FILED: NEW YORK COUNTY CLERK 06/21/ :46 PM INDEX NO /2016 NYSCEF DOC. NO. 64 RECEIVED NYSCEF: 06/21/2017. Exhibit GG

Transcription

1 Exhibit GG

2 Kathy D. Patrick December 15, 2011 Via Federal Express Wells Fargo Bank National Association 9062 Old Annapolis Road Columbia, Maryland Attn: Corporate Trust Group Wells Fargo Bank National Association MAC N Samuel Morse Drive Columbia, Maryland Re: Instruction to Act to Trustee Dear Sir or Madam: Gibbs & Bruns LLP is authorized to send this letter on behalf of a group of major institutional investors which collectively hold or manage accounts that hold 25% or more of the Voting Rights ("Holders") of the Trusts 1 listed on the attached Exhibit A ("Trusts"). A list of these clients is attached as Exhibit B. This letter is sent, by those Holders, to provide instructions to Wells Fargo as Trustee of one or more of the Trusts. Capitalized terms in this letter have the meaning ascribed to them in the applicable Pooling and Servicing Agreements and other similar agreements ("PSAs"). On October 17, 2011, this firm sent a letter to JPMorgan Chase & Co. ("JPMorgan") on behalf of the Holders, advising JPMorgan of widespread, readily available information suggesting that large numbers of ineligible mortgage loans were sold or deposited into the RMBS pools underlying the Trusts, and that JPMorgan had failed to meet its ongoing duties as Servicer and/or Master Servicer of such mortgage loans. The Holders further advised JPMorgan that JPMorgan bears substantial repurchase liability for ineligible loans, and that JPMorgan's servicing deficiencies may constitute an Event of Default under the PSAs. Attached as Exhibit C is a copy of the October 17, 2011 letter. 1 PSAs for the CFLX, CHASE, JPAL T, and JPMMT issuances authorize holders of 25% of the Voting Rights of ll!lx Class of a Trust to issue instructions to the Trustee and/or to exculpate the Trustee when acting pursuant to an instruction from certificateholders. Thus, the figures cited in the first paragraph of this Letter reflect Class-based calculations for CFLX, CHASE, JP ALT, and JPMMT issuances, and Trust-based calculations for the other issuances. See, e.g., PSAs for BALTA( 8.07, 9.02), BSABS ( 9.02), BSARM ( 9.02), BSMF ( 9.02), BSAAT ( 9.02), CFLX ( 10.02), CHASE( 10.02), EMCM ( 9.02), JPALT ( 6.01), JPMAC ( 8.02), JPMMT ( 6.01), PRIME( 9.02), SACO( 10.02), SAM!( 9.02), WAMMS ( 8.02), WAMU ( 8.02), and WMALT ( 8.02) issuances.

3 2 Therefore, with respect to those Trusts in Exhibit A for which Wells Fargo is Trustee, the Holders hereby instruct the Trustee to take the following actions: 1. Within twenty business days, the Trustee shall commence an investigation of the matters set forth in our clients' October 17th letter to JPMorgan; The investigation shall include all steps reasonably necessary to determine: a) whether the representations and warranties provided by any Seller or Depositor concerning the eligibility of loans for securitization were true and correct when they were made; b) whether the allegations made by the mortgage insurers and credit enhancers concerning ineligible loans are true; and c) whether demands for repurchases or cures of ineligible loans should be pursued against the Sellers and/or Depositors of ineligible mortgages; 2. The Trustee shall promptly take all steps reasonably necessary to complete this investigation, including: a) the request of relevant loan files from the Servicer, b) the execution of appropriate and limited confidentiality agreements necessary to preserve the security of data and the confidentiality of borrowers' personally identifying information, and c) the solicitation of bids from approved re-underwriting firms to conduct any required loan review; and d) the retention of such other consultants, accountants, and appraisers as shall reasonably be deemed necessary to determine whether ineligible loans were securitized in any of the pools set forth on Exhibit A for which Wells Fargo is the Trustee; 3. If ineligible loans or breaches of Seller or Depositor representations and warranties are discovered as a result of the investigation described in paragraph 1, hereof, you are further instructed to authorize Gibbs & Bruns LLP to issue a demand on behalf of the Trustee that the Seller and/or Depositor repurchase or cure such loans, pursuant to the applicable sections of the PSAs. 2 If the Seller or Depositor refuses to cure the breach at issue within the time frame required by the applicable sections of the PSAs 3, the Trustee shall authorize Gibbs & Bruns LLP to pursue compelled repurchase or cure of such loans through litigation, together with a demand that each breaching Seller or Depositor reimburse the Trustee for expenses and legal fees incurred to enforce the remedies for such breach; 4. If the Trustee fails to investigate these matters or if, at the conclusion of sixty days, the Trustee concludes it does not wish to commence litigation concerning the matters raised in the October 17 letter, then the Holders instruct the Trustee to notify them formally that it does not intend to take action, so that they may do so pursuant to the terms of the applicable PSAs. The Trustee shall then immediately authorize Gibbs & Bruns LLP to commence an investigation on behalf of the Trustee of all of the matters set forth in the October 17th letter. 2 See, e.g., PSAs for BALTA( 2.03), BSABS ( 2.03), BSARM ( 2.03), BSMF ( 2.03), BSAAT ( 2.03), CFLX ( 3.01), CHASE( 3.01), EMCM ( 2.03), JPALT ( 2.04, 2.05), JPMAC ( 2.03, 2.05), JPMMT ( 2.05), PRIME ( 2.03), SACO ( 2.03), SAM! ( 2.03), WAMMS ( 2.08), WAMU ( 2.08, 2.09), and WMALT ( 2.08, 2.09) issuances. 3 Id Gihlis & Bruns LIP I ioolouisiaoa Suite ii:loli Houston, Texas T fl805 F

