POST 3 OF 4: CIVIL JUDGMENT
Post 1 of 4 previously posted on this date on this SI thread is hereby incorporated into this post and all readers of this post should read Post 1 of 4 prior to reading this post. Readers are also advised that Post 2 of 4 previously posted on this date contains related information.
Again, I apologize for the length of this posting. It is my belief that any individual interested in this subject should take the time to read the entirety of this post. This post contains multiple documents and it is important that all documents be read in their entirety.
Filed December 30, 1991
Amended April 17, 1992
BEGINNING OF TEXT OF PLAINTIFF'S AMENDED PETITION DATED APRIL 17, 1992.
IN THE EIGHTEENTH JUDICIAL DISTRICT
DISTRICT COURT, SEDGWICK COUNTY, KANSAS
CIVIL DEPARTMENT
Case No. 91C-3673
GEORGE W. WAYMAN and
CONNIE J. WAYMAN, husband and wife,
Plaintiffs,
Vs.
ALLEN L. BURDITT, II, individually,
CARANCAHUA RESOURCES, INC.,
WELLINGTON FUNDING CORPORATION,
CHARTWELL HOLDINGS LTD., INC., and
BRISTOL OPERATING CO., INC.
AMENDED PETITION
COME NOW the plaintiffs, George W. Wayman and Connie J. Wayman, husband and wife, and for their causes for action against the defendants Allen L. Burditt II, Carancahua Resources, Inc., Wellington Funding Corporation, Chartwell Holdings Ltd., Inc., and Bristol Operating Company, Inc., allege and state:
PARTIES
1. The plaintiffs, George W. and Connie J. Wayman, husband and wife ("Waymans"), are residents of Sedgwick County, Kansas, and reside at (address withheld by Offie).
2. The defendant Allen L. Burditt II ("Burditt") is a resident of Houston, Texas, and resides at (address withheld by Offie).
3. The defendant Carancahua Resources, Inc. ("Carancahua"), is a Texas Corporation whose principal place of business is Houston, Texas, and last known address was 8303 Southwest Freeway, Suite 310, Houston, Texas 77074. Carancahua has forfeited its corporate status and has failed or refused to revive its right to do business. Carancahua never registered nor was authorized to do business in Kansas. Carancahua may be served by serving the Kansas Secretary of State or personally serving defendant Burditt who was an officer, director and shareholder of the corporation.
4. The defendant Wellington Funding Corporation ("Wellington" is a Texas corporation whose principal place of business is Houston, Texas, and last known address was 8303 Southwest Freeway, Suite 310, Houston, Texas 77074. Bristol (sic) has forfeited its corporate status and has failed or refused to revive its right to do business. Wellington never registered nor was authorized to do business in Kansas. Wellington may be served by serving the Kansas Secretary of State or by personally serving defendant Burditt who was an officer, director and shareholder of the corporation.
5. The defendant Chartwell Holdings Ltd., Inc. ("Chartwell") is a Texas corporation whose principal place of business is San Antonio, Texas. Chartwell's registered office is 2000 NCNB Plaza Convent, San Antonio, Texas 78205, and its registered agent for service of process at that address is Oliver H. Timmons (sic) III.
6. The defendant Bristol Operating Company, Inc. ("Bristol") is a Texas Corporation whose principal place of business if Stafford, Texas, and last known address was P.O. Box 1536, Stafford, Texas 77497-1536. Bristol's registered office is 2000 NCNB Plaza 300 Convent, San Antonio, Texas 78205, and its registered agent for service of process at that address is Oliver H. Timmons (sic) III.
STATEMENT OF FACTS
7. Beginning in October, 1989, defendant Burditt, individually and representing himself to be President of defendant Carancahua, and another agent, Carlo A. Ugolini ("Ugolini"), solicited the Waymans in Wichita to purchase working interests in the Davis #2 oil and gas well to be drilled in Jefferson County, Texas. Ugolini, on behalf of Burditt and Carancahua provided the Waymans with a Drilling Prospect brochure, Memorandum Documents, including a Participation Agreement, an estimate of the cost to drill and complete the well in the form of an Authority for Expenditure, and a video tape of Burditt discussing oil and gas prospects in Jefferson County, Texas. Burditt subsequently solicited the Waymans in Wichita from his offices in Texas by United States mail and telephone to purchase a working interests in the Davis #2 oil and gas well.
8. In communication with and documents furnished to the Waymans, Burditt and Carancahua misrepresented the potential for production of oil and/or gas from the Davis #2 well and overstated the cost to drill and complete the well.
