Calypso Wireless (fka CLYW)

[conagra]

AMENDED NOTICE OF ORAL DEPOSITION OF JIMMY WILLIAMSON, P.C.

To: Jimmy Williamson, P.C., by and through its attorney of record, Guy Matthews, Matthews, Lawson & Bowick, PLLC, 2000 Bering Drive, Suite 700, Houston, Texas 77057

Please take notice that, under Federal Rule of Civil Procedure 30(b)(6), Plaintiff Calypso Wireless, Inc. (“Calypso”) will take the oral deposition of Jimmy Williamson, P.C. beginning on Tuesday, January 19, 2010, starting at 9:00 a.m., at:

711 Louisiana Street, Suite 2010
Pennzoil Place, South Tower
Houston, Texas 77002

Jimmy Williamson P.C. (“Williamson”) is directed to designate a person or persons to testify on its behalf regarding:
1. Williamson’s involvement and/or investment in Calypso;

2. Drago Daic, Curtis Scott Howell d/b/a Tribeca, Champion Classic, Inc. and U.S. Lights, Inc. v. Calypso Wireless, Inc., Carlos Mendoza and David Davila, Cause No. 2004-
63048, in the 151st District Court of Harris County, Texas;

3. The April 3, 2008 Settlement Agreement between Calypso and Drago Daic;

4. The April 3, 2009 Amended and Restated Settlement Agreement between Calypso and Drago Daic;

5. Any alleged breaches by any party of either of the agreements in paragraphs 4 or 5 above;

6. The purported Patent Assignment, attached as Exhibit 12 to the Declaration of Cristian Turrini, filed in support of Calypso’s Emergency Motion for Temporary Restraining Order and Preliminary Injunction and Memorandum in Support;

7. All facts surrounding the public auction that Williamson and/or Kelly D. Stephens intended to conduct on January 15, 2010, as described in the Notification of Public Disposition of Intellectual Property (Non-Consumer Transaction) attached as Exhibit 13 to the Declaration of Cristian Turrini, filed in support of Calypso’s Emergency Motion for Temporary Restraining
Order and Preliminary Injunction and Memorandum in Support.

Under Federal Rules of Civil Procedure 30(b)(5) and 34, Williamson is requested to produce any and all documents in its possession relating to any of the above topics, as well as
any and all documents that it intends to rely on in the January 29, 2010 hearing before Judge Ward.

The deposition will be taken before a court reporter, and will continue from day-to-day until complete.

Dated: January 15, 2010 Respectfully submitted,
/s/ Anthony Miller
Paul V. Storm (lead counsel)
[e-mail]
State Bar No. 19325350
Anthony P. Miller
[e-mail]
State Bar No. 24041484
Michael Leach
[e-mail]
State Bar No. 24065598
Storm LLP
901 Main Street, Suite 7100
Phone: [phone]
Fax: [phone]
CERTIFICATE OF SERVICE
I hereby certify that on January 15, 2010, I caused a true and correct copy of the
foregoing to be served on all counsel of record via e-mail.
/s/ Anthony Miller
Anthony Miller