4 3 You are instructed to implement these instructions forthwith, and in any event no later than twenty business days after receipt of these instructions. The Holders hereunder reserve their rights to provide additional instructions to you concerning these or other matters under the applicable PSAs. You are further instructed that a delay in implementing one of the instructions set out above, shall not excuse the Trustee's prompt performance of any other instruction. When the Trustee acts in good faith pursuant to the instructions of25% of the Holders 4, it is not liable for any "action taken, suffered or omitted to be taken by it... " 5 Thus, any claim for damages against the Trustee as a result of the implementation of these instructions is barred bythepsas. The Holders are willing to provide the Trustee a reasonably satisfactory indemnity that will cover the "costs, expenses or liabilities likely to be incurred" by the Trustee as a result of the Trustee's implementation of these instructions. 6 The Holders are also willing to provide for the retention of contingent fee counsel to investigate and pursue the Trusts' claims. Accordingly, nothing in this instruction requires "the Trustee to risk or expend its own funds or otherwise incur any financial liability in the performance of any of its duties." 7 Please contact me by January 3rd, 2012 to advise whether the Trustee will implement the instruction as set forth above. 4 The 25% threshold reflects a Class-based or Trust-based calculation, as appropriate under the applicable PSAs. 5 See, e.g., PSAs for BALTA( 8.06, 9.01), BSABS ( 9.01, 10.01), BSARM ( 9.01), BSMF ( 9.01), BSAAT ( 9.01), CFLX ( 10.01), CHASE( 10.01), EMCM ( 9.01), JPALT ( 6.01), JPMAC ( 6.01), JPMMT ( 6.01), PRIME( 9.01), SACO( 10.01), SAM!( 9.01), WAMMS ( 8.01), WAMU ( 8.01), and WMALT ( 8.01) issuances. 6 See footnote 1 for the applicable Sections of the PS As. 7 See, e.g., PSAs for BALTA( 8.06, 9.01), BSABS ( 9.01, 10.01), BSARM ( 9.01), BSMF ( 9.01), BSAAT ( 6.01), CFLX ( 10.02), CHASE( 10.02), EMCM ( 9.01), JPALT ( 6.01), JPMAC ( 8.01), JPMMT ( 6.01), PRIME( 9.01), SACO( 10.01), SAM!( 9.01), WAMMS ( 8.02), WAMU ( 8.02), and WMALT ( 8.02) issuances. Gibbs & Bruns UP ;JOO Lonisiana Suite Houston. Texas T f Lll90:J

