Inspar's Response to Motion to Dismiss
This is an OCR recreation from the court filed pdf document, so there a few reconition typos scattered about.
Case 4:10-cv-05086 Document 10 Filed in TXSD on 02/10/11
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF TEXAS
HOUSTON DIVISION
KENT WEISENBERG AND §
INSPAR FIELD SERVICES, LLC §
Plaintiffs §
vs., § CIVIL ACTION NO. 4:l0-cv-05086
PLANET RESOURCE RECOVERY, §
INC., KURT NEUBAUER §
Defendants
PLAINTIFFS' RESPONSE TO MOTION TO DISMISS
TO THE HONORABLE UNITED STATES DISTRICT COURT:
COMES NOW, Plaintiffs Kent Weisenberg and Inspar Field Services, LLC and file this
Response to the Motion to Dismiss (the "Motion") (Docket No. 6) filed by the Defendants,
Planet Resources Recovery, Inc. ("Planet") and Kurt Neubauer ("Neubauer") and would
respectfially show as follows:
At its heart, this case involves the Defendants' fraud in connection with a securities
transaction. By virtue of an Asset Purchase Agreement (Exhibit A to the Motion), the
Plaintiffs conveyed a number of patents and intellectual property in exchange for restricted
stock in Planet. The consideration was set out specifically in the Asset Purchase Agreement
as follows:
3. lbs Purchaser shall issue lie Seller 15,000,000 shares of restdcted comjaoa stock of the
Purchaser (the "Shares" or the "Common Stock") in consideratipii for the Assets and
the Weisenberg Assets. The Paities agree that "the Purchase Price for the Assets wil! he
allocated among the Assets as follows suhject to required adjustments that are nratually
agreed upon by the Partiies:
i. Business Equipment, Inventory and packaging, outstanding biisiness
cDntracts, BoolcSj records and files. Trade marks and trade names.
Goodwill and Patents.
The term "Assets" and "Weisenberg Assets" were specifically identified in the Asset Purchase
Agreement, but consist primarily of these patents and intellectual property.
2. Additionally, in connection with the Asset Purchase Agreement, the following people
received stock as a part of this transaction:
2.1. Dudley Primeaux - 1,500,00 shares
2.2. Emil Pena- 750,000 shares
2.3. John Nixon -- 750,000 shares
2.4. Barbara A. Hoekstra Revocable Trust - 642,857 shares
2.5. Mark Alan Ragen - 35, 714 shares
2.6. Sheila M. Wales - 35,714 shares
3. This is the only consideration supporting the Asset Purchase Agreement. After the purchase
of the Assets, Planet set up a subsidiary corporation, Inspar Robotic Technologies, Inc.
("IRT"), to hold the Assets and assume business using the Assets. Weisenberg was
appointed as the CEO of IRT and signed an employment agreement with IRT. In its brief
existence. Planet did infuse some money into IRT (although not near the amount needed or
promised). This is the money that the Defendants refer to as "working capital".' That money
1 This is a disputed issue in this case. While the Defendants claim (without evidence or support) that they infused
approximately $1,000,000 into IRT, the evidence will show, when Planet is forced to produce its books and records,
that this is a false statement. More than half of this is in arrears to employees and vendors. More than 10% of the
was used to pay certain bills of IRT and salaries of the employees of IRT. That money was
completely controlled by Planet and Neubauer, who never gave Weisenberg any independent
authority to make payments on IRT's behalf. But more importantly, the working capital had
NOTHING to do with the Asset Purchase Agreement or the consideration thereunder.
4. It was then learned that through a systematic scheme designed to artificially inflate the value
of Planet's stock, the Defendants disseminated a substantial amount of false information to
the Plaintiffs, as"wells as to the investing public. That information is detailed in the
Plaintiffs' Original Petition (Docket No. 1) as amended by the Plaintiffs' First Amended
Petition (Docket No. 9). The Plaintiffs identify the information, the speaker, the timing, and
how it ended up all being one big lie. There is no question that the Defendants are on notice
of the specific claims being made against them. There is no question that the Plaintiffs' live
petition meets the specificity requirements of the federal securities laws as well as Rule 9 of
the Federal Rules of Civil Procedure.
