA’s books as of September 9, 2003;

g. That debts allegedly owed by OMDA to Lanza, Jayne Lanza, Mario Lanza, Dei Lanza, Mardyne, Inc., Topnet, Inc., IWIC and Andy Geiss are not rooted in fact. Rather, the debts allegedly owed by OMDA to Lanza, Jayne Lanza, Mario Lanza, Dei Lanza, Mardyne, Inc., Topnet, Inc., IWIC and Andy Geiss are fictitious and should be rendered void;

h. That the Class D Stock certificate numbered 1012 issued in the name of IWIC dated 04/30/99 for 140,000 of OMDA common shares is void ab initio;

i. That the Class D Stock certificate number 1013 issued in the name of the 007 Trust dated 08/20/99 for 68,000 of OMDA common shares is void ab initio;

j. That the Class D Stock certificate number 1008 issued in the name of 007 Trust dated 04/28/99 for 100,000 of OMDA common shares is void ab initio;

k. That the Class D Stock certificate number 1016 issued in the name of 007 Trust dated 10/29/99 for 100,000 of OMDA common shares is void ab initio;

l. That the Class D Stock certificate number 1019 issued in the name of 007 Trust dated 09/22/99 for 142,500 of OMDA common shares is void ab initio;

m. That the Class D Stock certificate number 1024 issued in the name of Topnet, Inc. dated 09/30/99 for 345,800 of OMDA common shares is void ab initio; and

n. That the Class D Stock certificate number 1039 issued in the name of IWIC dated 02/29/00 for 300,000 of OMDA common shares is void ab initio.

CONVERSION

(Lanza, Michael, Anderson, Neeley, Taylor)

128. On or before September 9, 2003, OMDA owned and had legal and rightful possession of the stock of its wholly-owned Subsidiaries.
129. On or before September 9, 2003, OMDA and its wholly-owned Subsidiaries owned and had legal and rightful possession of the corporate documentation of OMDA and its wholly-owned Subsidiaries, including, but not limited to, incorporating documents, minute books, stock certificates, accounting records, bank account records, and leasehold information.
130. On or before September 9, 2003, OMDA and its wholly-owned subsidiary, Management, owned and had legal and rightful possession of certain oil and gas wells and leases, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties.
131. On or before September 9, 2003, OMDA, and its wholly-owned subsidiary, Management, owned and had legal and rightful possession of certain proceeds generated from the operation of the aforementioned oil and gas wells and leases.
132. Following a change in OMDA’s management on September 9, 2003, Lanza, Michael, Anderson, Neeley, and Taylor wrongfully exercised dominion and control over OMDA’s wholly-owned Subsidiaries.
133. Following a change in OMDA’s management on September 9, 2003, Lanza, Michael, Anderson, Neeley, and Taylor wrongfully exercised dominion and control over the corporate documentation of OMDA and its wholly-owned Subsidiaries.
134. Following a change in OMDA’s management on September 9, 2003, Lanza, Michael, Anderson, Neeley, and Taylor wrongfully exercised dominion and control over the aforementioned oil and gas wells and leases.
135. Following a change in OMDA’s management on September 9, 2003, Lanza, Michael, Anderson, Neeley, and Taylor wrongfully exercised dominion and control over certain proceeds generated from the operation of the aforementioned oil and gas wells and leases.
136. As a result of the wrongful conduct of Lanza, Michael, Anderson, Neeley, and Taylor, OMDA has suffered significant injury.
CONVERSION

(Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ, and SHWJ Partnership)

137. On or before September 9, 2003, OMDA and its wholly-owned subsidiary, Management, owned and had legal and rightful possession of certain oil and gas wells and leases, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties.
138. On or before September 9, 2003, OMDA and its wholly-owned subsidiary, Management, owned and had legal and rightful possession of certain proceeds generated from the operations of the aforementioned oil and gas wells and leases.
139. Following a change in OMDA’s management on September 9, 2003, Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ, and SHWJ Partnership have wrongfully exercised dominion and control over the aforementioned oil and gas wells and leases.
140. Following a change in OMDA’s management on September 9, 2003, Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldride Production, LLC, LLM, SHWJ, and SHWJ Partnership have wrongfully exercised dominion and control over proceeds generated from the operations of the aforementioned oil and gas wells and leases.
141. As a result of the wrongful conduct of Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ, and SHWJ Partnership, OMDA has suffered significant injury.
VIOLATION OF THE TEXAS THEFT LIABILITY ACT
(Lanza, Michael, Anderson, Neeley, Taylor)