5 Exhibit A: List of Trusts BAL TA BSARM JPMAC 2006-WMCl SAMI 2007-ARl BAL TA BSMF 2006-ACl SAMI 2007-AR2 BAL TA BSM F 2006-ARl SAMI 2007-AR3 BALTA BSM F 2006-AR2 JPMMT 2005-A3 SAMI 2007-AR4 BAL TA BSMF 2006-AR3 JPMMT 2005-A4 SAMI 2007-AR5 BALTA BSMF 2006-AR5 JPMMT 2005-A5 SAMI 2007-AR6 BAL TA BSMF 2006-SL2 JPMMT 2005-A6 SAMI 2007-AR7 BALTA BSM F 2006-SL3 JPMMT 2005-A7 WAMMS 2005-RAl BSAAT BSMF 2006-SL4 JPMMT 2005-AB WAMU 2005-AR12 BSABS BSMF 2006-SL6 JPMMT 2005-AL Tl WAMU 2005-AR15 BSABS 2005-ACl BSM F 2007-ARl JPMMT 2005-S2 WAMU 2005-AR17 BSABS 2005-AC2 BSM F 2007-AR3 JPMMT 2005-S3 WAMU 2005-AR19 BSABS 2005-AC5 BSMF 2007-AR4 JPMMT 2006-Al WAMU 2005-AR5 BSABS 2005-AC? BSM F 2007-AR5 JPMMT 2006-A2 BSABS 2005-ACB BSMF 2007-SL2 JPMMT 2006-A3 WAMU 2006-ARlO BSABS 2005-AC9 CFLX JPMMT 2006-A4 WAMU 2006-ARll BSABS 2005-AQ2 CFLX JPMMT 2006-A5 WAMU 2006-AR13 BSABS 2005-CLl CFLX JPMMT 2006-A6 WAMU 2006-AR14 BSABS 2005-FRl CFLX JPMMT 2006-A7 WAMU 2006-AR15 BSABS 2005-HEll CFLX JPMMT 2006-Sl WAMU 2006-AR17 BSABS 2005-SOl CFLX JPMMT 2006-S2 WAMU 2006-AR19 BSABS 2005-S02 CFLX JPMMT 2006-S3 BSABS 2005-S03 CFLX 2007-Ml JPMMT 2006-S4 BSABS 2005-S04 CHASE 2005-Al JPMMT 2007-Al BSABS 2005-TC2 CHASE 2005-A2 JPMMT 2007-A2 BSABS CHASE 2005-Sl JPMMT 2007-A3 BSABS CHASE 2005-S2 JPMMT 2007-A4 BSABS 2006-ACl CHASE 2005-S3 JPMMT 2007-A5 BSABS 2006-AC2 CHASE 2006-Al JPMMT 2007-A6 BSABS 2006-AC3 CHASE 2006-Sl JPMMT 2007-Sl BSABS 2006-AQl CHASE 2006-S2 JPMMT 2007-S2 BSABS 2006-HE3 CHASE 2006-S3 JPMMT 2007-S3 BSABS 2006-HE6 CHASE 2006-S4 PRIME BSA BS 2006-H E7 CHASE 2007-Al PRIME BSABS 2006-IMl CHASE 2007-A2 PRIME BSABS 2006-SOl CHASE 2007-Sl PRIME Rl BSABS 2006-S02 CHASE 2007-S2 PRIME

6 CHASE 2007-S5 PRIME BSABS 2006-STl CHASE 2007-S6 SACO BSABS EMCM 2006-A SACO 2005-WM3 BSABS 2007-AC3 JPALT 2005-A2 SACO WMAL T 2005-ARl BSABS 2007-AC4 JPALT 2005-Sl SACO BSABS 2007-AC5 JPALT 2006-Al SACO BSABS 2007-AC6 JPALT 2006-A2 SACO BSABS 2007-AQ2 JPALT 2006-A4 SACO BSABS 2007-FSl JPALT 2006-A5 SACO 2007-VAl BSABS 2007-HE4 JPALT 2006-A6 SAM! 2005-ARl WMAL T 2006-AR6 BSABS 2007-HE6 JPALT 2006-A7 SAM I 2005-AR2 WMAL T 2006-AR7 BSABS 2007-HE7 JPALT 2006-Sl SAM! 2005-AR3 WMAL T 2006-AR8 BSABS 2007-SDl JPALT 2006-S2 SAM! 2005-AR4 WMALT 2006-AR9 BSABS 2007-SD2 JPALT 2006-S3 SAM! 2005-AR5 BSARM JPALT 2006-S4 SAM! 2005-AR7 BSARM JPALT 2007-Al SAM! 2006-ARl BSARM JPALT 2007-A2 SAM! 2006-AR2 BSARM JPALT 2007-Sl SAM! 2006-AR3 BSARM J PMAC 2006-CH 1 SAM! 2006-AR4 BSARM J PMAC 2006-FRE2 SAM! 2006-AR5 BSARM JPMAC 2006-HE2 SAM! 2006-AR6 BSARM JPMAC 2006-NC2 SAM! 2006-AR7