9. In response to Burditt's solicitation and in reliance upon Burditt's misrepresentations, the Waymans agreed to purchase a 3.125% working interest in the Davis #2 well. The Waymans delivered their personal check made payable to Carancahua in the amount of $28,251.50, by mail to Burditt on or about December 30, 1989.
10. On or about February 14, 1990, in Wichita, the Waymans executed an Operating Agreement dated January 30, 1990 and a Participation Agreement with defendant Wellington regarding the Davis #2 well, naming defendant Wellington as the operator of the well. Burditt executed the Operating Agreement and the Participation Agreement as President of Wellington.
11. In response to Burditt's further solicitation and in reliance upon Burditt's misrepresentations, the Waymans agreed to purchase an additional 2.00% working interest in the Davis #2 well. The Waymans delivered their personal check made payable to Wellington in the amount of $28,000 by mail to Burditt on or about February 18, 1990. On or about February 26, 1990, in Wichita, the Waymans executed the Operating Agreement dated January 30, 1990 and a Participation Agreement with defendant Wellington regarding the Davis #2 well, naming defendant Wellington as the operator of the well. Burditt executed the Operating Agreement and the Participation Agreement as President of Wellington.
12. On July 3, 1990, defendant Chartwell assigned to the Waymans an undivided 5.125% working interest in the Davis #2 well. The terms of the written assignment stated that assignment was being made pursuant to the agreements referenced above.
13. In December 1990, Burditt and Wellington advised the Waymans the lease underlying the Davis #2 well was lost as a result of non-production and/or work over problems.
14. During 1990, Burditt and Wellington invoiced the Waymans for the costs to drill, complete and operate the Davis #2 well. These invoices contain material misrepresentations and false statements regarding the costs and expenses attributable to the Waymans interest in the well. During 1989 and 1990, the Waymans paid Burditt and Wellington a total of $92,890.25 for the drilling, completion and operation of the in the (sic) Davis #2 well, as a result of the original solicitation by Carancahua and Burditt and subsequent invoices from Wellington over Burditt's name. The Waymans have received not more than $4,495.83 in income from the well.
15. During June, 1990, Burditt solicited the Waymans in Wichita to purchase working interests in the Gerdes #1 oil and gas well to be drilled in San Patricio County, Texas. Burditt represented to the Waymans that he was the President of defendant Wellington. Burditt supplied specific information about the oil well to Waymans through the United States mail and personal telephone conversations.
16. In communications with and documents furnished to the Wayman's, Burditt and Wellington misrepresented the potential for production of oil and/or gas from the Gerdes #1 well and overstated the cost to drill and complete the well.
17. In response to Burditt's solicitation and in reliance upon Burditt's misrepresentations, the Waymans agreed to purchase a 6.00% working interest in the Gerdes #1 well. The Waymans delivered their personal check made payable to Wellington in the amount of $9,000.00 by mail to Burditt on or about June 16, 1990.
18. The Waymans subsequently executed a Participation Agreement and an Operating agreement dated June 30, 1990, regarding the Gerdes #1 well, naming defendant Wellington as the operator of the well. Burditt executed the Participation Agreement and the Operating Agreement as President of Wellington.
19. On October 15, 1990, defendant Chartwell assigned to the Waymans an undivided 6.00% working interest in the Gerdes #1 well. The terms of the written assignment stated that the assignment was being made pursuant to the agreements referenced above.
20. During 1990, Burditt, Wellington and Bristol invoiced the Waymans for the cost to drill, complete and operated (sic) the Gerdes #1 well. These invoices contain material misrepresentations and false statements regarding the costs and expenses attributable to the Waymans interest in the well. The Waymans paid Burditt, Wellington and Bristol a total of $12,562.21 for the drilling, completion and operation of the Gerdes #1 well, as a result of the original solicitation by Burditt and subsequent invoices from defendants Wellington and Bristol over Burditt's name. The Waymans have received no income from the well.
21. During December, 1990, the Waymans began inquiring about the validity of some of the invoices for the Davis #2 and the Gerdes #1 wells submitted by Burditt, Wellington and/or Bristol. The defendants were unwilling to provide a satisfactory response and refused the Wayman's requests to audit the defendant' financial records regarding the wells.
22. Upon inquiry with the Kansas Securities Commissioner in February 1991, the Waymans' learned that Burditt, Carancahua and Wellington were the subject of a Cease and Desist Order issued by the Commissioner on April 2, 1990, for sale in Kansas of unregistered securities, specifically interests in oil and gas leases in Jefferson and San Patricio Counties, Texas.