142. On or before September 9, 2003, OMDA owned and had legal and rightful possession of the stock of its wholly-owned Subsidiaries.
143. On or before September 9, 2003, OMDA and its wholly-owned Subsidiaries owned and had legal and rightful possession of the corporate documentation of OMDA and its wholly-owned Subsidiaries, including, but not limited to, incorporating documents, minute books, stock certificates, accounting records, bank account records and leasehold information.
144. On or before September 9, 2003, OMDA and its wholly-owned subsidiary, Management, owned and had legal and rightful possession of certain oil and gas wells and leases, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties.
145. On or before September 9, 2003, OMDA and its wholly-owned subsidiary, Management, owned and had legal and rightful possession of certain proceeds generated from the operation of the aforementioned oil and gas wells and leases.
146. Following a change in OMDA’s management on September 9, 2003, Lanza, Michael, Anderson, Neeley, and Taylor acted with the wrongful intent to deprive OMDA’s of its wholly-owned Subsidiaries.
147. Following a change in OMDA’s management on September 9, 2003, Lanza, Michael, Anderson, Neeley, and Taylor acted with the wrongful intent to deprive OMDA and its wholly-owned Subsidiaries of its corporate documentation.
148. Following a change in OMDA’s management on September 9, 2003, Lanza, Michael, Anderson, Neeley, and Taylor acted with the wrongful intent to deprive OMDA of the aforementioned oil and gas wells and leases.
149. Following a change in OMDA’s management on September 9, 2003, Lanza, Michael, Anderson, Neeley, and Taylor acted with the wrongful intent to deprive OMDA of proceeds generated from the aforementioned oil and gas wells and leases.
150. As a result of the voluntary and intentional wrongful conduct of Lanza, Michael, Anderson, Neeley, and Taylor, OMDA has suffered significant injury.
VIOLATION OF THE TEXAS THEFT LIABILITY ACT
(Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ and SHWJ Partnership)

151. On or before September 9, 2003, OMDA and its wholly-owned subsidiary, Management, owned and had legal and rightful possession of certain oil and gas wells and leases, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties.
152. On or before September 9, 2003, OMDA and its wholly-owned subsidiary, Management, owned and had legal and rightful possession of proceeds generated from the operations of the aforementioned oil and gas wells and leases.
153. Following a change in OMDA’s management on September 9, 2003, Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ, and SHWJ Partnership have acted with the wrongful intent to deprive OMDA of the aforementioned oil and gas wells and leases.
154. Following a change in OMDA’s management on September 9, 2003, Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ, and SHWJ Partnership have acted to wrongfully deprive OMDA of proceeds generated from the operations of the aforementioned oil and gas wells and leases.
155. As a result of the voluntary and intentional conduct of Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ, and SHWJ Partnership, OMDA has suffered significant injury.
CONSPIRACY, CONCERT OF ACTION, ASSISTING AND PARTICIPATING
AND ASSISTING OR ENCOURAGING

(Lanza, Jayne Lanza, Michael, Anderson, Neeley, Taylor)

156. Lanza, Jane Lanza, Michael, Anderson, Neeley, and Taylor, have knowingly and intentionally assisted, encouraged, acted in concert, or participated in the attempted conversion or theft of OMDA’s oil and gas assets, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties, and the proceeds generated therefrom. In doing so, Lanza, Jane Lanza, Michael, Anderson, Neeley, and Taylor have assisted, encouraged, acted in concer,t or participated in the one or more of the following acts resulting in a violation of a duty or duties owed to OMDA:
a. causing OMDA to incur fictitious debt whereby Lanza, his family, and frontmen were able to line their respective pockets with significant amounts of OMDA stock;
b. using the proceeds of the sale of OMDA securities to repay fictitious debt whereby Lanza, his family, and frontmen were able to line their pockets with monies paid to retire this fictitious debt;
c. attempting to issue unregistered OMDA Class D Stock to various third parties allegedly in exchange for the forgiveness of OMDA debt, both real and fictitious;
d. causing OMDA to incur fictitious debt, enabling Lanza to allegedly “purchase” OMDA’s wholly-owned subsidiary, SHWJ, for the apparent forgiveness of said debts;
e. using monies generated from the sale of OMDA common stock to fund the purchase of certain oil and gas wells and leases, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties, on behalf of its wholly-owned subsidiary, Management, and then claiming that Management was not OMDA’s wholly-owned subsidiary;
f. issuing press releases on behalf of OMDA stating that it had purchased certain oil and gas wells and leases, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties, on behalf of its wholly-owned subsidiary, Management, and then claiming that Management was not OMDA’s wholly-owned subsidiary;
g. Prior to September 9, 2003, making affirmative statements of fact that OMDA had purchased certain oil and gas wells and leases, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties, on behalf of its wholly-owned subsidiary, Management, and then claiming that Management was not OMDA’s wholly-owned subsidiary;
h. fraudulently and illegally attempting to convert or steal OMDA’s assets consisting of certain oil and gas wells and leases, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties, receivables, cash, and documentation;
i. Prior to September 9, 2003, making affirmative statements of fact that OMDA had no outstanding classes of preferred stock;
j. After September 9, 2003, attempting to convert Class D Stock allegedly issued prior to September 9, 2003, for shares of OMDA common stock;
k. failing to maintain adequate corporate and financial records permitting the defendants to fraudulently account for all assets and cash that passed through OMDA; and
l. drafting back-dated minutes, attempting to create an alternate paper trail authorizing the incurring of this fictitious debt;
157. As a result of the assistance, encouragement, concerted action or participation of Lanza, Michael, Anderson, Neeley, and Taylor, OMDA has suffered significant injury.