7 Exhibit B: List of Clients of Gibbs & Bruns LLP I. BlackRock Financial Management Inc. and its advisory affiliates 2. Kore Advisors, L.P. 3. Maiden Lane, LLC; Maiden Lane II, LLC; and Maiden Lane III, LLC by Federal Reserve Bank of New York, as managing member 4. Metropolitan Life Insurance Company 5. Trust Company of the West and affiliated companies controlled by The TCW Group, Inc. 6. Neuberger Berman Europe Limited 7. Pacific Investment Management Company LLC 8. Goldman Sachs Asset Management, L.P., as adviser to its funds and accounts 9. Teachers Insurance and Ammity Association of America I 0. Invesco Advisers, Inc. 11. Thrivent Financial for Lutherans 12. Landesbank Baden-Wi.irttemberg 13. LBBW Asset Management (Ireland) pie, Dublin 14. ING Entities 15. New York Life Investment Management LLC, as investment manager 16. AEGON USA Investment Management LLC, authorized signatory for various AEGON affiliates 17. Federal Home Loan Bank of Atlanta 18. Bayerische Landesbank, acting through its New York Branch 19. Prudential Investment Management, Inc. 20. Western Asset Management Company 21. Cascade Investment, L.L.C.

8 Kathy D. Patrick October 17, 2011 Via Federal Express Stephen M. Cutler, Esq. General Counsel JPMorgan Chase & Co. 270 Park Avenue New York, New York Dear Mr. Cutler: This firm represents investment advisers and holders of Residential Mortgage Backed Securities (RMBS) issued and/ or underwritten by JPMorgan Chase & Co. and/or its affiliates ("JPMorgan"). The aggregate outstanding balance of the 231 JPMorgan deals in which our clients collectively hold 25% or more of the voting rights exceeds $94 billion. The aggregate outstanding balance of the 43 JPMorgan deals in which our clients collectively hold 50% or more of the voting rights exceeds $12 billion. There is widespread, readily available evidence suggesting that large numbers of mortgages securing the certificates held by our clients were sold or deposited into the RMBS pools based on false and/or fraudulent representations and wan-anties by the mortgage originators, sellers and/or depositors. This evidence includes, but is certainly not limited to: excessive early default and foreclosure rates experienced in the underlying mortgage pools; a report of the United States Senate Permanent Subcommittee on Investigations, based on an extensive record, finding, among other things, that Washington Mutual "used shoddy lending practices riddled with credit, compliance, and operational deficiencies to make tens of thousands of high risk home loans that too often contained excessive risk, fraudulent information, or errors," and that, "[a]t times, Washington Mutual selected and securitized loans that it had identified as likely to go delinquent, without disclosing its analysis to investors who bought the securities, and also securitized loans tainted by fraudulent information, without notifying purchasers of the fraud that was discovered" (emphasis added); j c EXHIBIT