5. Yet, the Defendants filed the Motion arguing that: (1) there was a failure to name necessary
parties, namely the people listed in Paragraph 2 herein; (2) there was a failure to join required
parties in the form of undisclosed recipients of payments from IRT; (3) failure to name Tim
Williams; (4) failure to plead fraud with particularity; (5) failure to plead a proper claim
under the securities act; and (6) failure to attend mediation.
Failure to Join Necessary Parties - Stock Recipients or the "Additional Shares "
6. Defendants' first argument regarding the failure to join all people who received Planet stock
money they paid went to the salaries of Planet officers.
2 In fact, even as the CEO of IRT, Weisenberg was only given a company debit card with a $500 limit. Weisenberg
was permitted to make payments on his own credit cards; however, reimbursement required the approval of
Neubauer. Neubauer approved all reimbursements and controlled all "working capital". At no time did Weisenberg
or any IRT staff have control over or were a signatory to any IRT account. Despite the $500 debit card, many of
those expenditres were rejected due to lack of funds in the account.
under the Asset Purchase Agreement is now moot. Pursuant to Rule 15(a)(l)(B), the
Plaintiffs were allowed to amend the Complaint and add all of these parties. All of these
people are now parties to this case. (Docket No. 9).
Failure to Join Necessary Parties — Recipients of IRTpayments
7. Defendants' second argument regarding the failure to join the imdisclosed recipients of
payments from IRT is misplaced for several reasons. The Defendants' basic argument is that
if the Court rescinds the Asset Purchase Agreement, it is required to put the parties back in
the exact same place they were had there never been a contract. The Defendants then argue
that because of the Asset Purchase Agreement, they infused money into IRT, and that money
should be returned to them. The Defendants then go a step further and argue that all of the
many, many parties that received payments from IRT should be made party to this lawsuit as
necessary parties. However, because those parties cannot be identified, this case should be
dismissed in its entirety. This is an extraordinarily inequitable argument, and one that is not
based in law or fact.
8. First, any money the Defendants infused into IRT was not consideration supporting the Asset
Purchase Agreement. When rescinding an agreement, the Court's charge is to return the
consideration paid under the terms of the contract. See Ford Motor Co. v. Castillo, 279
S.W.3d 656, 66A-65 (Tex. 2009) {citing Tex. Employers Ins. Ass'n v. Kennedy, 135 Tex. 486,
143 S.W.2d 583, 585 (Tex. 1940) ("The general equitable rule is that a plaintiff in a suit for
the rescission or cancellation of a contract to which he is a party must return, or offer to
return, any consideration which he has received under the contract."); Gibson v. Lancaster,
90 Tex. 540, 39 S.W. 1078, 1079 (Tex. 1897) ("[I]f any part of the purchase price has been
paid, in order to [obtain] a rescission the money so paid must be tendered by the seller to the
purchaser."). Restoring consideration actually received by the party seeking rescission is the
goal. See Johnson v. Cherry, 726 S.W.2d 4, 9 (Tex. 1987).
9. To do equity, the party seeking rescission must generally offer and be prepared to return any
consideration already received under the contract, since one may not repudiate a contract and
still retain the benefits received under it. See Freyer v. Michaels, 360 S.W.2d 559, 562 (Tex.
App. — Dallas 1962, Avrit dism'd). Restitution of the consideration is the goal of rescission.
See id; see also Hunt County Oil Co. v. Scott, 61 S.W. 451, 452 (Tex. Civ. App. - 1902, writ
ref d). The party seeking rescission cannot retain any of the benefits of the contract. See
Texas Co. v. State, 281 S.W.2d 83 (Tex. 1955). "[T]he cases requiring a party to restore
the original status refer to returning money or property received pursuant to the
contract." Castillo, 279 S.W.3d at 664.
10. Because the "v^orking capital" was not consideration paid under the terms of the Asset
Purchase Agreement, it is not consideration to be returned if rescission is ordered. It is not
consideration that the Plaintiffs, or any other party received as a result of the Asset Purchase
Agreement. The Plaintiffs are ready, willing, and able to return all money and property that
they received pursuant to the terms of the Asset Purchase Agreement. The Plaintiffs have
offered repeatedly to return all such consideration.
11. Second, because those payments were to vendors and employees, they are not necessary
parties as this lawsuit does not effect their rights at all. More importantly, the Defendants
have not shown how or why these parties are "indispensable" as that term is defmed by the
Federal Rules of Civil Procedure.