CONSPIRACY, CONCERT OF ACTION, ASSISTING AND PARTICIPATING
AND ASSISTING OR ENCOURAGING

(Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ, and SHWJ Partnership)

158. Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ, and SHWJ Partnership have knowingly and intentionally assisted, encouraged, acted in concert, or participated in the attempted conversion or theft of OMDA’s oil and gas assets, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties, and the proceeds generated therefrom. In doing so, Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ, and SHWJ Partnership have assisted, encouraged, acted in concert or participated in the one or more of the following acts resulting in a violation of a duty or duties owed to OMDA:
a. fraudulently and illegally attempting to convert or steal OMDA’s assets consisting of certain oil and gas wells and leases, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties, receivables, cash, and documentation;
b. After September 9, 2003, attempting to convert Class D Stock allegedly issued prior to September 9, 2003 for shares of OMDA common stock;
159. As a result of the assistance, encouragement, concerted action, or participation of Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ, and SHWJ Partnership, OMDA has suffered significant injury.
FRAUD

(Lanza, Jayne Lanza, Michael, Anderson, Neeley, Taylor)
160. Lanza, Jayne Lanza, Michael, Wilbur, Anderson, Neeley, and Taylor made certain material representations to plaintiff OMDA and others, with full-knowledge that said representations were false before, during, and after they were made.
161. In perpetrating their fraud, Lanza, Jayne Lanza, Michael, Wilbur, Anderson, Neeley, and Taylor made one or more of the following statements or statements in effort to effectuate a fraudulent transfer of OMDA’s assets:
a. made statements both orally and in writing that caused OMDA to incur fictitious debt, whereby Lanza, his family, and frontmen were able to line their respective pockets with significant amounts of OMDA stock;
b. made statements both orally and in writing that authorized the use of proceeds from the sale of OMDA securities to repay fictitious debt whereby Lanza, his family, and frontmen were able to line their pockets with monies paid to retire this fictitious debt;
c. made statements both orally and in writing in attempting to issue unregistered OMDA Class D Stock to various third parties, allegedly in exchange for the forgiveness of OMDA debt, both real and fictitious;
d. made statements both orally and in writing causing OMDA to incur fictitious debt, enabling Lanza to allegedly “purchase” OMDA’s wholly-owned subsidiary, SHWJ, for the apparent forgiveness of said debts;
e. made statements both orally and in writing permitting the use of monies generated from the sale of OMDA common stock to fund the purchase of certain oil and gas wells and leases, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties, on behalf of its wholly-owned subsidiary, Management, and then claiming that Management was not OMDA’s wholly-owned subsidiary;
f. made statements both orally and in writing resulting in the issuance of press releases on behalf of OMDA stating that it had purchased certain oil and gas wells and leases, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties, on behalf of its wholly-owned subsidiary, Management, and then claiming that Management was not OMDA’s wholly-owned subsidiary;
g. prior to September 9, 2003, making affirmative statements of fact that OMDA had purchased certain oil and gas wells and leases, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties, on behalf of its wholly-owned subsidiary, Management, and then claiming that Management was not OMDA’s wholly-owned subsidiary;
h. made statements both orally and in writing fraudulently and illegally attempting to convert or steal OMDA’s assets consisting of certain oil and gas wells and leases, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties, receivables, cash and documentation;
i. prior to September 9, 2003, making affirmative statements of fact that OMDA had no outstanding classes of preferred stock;
j. after September 9, 2003, making statements both orally or in writing attempting to convert Class D Stock allegedly issued prior to September 9, 2003, for shares of OMDA common stock;
k. made statements both orally or in writing resulting in the drafting of back-dated minutes attempting to create an alternate paper trail fraudulently authorizing the incurring of this fictitious debt;
162. Lanza, Jayne Lanza, Michael, Wilbur, Anderson, Neeley, and Taylor made the above statements with the intent of defrauding OMDA and OMDA’s new management.
163. OMDA relied on the fraudulent representations of Lanza, Jayne Lanza, Michael, Wilbur, Anderson, Neeley, and Taylor to its detriment. The conduct of Lanza, Jayne Lanza, Michael, Wilbur, Anderson, Neeley, and Taylor has caused OMDA to suffer significant injury.
FRAUD

(Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ, and SHWJ Partnership)

164. Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ, and SHWJ Partnership made certain material representations to plaintiff OMDA and others, with full-knowledge that said representations were false before, during and after they were made.
165. In perpetrating their fraud, Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ, and SHWJ Partnership made one or more of the following statements in and effort to effectuate a fraudulent transfer of OMDA’s assets:
a. made statements both orally and in writing fraudulently and illegally attempting to convert or steal OMDA’s assets consisting of certain oil and gas wells and leases, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties, receivables, cash and documentation. Specifically, Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ and SHWJ Partnership have claimed that OMDA is not the rightful owner of the aforementioned oil and gas wells and leases;
b. after September 9, 2003, made statements both orally and in writing attempting to convert Class D Stock allegedly issued prior to September 9, 2003, for shares of OMDA common stock;
166. Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ, and SHWJ Partnership made the above statements with the intent of defrauding OMDA and OMDA’s new management.
167. OMDA relied on the fraudulent representations of Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ and SHWJ Partnership to its detriment. The conduct of Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ, and SHWJ Partnership has caused OMDA to suffer significant injury

STATUTORY FRAUD

(Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ, and SHWJ Partnership)

168. Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ, and SHWJ Partnership made certain material misrepresentaitons to plaintiff OMDA and others pertaining to the redemption of the Class D Stock and the disposition of OMDA’s assets, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties.
169. In perpetrating their fraud, Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ, and SHWJ Partnership made one or more of the following in an effort to effectuate a fraudulent transfer of OMDA’s assets:
a. made statements both orally and in writing in attempting to issue unregistered OMDA Class D Stock to various third parties, allegedly in exchange for the forgiveness of OMDA debt, both real and fictitious;
b. made statements both orally and in writing fraudulently and illegally attempting to convert or steal OMDA’s assets consisting of certain oil and gas wells and leases, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties;
c. prior to September 9, 2003, making affirmative statements of fact that OMDA had no outstanding classes of preferred stock;
d. after September 9, 2003, making statements both orally and in writing attempting to convert Class D Stock allegedly issued prior to September 9, 2003, for shares of OMDA common stock;
e. made statements both orally and in writing resulting in the drafting of back-dated minutes, attempting to create an alternate paper trail authorizing the incurring of this fictitious debt;
f. made statements both orally and in writing fraudulently and illegally attempting to convert or steal OMDA’s assets consisting of certain oil and gas wells and leases, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties. Specifically, Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ, and SHWJ Partnership have claimed that OMDA is not the rightful owner of the aforementioned oil and gas wells and leases;
g. after September 9, 2003, made statements both orally and in writing attempting to convert Class D Stock allegedly issued prior to September 9, 2003, for shares of OMDA common stock;
170. OMDA relied on the fraudulent representations of Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ and SHWJ Partnership to its detriment. The conduct of Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ, and SHWJ Partnership has caused OMDA to suffer significant injury.
NEGLIGENT MISREPRESENTATION

(Lanza, Jayne Lanza, Michael, Anderson, Neeley, Taylor)
171. Lanza, Jayne Lanza, Michael, Wilbur, Anderson, Neeley, and Taylor made certain material representations to plaintiff OMDA and others that proved to be false and misleading before, during, and after they were made.
172. In providing this false and misleading information to OMDA, Lanza, Jayne Lanza, Michael, Wilbur, Anderson, Neeley, and Taylor made the misrepresentations in an effort to provide false guidance to OMDA and others. Lanza, Jayne Lanza, Michael, Wilbur, Anderson, Neeley, and Taylor made one or more of the following mistatements without exercising reasonable care or competence in verifying the information. In doing so, Lanza, Jayne Lanza, Michael, Wilbur, Anderson, Neeley, and Taylor:
a. made statements both orally and in writing that caused OMDA to incur fictitious debt whereby Lanza, his family, and frontmen were able to line their respective pockets with significant amounts of OMDA stock;
b. made statements both orally and in writing that authorized the use of proceeds from the sale of OMDA securities to repay fictitious debt whereby Lanza, his family, and frontmen were able to line their pockets with monies paid to retire this fictitious debt;
c. made statements both orally and in writing in attempting to issue unregistered OMDA Class D Stock to various third parties, allegedly in exchange for the forgiveness of OMDA debt, both real and fictitious;
d. made statements both orally and in writing causing OMDA to incur fictitious debt, enabling Lanza to allegedly “purchase” OMDA’s wholly-owned subsidiary, SHWJ, for the apparent forgiveness of said debts;
e. made statements both orally and in writing permitting the use of monies generated from the sale of OMDA common stock to fund the purchase of certain oil and gas wells and leases, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties, on behalf of its wholly-owned subsidiary, Management, and then claiming that Management was not OMDA’s wholly-owned subsidiary;
f. made statements both orally and in writing resulting in the issuance of press releases on behalf of OMDA stating that it had purchased certain oil and gas wells and leases, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties, on behalf of its wholly-owned subsidiary, Management, and then claiming that Management was not OMDA’s wholly-owned subsidiary;
g. prior to September 9, 2003, making affirmative statements of fact that OMDA had purchased certain oil and gas wells and leases, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties, on behalf of its wholly-owned subsidiary, Management, and then claiming that Management was not OMDA’s wholly-owned subsidiary;
h. made statements both orally and in writing fraudulently and illegally attempting to convert or steal OMDA’s assets consisting of certain oil and gas wells and leases, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties, receivables, cash, and documentation;
i. prior to September 9, 2003, making affirmative statements of fact that OMDA had no outstanding classes of preferred stock;
j. after September 9, 2003, making statements both orally and in writing attempting to convert Class D Stock allegedly issued prior to September 9, 2003 for shares of OMDA common stock;
k. made statements both orally and in writing resulting in the drafting of back-dated minutes attempting to create an alternate paper trail authorizing the incurring of this fictitious debt;
173. OMDA relied on the misrepresentations of Lanza, Jayne Lanza, Michael, Wilbur, Anderson, Neeley, and Taylor to its detriment. The conduct of Lanza, Jayne Lanza, Michael, Wilbur, Anderson, Neeley, and Taylor has caused OMDA to suffer significant injury.
NEGLIGENT MISREPRESENTATION

(Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ, and SHWJ Partnership)

174. Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ, and SHWJ Partnership made certain material representations to plaintiff OMDA and others that proved to be false and misleading before, during and after they were made.
175. In providing this false and misleading information to OMDA, Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ, and SHWJ Partnership made the misrepresentations in an effort to provide false guidance to OMDA and others. Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ, and SHWJ Partnership made one or more of the following misstatements without exercising reasonable care or competence in verifying the information. In doing so, Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ, and SHWJ Partnership:
a. made statements both orally and in writing fraudulently and illegally attempting to convert or steal OMDA’s assets consisting of certain oil and gas wells and leases, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties, receivables, cash, and documentation. Specifically, Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ and SHWJ Partnership have claimed that OMDA is not the rightful owner of the aforementioned oil and gas wells and leases;
b. after September 9, 2003, made statements both orally and in writing attempting to convert Class D Stock allegedly issued prior to September 9, 2003, for shares of OMDA common stock;
176. OMDA relied on the representations of Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ, and SHWJ Partnership to its detriment. The conduct of Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ, and SHWJ Partnership has caused OMDA to suffer significant injury
SUIT TO QUIET TITLE
(All Defendants)
177. At all times relevant, OMDA has owned and continues to own a possessory interest in certain oil and gas wells and leases, including, but not limited to, the Concorde Dome Properties and Caddo Parish Properties.
178. On or after September 9, 2003, Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ, and SHWJ Partnership have uttered disparaging statements regarding the ownership of OMDA’s oil and gas wells and leases, including, but not limited to, the Concorde Dome Properties and Caddo Parish Properties have uttered and have published false statements regarding their purported ownership thereof.
179. OMDA requests that this Court enter judgment declaring OMDA the rightful owner of the oil and gas wells and leases, including, but not limited to, the Concorde Dome Properties and Caddo Parish Properties.
BREACH OF FIDUCIARY DUTY
(Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor)
180. Jayne Lanza, Wilbur, Anderson, Neeley, and Taylor have breached their fiduciary duties owed to OMDA, as its former directors. The duties breached by Jane lanza, Wilbur, Anderson, Neeley and Taylor, include, among other things:
a. causing OMDA to incur fictitious debt whereby Lanza, his family and frontmen were able to line their respective pockets with significant amounts of OMDA stock;
b. using the proceeds of the sale of OMDA securities to repay fictitious debt whereby Lanza, his family and frontmen were able to line their pockets with monies paid to retire this fictitious debt;
c. attempting to issue unregistered OMDA Class D Stock to various third parties, allegedly in exchange for the forgiveness of OMDA debt, both real and fictitious;
d. causing OMDA to incur fictitious debt, enabling Lanza to allegedly “purchase” OMDA’s wholly-owned subsidiary, SHWJ, for the apparent forgiveness of said debts;
e. using monies generated from the sale of OMDA common stock to fund the purchase of certain oil and gas wells and leases, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties, on behalf of its wholly-owned subsidiary, Management, and then claiming that Management was not OMDA’s wholly-owned subsidiary;
f. issuing press releases on behalf of OMDA stating that it had purchased certain oil and gas wells and leases, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties, on behalf of its wholly-owned subsidiary, Management, and then claiming that Management was not OMDA’s wholly-owned subsidiary;
g. Prior to September 9, 2003, making affirmative statements of fact that OMDA had purchased certain oil and gas wells and leases, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties, on behalf of its wholly-owned subsidiary, Management, and then claiming that Management was not OMDA’s wholly-owned subsidiary;
h. fraudulently and illegally attempting to convert or steal OMDA’s assets consisting of certain oil and gas wells and leases, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties, receivables, cash, and documentation;
i. Prior to September 9, 2003, making affirmative statements of fact that OMDA had no outstanding classes of preferred stock;
j. After September 9, 2003, attempting to convert Class D Stock allegedly issued prior to September 9, 2003, for shares of OMDA common stock;
k. failing to maintain adequate corporate and financial records permitting the defendants to fraudulently account for all assets and cash that passed through OMDA; and
l. drafting back-dated minutes, attempting to create an alternate paper trail authorizing the incurring of this fictitious debt.