23. In March 1991, through telephone conversations and written correspondence with Burditt, the Waymans rescinded their purchase of any interest in the Davis #2 and the Gerdes #1 wells, tendered the working interests in the wells back to the defendants and demand the return of all moneys paid to Burditt, Carancahua, Wellington and Bristol. The Waymans' demands have been refused.
CLAIMS FOR RELIEF
COUNT 1
24. Waymans reallege and incorporate by reference the allegations contained in paragraphs 1 through 23 as though fully set forth herein.
25. The undivided fractional interests in oil and gas leases and/or investment contracts in the Davis #2 and Gerdes #1 wells located in Jefferson and San Patricio Counties, Texas, offered for sale in Kansas by defendants Burditt, Carancahua and Wellington are securities within the meaning of the Securities Act of 1933 (15 U.S. C. 77a, et. Seq.).
26. Defendants Burditt, Carancahua, and Wellington offered and sold interests in the Davis #2 and the Gerdes #1 wells to Waymans in Sedgwick County by the use of instruments of communication in interstate commerce or of the mails and by means of oral communications. These communications contained untrue statements of material facts and omissions of material facts necessary in order to make the statements, in light of the circumstances under which they were made.
27. The representations and omissions herein alleged were material and the Waymans relied on them in deciding to purchase the interests in the Davis #2 and the Gerdes #1 wells.
28. As a direct and proximate result of the representations and omissions herein alleged, Waymans purchased the interests in the Davis #2 and the Gerdes #1 wells which are now virtually worthless, and have been damaged in an amount in excess of $50,000.00.
29. For the foregoing reasons, the defendants Burditt, Carancahua and Wellington are in violation of Section 12(2) of the 1933 Act, 15 U.S.C. Section 771(2), and other applicable federal laws.
WHEREFORE, Waymans respectfully requests judgment in their favor and against the defendants Burditt, Carancahua and Wellington for recovery of all consideration paid for the interests in the Davis #2 and the Gerdes #1 wells, in the total amount of $105,452.46, less income received of not more than $4,495.83, together with prejudgment interest, costs, attorney fees, and such other and further relief as may be just and proper.
COUNT II
30. Waymans allege and incorporate by reference the allegations contained in paragraphs 1 through 29 as though fully set forth herein.
31. The undivided fractional interests in oil and gas leases and/or investment contracts in the Davis #2 and Gerdes #1 wells located in Jefferson and San Patricio Counties, Texas, offered for sale in Kansas by defendants Burditt, Carancahua and Wellington are securities within the meaning of K.S.A. 17-1252(j).
32. Defendants Burditt, Carancahua and Wellington are the issuers of said securities within the meaning of K.S.A. 17-1252(e). The securities of said defendants have never been and are not now registered with the Securities Commissioner of the State of Kansas pursuant to K.S.A.'s 17-1256,17-1257, or 17-1258. Said securities are not transactions in which they may be sold exempted by K.S.A.'s 17-1262 or 17-1262(a).
33. The sale and offer for sale of said unregistered securities in Kansas is in violation of K.S.A. 17-1255.
34. None of the above named defendants have ever been or are now registered as agents or broker-dealers for the sale of securities in the State of Kansas, and are in violation of K.S.A. 17-1254.
WHEREFORE, Waymans respectfully request judgment in their favor and against defendants Burditt, Carancahua and Wellington, for recovery of all consideration paid for the interests in the Davis #2 and Gerdes #1 wells, in the total amount of $105,452.46, less income received of not more than $4,495.83, together with interest at the rate of 15% from the date of payment, costs, reasonable attorneys' fees and such other and further relief as may be just and proper.
COUNT III
35. Waymans allege and incorporate by reference the allegations contained in paragraphs 1 through 34 as though fully set forth herein.
36. Burditt, Carancahua and Wellington offered and sold interests in the Davis #2 and Gerdes #1 wells to Waymans by means of untrue statements of fact and omissions, in the light of the circumstances under which they were made.
37. The misrepresentations and omissions alleged herein were material and the Waymans reasonably relied upon them in deciding to purchase the interests in the Davis #2 and Gerdes #1 wells.
38. Burditt, Carancahua and Wellington knew or should have known that the representations to Waymans regarding the interests in the Davis #2 and Gerdes #1 wells were false and materially misleading.