12. The Fifth Circuit has a two part inquiry to determine if a case should be dismissed for failure
to join a party. It states:
Determining whether to dismiss a case for failure to join an indispensable party
requires a two-step inquiry. First the district court must determine whether the
party should be added under the requirements of Rule 19(a). Rule 19(a)(l)
requires that a person subject to process and whose joinder will not deprive the
court of subject-matter jurisdiction be joined if:
(A) in that person's^ absence, the court cannot accord complete
relief among existing parties; or (B) that person claims an interest
relating to the subject of the action and is so situated that disposing
of the action in the person's absence may: (i) as a practical matter
impair or impede the person's ability to protect the interest; or (ii)
leave an existing party subject to a substantial risk of incurring
double, multiple, or otherwise inconsistent obligations because of
the interest.
FED. R. CrV. P. 19(a)(l). While the party advocating joinder has the initial
burden of demonstrating that a missing party is necessary, after "an initial
appraisal of the facts indicates that a possibly necessary party is absent, the
burden of disputing this initial appraisal falls on the party who opposes joinder."
Pulitzer-Polster, 784 F.2d at 1309.
Hoodv. The City of Memphis. 570 F.3d 625, 628 (5* Cir. 2009).
13. The second part of the test relates to the addition of a party that will destroy subject matter
jurisdiction.
If the necessary party cannot be joined without destroying subject-matter
jurisdiction, the court must then determine whether that person is "indispensable,"
that is, whether litigation can be properly pursued without the absent party. HS
Res., 327 F.3d at 439. The factors that the district court is to consider in maldng
this determination are laid out in Rule 19(b):
(1) the extent to which a judgment rendered in the person's absence
might prejudice that person or the existing parties; (2) the extent to
which any prejudice could be lessened or avoided by; (A)
protective provisions in the judgment; (B) shaping the relief; or (C)
other measures; (3) whether a judgment rendered in the person's
absence would be adequate; and (4) whether the plaintiff would
have an adequate remedy if the action were dismissed for
nonjoinder.
Id. Diversity jurisdiction is not an issue in this case, so here, the Court only need determine
if these unJkaiown recipients of IRT payments are indispensable.
14. In this case, the initial burden falls on the Defendants to establish how these missing, and
unidentified parties are necessary to this lawsuit. The Defendants completely failed to meet
this burden. Nowhere in the four comers of the Asset Purchase Agreement are these
"unidentified" parties mentioned. In fact, nowhere in the four comers of the Asset Purchase
Agreement is IRT mentioned except to state that it will be formed. If Planet invested money
into IRT, and it wants to get that money back, it can go after IRT. Interestingly, and not
mentioned by the Defendants, IRT is a wholly owned subsidiary of Planet. If Planet thinks
that IRT owes it something, it can take care of that issue with its own subsidiary. This has
nothing to do with the issues in this case.
15. Nothing about IRT served as the consideration supporting the Asset Purchase Agreement.
While the concept of IRT (although not mentioned by name) is referenced in the Letter of
Intent, that document was merely the springboard for the Asset Purchase Agreement.
Neither IRT nor any obligations relating to IRT, found their way into the Asset Purchase
Agreement.
16. For example, the Plaintiffs believe strongly that the Defendants ignored their promises and
obligations to IRT. The Defendants made repeated promises to fund this company and
provide it with the resources it needed to build its business. This never happened. In fact,
the Defendants, not only failed to pay the ongoing bills of IRT, but also failed to pay IRT's
employees.^ The Defendants are currently under investigation of the Texas Workforce
3 The failure to pay wages is a violation of the Texas Labor Code §61.019 and carries with it criminal penalties.
Commission (Texas Workforce Commission/Attorney General's office - Case # 10 064146-
1} as well as the U.S. Department of Labor (US Department of Labor — Case # 1599036)
regarding their failure to pay these employees. Additionally, all employees of IRT filed
complaint form 3949-A with the Internal Revenue Service for nonpayment of withholding
taxes as they were ineligible for unemployment due to the non-reporting of income or
employment by Planet.