181. Neither Jayne Lanza, Wilbur, Anderson, Neeley, nor Taylor are entitled to the exculpatory provisions in OMDA’s Amended and Restated Certificate of Incorporation, Article VIII, regarding former directors because:
a. each of the breaches outlined above were breaches of their duty of loyalty to OMDA and its stockholders;

b. Jayne Lanza, Wilbur, Anderson, Neeley, and Taylor have acted without good faith;

c. Jayne Lanza, Wilbur, Anderson, Neeley, and Taylor have committed acts that involve intentional misconduct or a knowing violation of law; or

d. Jayne Lanza, Wilbur, Anderson, Neeley, and Taylor have engaged in self-dealing and entered into transactions from which those directors received improper personal benefit.

182. Anderson and Taylor breached their fiduciary duties imposed under the Trust by:
a. failing to keep the Subsidiaries’ stock certificates safe from Lanza and his agents, who seized control of the Subsidiaries’ stock certificates;

b. failing to inform OMDA’s new management that they had accepted the stock of the Subsidiaries to hold for the benefit of OMDA;

c. signing the Revocation while knowing that OMDA’s management had changed and that OMDA’s new management was actively seeking possession of the Subsidiaries’ stock they held for the benefit of OMDA; and
d. attempting to convert the Subsidiaries’ stock in contravention of OMDA’s best interests.

183. Michael, as OMDA’s former counsel, breached his fiduciary duty to OMDA by permitting Lanza, his family, and henchmen to transfer OMDA’s assets, including, but not limited to, the Caddo Parish Properties, ultimately into an entity, Black Dragon, for which he was purportedly acting as president.
184. The conduct of Jayne Lanza, Wilbur, Michael, Anderson, Neeley, and Taylor has caused OMDA significant injury.
NEGLIGENCE
(Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor)
185. In the alternative, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, and Taylor acted negligently in failing to maintain control of OMDA’s assets, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties.
186. The negligence of Jayne Lanza, Wilbur, Michael, Anderson, Neeley, and Taylor has proximately caused OMDA significant injury.
INJUNCTIVE RELIEF
187. To protect the public, OMDA’s shareholders, and OMDA itself, the Court is asked to impose, after adequate hearing and notice, an Order restraining and enjoining Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ, and SHWJ Partnership from transferring any of OMDA’s oil and gas assets, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties, to any additional entity or person until the present dispute over their ownership is resolved. Further, this Court should enter an Order imposing a constructive trust for the benefit of OMDA, placing the proceeds from the sale of any oil or gas extracted from OMDA’s oil and gas assets, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties.
188. OMDA does not have an adequate remedy at law if Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ, and SHWJ Partnership not only continue to receive the benefits of purported ownership of OMDA’s aforementioned oil and gas assets and the proceeds thereof, but also continue to purportedly transfer the right, title and ownership to co-conspirators or unwitting third parties. Specifically, OMDA will incur the following damages:
a. the incalculable reduction in the value of OMDA’s shares due to the confusion caused by Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ, and SHWJ Partnership regarding the ownership of OMDA’s oil and gas assets, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties. Specifically, OMDA will incur the following damages;
b. incalculable financial losses caused by the failure of Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ, and SHWJ Partnership to adequately operate OMDA’s oil and gas assets, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties;
c. the loss of incalculable damages that Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ, and SHWJ Partnership are not in a position to repay if a monetary judgement were levied against them;
d. the loss of the right to manage, operate or sell its oil and gas assets, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties;
e. the inability to recover its stolen oil and gas assets, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties, because of the difficulty of tracing the ownership or chain of title of same through the repeated “sales” or other alleged disposition by Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ, and SHWJ Partnership; and
f. the incurring of significant attorneys’ fees in establishing OMDA’s rightful ownership of its oil and gas assets, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties.
189. Pursuant to the Texas Rules of Civil Procedure Section 680, OMDA is entitled to injunctive relief against Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ, and SHWJ Partnership. An imminent threat exists that Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ and SHWJ Partnership will further attempt to sell or dispose of OMDA’s aforementioned oil and gas assets and the proceeds thereof.
190. By virtue of the foregoing, OMDA has demonstrated the likelihood of success on the merits of their claims and a balancing of the equities favors the issuance of a temporary restraining order, temporary injunction, and permanent injunction against Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ and SHWJ Partnership.
191. OMDA further requests that the Court schedule a hearing, at which time Lanza, Jayne Lanza, Wilbur, Michael, Anderson, Neeley, Taylor, Black Dragon, Four Star, Four Star Productions, PTLD, Wooldridge Partnership, Wooldridge Production, Wooldridge Production, LLC, LLM, SHWJ, and SHWJ Partnership shall be required to appear and show cause why a temporary injunction should not be issued consistent with that requested above.
192. OMDA requests that any bond required of it be a nominal amount.
EXEMPLARY DAMAGES
193. OMDA’s injuries resulted from the Defendants’ malice, gross negligence, failure to act, conversion, theft, breach of fiduciary duties, conspiracy and fraud, entitling OMDA to exemplary damages under the Texas Civil Practice and Remedies Code Section 41.003 et seq.
194. OMDA expects that, after further investigation, it will be able to prove that Defendants have knowingly, maliciously, and intentionally engaged in conduct described in the following Texas Penal Code Sections:
a. Section 32.21 (forgery);
b. Section 32.45 (misapplication of fiduciary property);
c. Section 32.46 (securing execution of documents by deception); and/or
d. Section 32.47 (fraudulent destruction, removal, or concealment of writing).