9 2 a loan-level analysis of JPMorgan RMBS conducted by the Federal Housing Finance Agency (FHFA), which revealed that up to 18% of the mortgage loans in JPMorgan RMBS breached owner-occupancy representations and warranties, and that up to 60% of the mortgage loans in JPMorgan RMBS breached Loan-to- Value representations and warranties 1 ; lawsuits by various financial guaranty insurers against JPMorgan, reporting that their loan-level analysis of various JPMorgan RMBS showed that high numbers of mortgages in the pools were ineligible at origination 2 ; public reports, including the Financial Crisis Inquiry Report, indicating that JPMorgan disregarded findings of third party due diligence firms that particular mortgages were ineligible for securitizations 3 ; pervasive evidence of deficient underwriting practices by third party originators of mortgage Joans in JPMorgan RMBS, including detailed allegations, supported by internal JPMorgan documents, that large volumes of repurchase requests have been submitted by JPMorgan itself to such third party originators 4 ; detailed allegations in securities cases against JPMorgan, which suggest widespread deficiencies in JPMorgan' s underwriting practices, including inaccurate representations and warranties regarding important loan characteristics such as borrower incomes and home appraisals 5 ; ' Our clients collectively hold 25% or more of the voting rights in 35 of the 92 deals which FHF A analyzed among JPMorgan's BALTA, BSABS, BSMF, JPALT, JPMAC, JPMMT, LBMLT, SACO, SAM!, WAMU, WMABS, WMALT, and WMl-IB issuances. 2 For exa1nple, Ambac has reported that 91% of randomly selected loans in 4 separate Bear Stearns securitizations breached representations and warranties. See Complaint 1l 28, Ambac Assurance Corp. v. EMC Mortg. Corp. and J.P. Morgan Sec., Inc., No /2011 (N.Y. Sup. Ct.). Assured Guaranty has reported similar results with respect to a Bear Stearns securitization, finding in 2009 and 2010 analyses that over 88% and 92%, respectively, of adversely selected loans breached representations and warranties. See Complaint 1!1! 7-8, Assured Guaranty Corp. v. EMC Mortg. Corp., No. 1 :10-cv (S.D.N.Y.). Syncora Guarantee has also reported similar results with respect to a Bear Stearns securitization, finding that 85% of randomly selected loans breached representations and warranties. See Complaint 1!1f 5-{;, Syncora Guarantee Inc. v. EMC Mortg. Corp., No. 1:09-cv (S.D.N.Y). 3 See, e.g., Financial Crisis Inquiry Report at 167 (reporting that from January 2006 through June 2007, Clayton rejected 27 percent of the loans submitted to it by JPMorgan, and that JPMorgan subsequently "waived in" 51 percent of those rejected loans). 4 Testimony of JPMorgan executives to the Financial Crisis Inquiry Commission also reveals that JPMorgan acknowledges the deficient underwriting practices of third-party originators of mortgage loans in the RMBS pools. See, e.g., Testimony of James Dimon to the FCIC. In addition, there have been troubling reports that JPMorgan submitted repurchase requests to third-paity originators for mortgage loans in the RMBS pools, settled those claims, and then pocketed the proceeds, without notifjjing investors in the RMBS, and without repurchasing the loans from the pools or otherwise co1npensating investors. 5 See, e.g., Third Amended Class Action Complaint, In Re Bear Stearns Mortg. Pass-Through Certificates Litig., No. 1:08-cv (S.D.N.Y.). Gibbs & Bruns llp ' 110G Louisiana Suite 53Dtl " llnustun. lexas ' T DJ8D5 " f 71J.751.U9D3 '

10 3 suits by Trustees against JPMorgan alleging breaches of representations and warranties and seeking access to mortgage loan files to investigate potential breaches ofrepresentations and warranties 6 ; substantial downgrades of the certificates by credit rating agencies; and JPMorgan's own apparent acknowledgement that it is potentially liable for violations of representations and warranties in JPMorgan RMBS, evidenced by its substantial recent additions to litigation reserves associated with private label securitizations. In addition, there is widespread, readily available evidence suggesting that JPMorgan, as servicer and/or master servicer of mortgage loans securing the certificates held by our clients, has failed to observe and perfonn the covenants and agreements imposed on it by the governing agreements, and has failed to meet its duty to prudently service those mortgage loans, including, but certainly not limited to: JPMorgan's admittedly flawed mortgage loan servicing and foreclosure practices, including deficient document signing practices, leading to JPMorgan' s foreclosure suspension and review in Fall 2010; JPMorgan's April 2011 consent order with the Office of the Comptroller of the Currency ("OCC"), in which OCC found that, in connection with certain foreclosures of loans in JPMorgan's servicing portfolio, JPMorgan engaged in "unsafe or unsound banking practices" because, among other reasons, JPMorgan filed or caused to be filed in courts inaccurate affidavits, filed or caused to be filed in courts or in land record offices improperly notarized mortgage-related documents, litigated or initiated foreclosure proceedings without ensuring proper assignment and possession of promissory notes or mortgage documents, failed to devote adequate resources to foreclosure processes, failed to subject its foreclosure processes to adequate oversight, internal controls, policies, and procedures, and failed to sufficiently oversee third parties handling foreclosurerelated services; JPMorgan' s April 2011 consent order with the Board of Governors of the Federal Reserve System, in which the Federal Reserve acknowledged OCC's findings and also highlighted allegations that JPMorgan failed to respond in a sufficient and timely manner to increased levels of loss mitigation activities-including activities related to special forbearances, repayment plans, modifications, short refinances, short sales, cash-for-keys, and deeds-in-lieu of foreclosure-to ensure 6 Please note that our clients fully support, and do not intend to interfere with, ongoing efforts by certain Trustees to seek mortgage loan files from JPMorgan and to pursue repurchase and servicing claims against JPMorgan, on behalf of holders of some JPMorgan RMBS. To the extent that such efforts are unsuccessful, however, our clients fully intend to exercise their rights under the governing agreements to pursue such repurchase and servicing claiins against JPMorgan. Gibbs & Bruns llp,. l1go Louisiana, Suite 5300, Houston. Texas!nOZ ' 1 71l650.R805, f ' w1w1.gibhsbru11uom