17. However, the failure to fimd ERT does not constitute a breach of the Asset Purchase
Agreement — because that promise is not found within that agreement. If the promise to fund
IRT is not a requirement of the Asset Purchase Agreement, then it is likewise not
consideration supporting the Agreement. If it is not consideration supporting the Asset
Purchase Agreement, then there is nothing for the Court to "return" if it determines that
rescission is the appropriate remedy in this case.
18. The Defendants make a number of unsubstantiated allegations against Weisenberg relating to
IRT's expenditure of money. The Plaintiffs strongly deny these allegations;^ however, they
are misplaced in this motion. If the Defendants have a claim against Weisenberg, they can
bring a claim against him (as they have in the filing of the Defendants' Counterclaim seeking
monetary damages). But, this does not demonstrate how the Plaintiffs failed to join
necessary parties in this suit thus justifying Rule 12 relief. These are bogus arguments
designed to sling mud against Weisenberg in an attempt to shift the focus from where it
belongs: on the wrongful conduct of Planet and Neubauer.
Failure to Join Necessary Parties — Tim Williams
4 These allegations are being made as a part of Planet's ongoing attempts to manipulate stock value through use of
postings on the internet. Planet fills its pleadings with false and bizarre accusations and then posts them on the
internet and issues ongoing press releases as though the accusations are facts.
5 Planet and Neubauer kept all the books on IRT.
19. Defendants' next argument is that a person named Tim Williams is the party that was
primarily responsible for negotiating the Asset Purchase Agreement by and between
Weisenberg, Inspar, and Planet, and should therefore be a party to this lawsuit. This
argument is not expressly stated within the arguments contained in the Motion; however, the
Defendants allude to this in their recitation of the facts. As such, and in an abundance of
caution, this idea is addressed in this Response. However, because the Defendants did not
properly present this issue to the Court, it should not be considered as a valid grounds for
dismissal.
20. Planet states that it was Tim Williams who was the person speaking on behalf of Planet in
this negotiation. Planet then alludes that Tim Williams should be a party to this lawsuit.
21. Planet can name Tim Williams if it so chooses. But, there is nothing about Tim Williams
that makes him a necessary party to this lawsuit. Complete relief can be afforded the parties
absent Tim Williams being named as a defendant. Tim Williams has no interest in the Assets
or the consideration supporting the Asset Purchase Agreement. Nor does Tim William's
absence leave any other party at risk of incurring double, multiple, or inconsistent
obligations. The Defendants did not even attempt to meet their initial burden on explaining
why Tim Williams is necessary to this lawsuit. As such, this should not be a groimd for
dismissal.
Failure to State a Claim — Pleading Fraud with Particularity
22. Defendants' fourth argument is that this case should be dismissed for failure to plead fraud
with particularity.
[FRCP 9(b)] requires the plaintiffs in secxirities fraud causes to plead with
particularity the circumstances constituting the alleged fraud. To satisfy
Rule 9(b)'s pleading requirements, the plaintiffs must 'specify the
statements contended to be fraudulent, identify the speaker, state when and
where the statements were made, and explain why the statements were
fraudulent.
Southland Sees. Corp. v. INSpire Ins. Soultions, Inc., 365 F.3d 353, 362 (5* Cir. 2004).
23. Case law continues:
[T]he normally rigorous particularity rule has been relaxed somewhat
where the factual information is peculiarly within the defendant's
knowledge or control. But even under a relaxed application of [FRCP]
9(b), boilerplate and conclusory allegations will not suffice. While state
of mind may be averred generally, plaintiffs must still allege facts that
show the court their basis for inferring that the defendants acted with
"scienter." '"•
In re Burlington Coat Factory Sec. Litg., 114 F.3d 1410, 1418 (3'''' Cir. 1997).
24. These are the standards under both Rule 9(b) and the federal securities laws. The Reform
Act amended the Securities Act of 1933 and the Exchange Act of 1934, in part by
heightening the pleading requirements in securities fraud lawsuits. See City of Philadelphia
V. Fleming Cos., Inc., 264 F.3d 1245, 1258-59 (10th Cir. 2001). In cases brought under
federal securities law, when a plaintiff alleges that the defendant made a false statement of a
material fact or omitted a material fact necessary to prevent the statements made from being
misleading, he or she must specify each allegedly false or misleading statement and explain
why it is false. 15 U.S.C. § 78u-4(b)(l). Additionally, a plaintiff must "state with
particularity facts giving rise to a strong inference that the defendant acted with the required
state of mind" for each alleged securities law violation. 15 U.S.C. § 78u-4(b)(2).