195. Thus, Texas Civil Practices and Remedies Code Section 41.008 limiting the amount of recovery of punitive damages will not apply.
CLAIM TO INTERPLEADER
196. OMDA hereby asserts is claim to rightful ownership and possession of the documents interplead into this Court by Varnadore.
197. OMDA had engaged Varnadore as its legal counsel and to organize the Subsidiaries. In addition, Varnadore drafted the Trust that is a central issue in the present dispute.
198. On or about March 23, 2005, OMDA requested the documents interpled into this Court from Varnadore.
199. On or about March 31, 2005, Varnadore stated that he could not deliver the documents to OMDA because Lanza claimed to be the owner of Management and claimed rightful ownership of the documents interpled into this Court.
200. Varnadore initially interpled the documents in question into the 7th Judicial District Court of Smith County, Texas.
201. Varnadore subsequently dismissed the Interpleader in the 7th Judicial District of Smith County and joined it with this case on May 4, 2005.
ATTORNEY’S FEES
202. OMDA is entitled to recover reasonable and necessary attorney’s fees that are equitable and just under the Texas Civil Practice & Remedies Code Section 37.009 because this is a suit for declaratory relief.
203. OMDA is entitled to recover reasonable and necessary attorney’s fees that are equitable and just under Texas Civil Practice & Remedies Code Section 134.005 because this is a suit under the Texas Theft Liability Act.
204. OMDA is entitled to recover, as part of their exemplary damages, a reasonable amount for the attorney’s fees incurred or to be paid by them in pursuing its claims.
CONTINUING INVESTIGATION
205. OMDA reserves its right to amend, modify, and/or supplement this Petition if, and when, facts disclosed by, during, or upon discovery establish it is entitled to pursue other causes of action or rights that exist, at law or in equity, including compensatory damages for its actual pecuniary loss and/or exemplary damages, as well as attorney’s fees; prejudgment and post judgment interest, costs of suit; and special damages of lost profits, restitution, or incidental damages.
CONDITIONS PRECEDENT
206. All conditions precedent have been performed, have occurred, or have been excused by the defendants’ conduct.
JURY DEMAND
207. OMDA demands a jury trial.
REQUEST FOR DISCLOSURE
208. Under Texas Rule of Civil Procedure 194, OMDA requests that defendants disclose, within 50 days of the service of this request, the information and material described in Rule 194.2.
PRAYER