11 4 "full exploration of Loss Mitigation options or programs prior to completion of foreclosure activities"; The Treasury Department's withholding of financial incentives for JPMorgan under the Making Home Affordable loan modification program, based on a determination that JPMorgan needs "substantial improvement" in its loan servicing under that program; notably, two very troubling audits showed that 31 % and 20%, respectively, of JPMorgan's calculations of borrower income-a fundamental indicator of borrowers' ability to repay loans--differed from the auditors' calculations by more than 5%; ongoing investigations by state attorneys general and other government agencies into JPMorgan's mortgage loan servicing and foreclosure-related practices; evidence of wholly avoidable and unnecessary servicing fees to maintain mortgaged property, which have resulted from JPMorgan's flawed mortgage loan servicing and foreclosure practices; evidence that JPMorgan's conflict of interest as both a servicer of first-lien mortgage loans in the RMBS pools, and as an investor in second-lien mortgage loans on the same mortgaged properties, has prejudiced the interests of our clients; JPMorgan's apparent failure to notify other parties to the governing agreements of mortgage loans in the pools that violated representations and warranties at the time they were sold into the pools, and its apparent failure to enforce the sellers' obligations to cure, substitute, or repurchase such loans, as JPMorgan is required to do under the governing agreements; and JPMorgan's own apparent acknowledgment that it is potentially liable for its servicing failures, evidenced by substantial recent additions to its reserves associated with foreclosure delays and related issues, including an addition of $1 billion to such reserves in the second quarter of 2011 alone. Based on this and other evidence, our clients believe that large numbers of ineligible loans were sold or deposited into, and remain in, the RMBS pools securing the certificates held by our clients. Under the governing agreements, JPMorgan has substantial repurchase liability for such Joans. Our clients further believe that JPMorgan's failure to observe and perform the covenants and agreements imposed on it by the governing agreements, and to meet its duty to prudently service those mortgages, may constitute a servicer event of default under the governing agreements. Gibbs & Bruns llp ' 1100 Louisiana ' Suite 53fiu Housion. Texas 77LlG "0.R8-05 f m

12 5 Our clients are not willing to suffer further losses resulting from ineligible loans in the pools and improper servicing of the loans in the pools, and they wish to seek a resolution of repurchase and servicing claims with JPMorgan. As such, our clients hope and anticipate that JPMorgan will begin a constructive dialogue with them regarding the concerns raised by this Jetter. If, however, JPMorgan proves to be an obstacle to their efforts to mitigate such losses, our clients fully intend to exercise their rights under the governing agreements-including the issuance of binding instructions to Trustees-to pursue enforcement of repurchase and servicing claims against JPMorgan. Finally, please note that our clients fully support, and do not intend to inteifere with, ongoing efforts by certain Trustees to seek mortgage loan files from JPMorgan and tp pursue repurchase and servicing claims against JPMorgan, on behalf of holders of some JPMorgan RMBS. To the extent that such efforts are unsuccessful, however, our clients fully intend to exercise their rights under the governing agreements to pursue such repurchase and servicing claims against JPMorgan. Should JPMorgan wish to begin a constructive dialogue regarding these issues, please make appropriately senior legal and business personnel available to meet with me and various of our clients on Monday, October 24, To arrange the details of this meeting, please contact me as soon as possible. Gibbs & Bruns llp ' 1100 Louisiana ' Suite 5300 ' Houston. Texas ' , f