25. Under the Exchange Act, the primary private cause of action arises under SEC Rule lOb-5,
17 C.F.R. § 240.10b-5, promulgated under 10-b of the Exchange Act, 15 U.S.C. § 78j. Both §
78j and Rule lOb-5 prohibit the use of manipulative and deceptive devices in the sale of
securities. Rule lOb-5 also explicitly forbids "making any untrue statement of a material fact
or . . . omitting to state a material fact" in connection with the purchase or sale of a security if
the fact is necessary to prevent the statement from being misleading. 17 C.F.R. § 240.10b-
5(b).
26. The Plaintiffs stand on their extremely detailed pleading showing the fraudulent scheme
initiated by the Defendants to artificially inflate the value of Planet's stock so that they could
sell off their stock at a high price and leave the Plaintiffs with worthless stock. A classic
"pump and dump" scheme.
27. By way of example, prior to execution of the Asset Purchase Agreement, Planet issued press
releases that spoke of the strength of Planet's relationship with a subsidiary called Rada
Technologies Inc. It was later discovered that the former owners of Rada initiated a number
of lawsuits against Planet and Neubauer alleging similar facts to the "pump and dump"
alleged in this lawsuit. Planet failed to disclose the existence of these lawsuits in their SEC
filings. The Plaintiffs explain that this was done knowingly by the Defendants and how they
intentionally misrepresented this relationship. The Plaintiffs go on that had they known of
the truth in this regard, they never would have sold their valuable patents and assets to such
schemesters.
28. The Petition goes on to identify 8 specific press releases issued by Planet discussing the
value and functionality of the PetroLexus technology. These releases also discussed the
value of the technology and the revenues generated from the technology. None of it was
true, rather Neubauer was simply copying information firom another product called Diamond
6 In a recent dissent, Justice Bryer describes the classic "pump and dump" where the defendants, "deliberately and
repeatedly make egregiously fraudulent misrepresentations to inflate the price of securities that, unbeknovmst to
investors, they own. After the stock price rises, the defendants sell at an artificial profit. When the fraud is revealed,
the price crashes, to the investors' detriment." Hemi Group, LLC v. City of New York, U.S. , 130 S.Ct. 983,
963 (2010).
Flo. Neubauer knew of the functionality of Diamond Flo because he formerly worked for the
owner of Diamond Flo, Sequioia Interests, Inc. Neubauer even copied the artwork to market
the products. The Petition describes how this was a part of the Defendants' scheme to
artificially inflate the value of Planet's stock.
29. Neubauer went on in another specific press release to discuss how Planet was patenting
PetroLexus. This was false and the technology was incapable of obtaining a patent.
30. Paragraph 16 details three specific press releases in which Planet makes false statements.
The best example surrounds the San Antonio de Turiri Antimony mine in Bolivia. Planet
totally made this up as neither the Bolivia Ministry of Mines or the USGS can identify this
mine in Bolivia. Yet, Planet issued a press release that it was entering into a joint venture to
develop this mine. Such a joint venture, if it truly existed, would increase the value of
Planet's stock. This statement among others, was relied upon in convincing the Plaintiffs that
Planet was a valuable company with many, many ongoing business opportunities. That is.
Planet artificially inflated the value of its stock. Then, when the stock reached a certain
price, the Defendants sold off their stock reaping significant gain. This was all done to the
detriment of the other investors, such as the Plaintiffs. These very specific examples of fi:aud
also demonstrate the scheme and course of conduct of the Defendants. This scheme forms
the basis for inferring that the Defendants acted with the requisite scienter.
31. The Petition goes on and on with example after example of how the Defendants released
false information to the public, including the Plaintiffs, through these press releases. The
Petition clearly states that the Defendants knew what they were doing. The Petition clearly
states how this caused harm to the Plaintiffs. There is nothing in the Petition that can be
called "boilerplate". As such, these allegations of fraud are plead with sufficient
particularity.