209. FOR THESE REASONS, plaintiff, OMDA Oil and Gas, Inc., asks that defendants be cited to appear and that the Court;
DECLARE:
a. Plaintiff OMDA is the sole shareholder of Management;

b. Plaintiff OMDA is the sole shareholder of Services;

c. Plaintiff OMDA is the sole shareholder of SHWJ;

d. Plaintiff OMDA, either directly or by and through its wholly owned subsidiary, Management, is the owner of the Concorde Dome Properties;

e. Plaintiff OMDA, either directly or by and through its wholly owned subsidiary, Management, is the owner of the Caddo Parish Properties;

f. Plaintiff OMDA, either directly, or by and through its wholly owned subsidiary, Management, is the owner of any and all assets on OMDA’s books as of September 9, 2003;

g. That debts allegedly owed by OMDA to Lanza, Jayne Lanza, Mario Lanza, Dei Lanza, Mardyne, Inc., Topnet, Inc., IWIC, and Andy Geiss are not rooted in fact. Rather, the debts allegedly owed by OMDA to Lanza, Jayne Lanza, Mario Lanza, Dei Lanza, Mardyne, Inc., Topnet, Inc., IWIC, and Andy Geiss are fictitious and should be rendered void;

h. That the Class D Stock certificate numbered 1012 issued in the name of IWIC dated 04/30/99 for 140,000 of OMDA common shares is void ab initio;

i. That the Class D Stock certificate number 1013 issued in the name of the 007 Trust dated 08/20/99 for 68,000 of OMDA common shares is void ab initio;

j. That the Class D Stock certificate number 1008 issued in the name of 007 Trust dated 04/28/99 for 100,000 of OMDA common shares is void ab initio;

k. That the Class D Stock certificate number 1016 issued in the name of 007 Trust dated 10/29/99 for 100,000 of OMDA common shares is void ab initio;

l. That the Class D Stock certificate number 1019 issued in the name of 007 Trust dated 09/22/99 for 142,500 of OMDA common shares is void ab initio;

m. That the Class D Stock certificate number 1024 issued in the name of Topnet, Inc. dated 09/30/99 for 345,800 of OMDA common shares is void ab initio; and

n. That the Class D Stock certificate number 1039 issued in the name of IWIC dated 02/29/00 for 300,000 of OMDA common shares is void ab initio.

ENTER JUDGMENT:
210. That OMDA be awarded any and all general, actual, direct, consequential and special damages of, at least, Fifty Million Dollars ($50,000,000), against the defendants jointly and severally;
211. That OMDA be awarded damages for lost profits against the defendants jointly and severally;
212. That OMDA be awarded special damages for loss of market value of its oil and gas assets against the defendants jointly and severally;
213. That OMDA be awarded special damages for loss of the enhanced value of its oil and gas assets against the defendants jointly and severally;
214. That OMDA be awarded special damages for loss of goodwill within the marketplace against the defendants jointly and severally;
215. That OMDA be awarded exemplary damages against the defendants jointly and severally;
216. That OMDA be awarded prejudgment and postjudgment interest;
217. That OMDA be awarded court costs;
218. That OMDA be awarded all other relief to which it is entitled.
ORDER:
219. The documents interpled by Varnadore be delivered to OMDA;
220. That all proceeds from the sale of any oil and gas from OMDA’s oil and gas assets, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties, be placed into a constructive trust for the benefit of OMDA until the dispute regarding the ownership of OMDA’s oil and gas assets, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties is resolved.
221. That the defendants be required to disgorge any and all remuneration received from the disposition or sale of OMDA’s oil and gas assets.
AWARD:
222. That OMDA be awarded reasonable attorney’s fees;
GRANT:
223. A temporary restraining, temporary, and permanent injunction restraining and enjoining the defendants from transferring any of OMDA’s oil and gas assets, including, but not limited to, the Concorde Dome Properties and the Caddo Parish Properties, to any additional entity or person until the present dispute over their ownership is resolved.

Respectfully submitted,


TIPTON JONES


By_____________________________
Rodney Drinnon
State Bar No. 24047841
6363 Woodway, Suite 820
Houston, Texas 77057
Telephone: [phone]
Facsimile: 713-333-6450

Mike Farris
State Bar No. 06844300
8144 Walnut Hill Lane, Suite 1080
Dallas, Texas 75231
Telephone: [phone]
Facsimile: 214.303.1812

ATTORNEYS FOR PLAINTIFF





















CERTIFICATE OF SERVICE

I hereby certify that a true, correct and complete copy of the above and foregoing instrument, including any exhibits or attachments thereto, was served in accordance with the applicable Texas Rules of Civil Procedure Rule 21(a) by certified mail, return receipt requested, upon:

Via Certified Mail RRR No.
Ms. Patricia Kay Dube, P.C.
203 East Colorado Street,
Dallas, Texas 75203
P.O. Box 223667
Dallas, Texas 75222
Attorney for Black Dragon Resource Companies, Inc.

Via Certified Mail RRR No.
Mr. Edwin K. Nelson IV
3814 Sun Valley Drive
Houston, Texas 77025
Attorney for the Lanza Defendants

Via Certified Mail RRR No.
M. DeWayne Varnadore
6101 South Broadway, Suite 590
Tyler, Texas 75703
Attorney for Interpleader



On this the 31st day of July, 2007


_______________________________
Rodney Drinnon