32. The Plaintiffs also describe how Neubauer represented the natiire of the restricted stock that
Weisenberg received under the terms of the Asset Purchase Agreement. Neubauer
misrepresented the filing of the company's Form S-10, which would "lift" the restrictions on
Weisenberg's stock. Not only have the Defendants failed to file this form, but research
revealed that the Defendants have been wrongfully asserting that this process was "nearly
completed" sine 2007, clearly establishing the Defendants' scienter regarding the falsity of
this information. Weisenberg explains how this was material to him (as it would be to any
investor) when he chose to enter the Asset Purchase Agreement.
33. The Plaintiffs go on with great detail to explain the false statements contained in the
unaudited financial statements that Planet posted on the Pinlc Sheets prior to April 10. 2010.
These statements misrepresented facts and failed to disclose serious material information on
a number of issues. See % 22(a)-(d). The Plaintiffs go on to explain many of the various and
sundry SEC violations that the Defendants are engaged in.
34. The reliance, scienter, and causation elements are all further explained in %% 21-33. fp4-35
further explain the benefit the Defendants recognized from the "pump and dump" scheme.
And then the Petition goes on to explain how all of this appears to be a pattern of conduct for
Neubauer who is involved in various other companies and investigations for similar conduct.
The allegations regarding this similar conduct with other business entities undeniably forms
the basis for inferring that these Defendants acted intentionally, deliberately, and with
scienter.
35. There is no mystery in this case as to the allegations against the Defendants. For purposes of
this review, the Court is to consider that all of the allegations are true. The inquiry is simple,
"if the allegations are trae, do they establish a claim for fraud?" Here, that inquiry is simple.
If allegations are true, the Plaintiffs meet every element of fraud (both common law and
statutory). See Ashcroft v. Iqbal, 129 S.Ct. 1937, 1949, 173 L. Ed. 2d 868 (2009). The
pleadings go way beyond recitals of elements and conclusory statements. The Petition
describes this fraudulent scheme with specific facts showing specifically how the Defendants
benefited from their actions to the detriment of the Plaintiffs. As such, this Motion should be
denied.
Failure to State a Claim - The Securities Exchange Act §10b-5.
36. Defendants' fifth argument relates to an alleged failure to state a claim under the Securities
Exchange Act. While the Plaintiffs disagree with the Defendants' rendition of the law, the
Complaint was amended to address this concern pursuant to Rule 15(a)(B)(l), and thus this
point is now moot.
37. Additionally, and damages sought under the Texas statutory laws are sought in the
alternative.
Mediation
38. Defendants' final argument is that this case should be dismissed because the Asset Purchase
Agreement requires mediation. While there is a section of the Asset Purchase Agreement
that references mediation (specifically ^ 45-48), this is not a valid ground under Rule 12 to
dismiss a case.
39. The Plaintiffs did malce a good faith effort to resolve this case before suit was filed; however,
that effort was only met with absurd demands and closed doors. Mediation would be
fruitless and it is believed that the Defendants are only raising this issue in an attempt to
delay.
40. More importantly, this lawsuit seeks to rescind the Asset Purchase Agreement. The
Plaintiffs' argument is that the Asset Purchase Agreement is unenforceable because it was
procured through fraud. Interestingly, that is also the Defendants' arguments through their
counterclaims. If the Asset Purchase Agreement was the product of fraud, then the mediation
provisions of that same agreement are likewise unenforceable. Fraud vitiates everything it
touches. See Cox v. The Upjohn Company, 913 S.W.2d 225 (Tex. Civ. App. - Dallas 1995,
no writ).
WHEREFORE, Plaintiffs request that the Court deny the Motion to Dismiss and grant the
Plaintiffs any and all further relief to which they may justly be entitled.
Respectfully Submitted,
By: /s/ Tanya N. Garrison
ANDREW M. CAPLAN
State Bar No. 03776700
TANYA N. GARRISON
State Bar No. 24027180
Weycer, Kaplan, Pulasld & Zuber, P.C.
11 Greenway Plaza, Suite 1400
Houston, Texas 77046
Telephone: (713) 961-9045
Facsimile: (7,132.961-5341
ATTORNEYS FOR PLAINTIFFS
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the foregoing instrument
has been served through electronic transmission through the USDC ECP, on February 10, 2011.
A copy of this pleading was also forwarded to the following via certified mail:
Mr. Michael Minns
The Minns Law Firm
9119 S. Gessner Suite One
Houston, Texas 1101A
s/Tanya N. Garrison
Tanya N. Garrison