39. Waymans did not know of the untruths and omissions alleged herein.
40. Waymans justifiably and reasonably relied upon the representations of Burditt, Carancahua and Wellington in deciding to purchase the interests in the Davis #2 and Gerdes #1 wells, which are now virtually worthless. As a direct and proximate result, Waymans has been damaged in an amount in excess of $50,000.00.
41. For the foregoing reasons, Burditt, Carancahua and Wellington have violated the provisions of K.S.A. 17-1253, 17-1254, 17-1255 and 17-1268 and other applicable Kansas securities.
WHEREFORE, Waymans respectfully request judgment in their favor and against defendants Burditt, Carancahua and Wellington, for recovery of all consideration paid for the interests in the Davis #2 and Gerdes #1 wells, in the total amount of $105,452.46, less income received of not more than $4,495.83, together with interest at the rate of 15% from the date of payment, costs, reasonable attorneys' fees and such other and further relief as may be just and proper.
COUNT IV
42. Waymans allege and incorporate by reference the allegations contained in paragraphs 1 through 41 as though fully set forth herein.
43. The Waymans allege upon information and belief that the certain information from Burditt, Carancahua, Wellington and Chartwell regarding the Davis #2 and the Gerdes #1 wells contained untrue statements of material fact, which were known to be untrue by each defendant at the time the statements were made. The statements were made with the intent to deceive or were recklessly made with disregard for the truthfulness of the statements. The Waymans justifiably relied upon the statements and acted to their injury.
44. The Waymans are entitled to the full repayment of all money paid to the defendants due to the fraud of the defendants. In addition, the plaintiffs are entitled to such additional monetary damages, attorney fees, and interest, as provided by law.
WHEREFORE, the Waymans seek judgment against all the defendants, either individually or jointly and severally, for all moneys paid to the defendant in the total amount of $105,452.46, less income received of not more than $4,495.83, for the relief as prayed, and for such other relief as the court deems just and equitable.
COUNT V
45. Waymans allege and incorporate by reference the allegations contained in paragraphs 1 through 44 as though fully set forth herein.
46. The Waymans allege upon information and belief that the invoices from Burditt, Carancahua, Wellington and/or Bristol regarding costs and expenses attributable to the Waymans' interests in the Davis #2 and the Gerdes #1 wells contained certain untrue statements of material fact, which were known to be untrue by each of them at the time the statements were made. The statements were made with the intent to deceive or were recklessly made with disregard for the truthfulness of the statements. The Waymans justifiably relied upon the statement and acted to their injury.
47. The Waymans are entitled to the full repayment of all money paid to the defendants due to the fraud of the defendants. In addition, the plaintiffs are entitled to such additional monetary damages, attorney fees, and interest, as provided by law.
WHEREFORE, the Waymans seek judgment against all the defendants, either individually or jointly and severally, for all moneys paid to the defendant in the total amount of $105,452.46, less income received of not more than $4,495.83, for the relief as prayed, and for such other relief as the court deems just and equitable.
COUNT VI
48. Waymans allege and incorporate by reference the allegations contained in paragraphs 1 through 47 as though fully set forth herein.
49. The actions of defendants Burditt, Carancahua, Wellington, Chartwell and Bristol in agreeing to defraud Waymans, as fully set forth in Counts I through V of this petition, constitute an unlawful common law continuing conspiracy.
50. The untrue and misleading representations alleged in Count I through V were made by defendants willfully, wantonly and maliciously, for the purpose of inducing Waymans to purchase interests in the Davis #2 and Gerdes #1 wells and pay for costs and expenses falsely attributed to such interests. These defendants acted with outrageous disregard for, or with reckless indifference to, the right of Waymans.
51. As a result of the continuing conspiracy of the defendants, Waymans have been damaged in an amount in excess of $50,000.00.
WHEREFORE, Waymans respectfully request judgment in their favor and against defendants Burditt, Carancahua, Wellington, Chartwell and Bristol, either individually or jointly and severally, for recovery of all monies paid for, or costs and expenses attributed to, their interests in the Davis #2 and Gerdes #1 wells, in the amount of $105,452.46, less income received of not more than $4,495.83, prejudgment interest, costs, attorneys' fees and such other and further relief as may be just and proper.
Respectfully submitted,
/s/
Evan J. Olson, #9663
Hershberger, Patterson, Jones & Roth
100 South Main
Suite 600
Wichita, Kansas 67202-3779
(316) 263-7583
Attorneys for Plaintiffs
END OF TEXT OF PLAINTIFF'S AMENDED PETITION DATED APRIL 17, 1992.
On May 19, 1992, the defendants entered their answers to the above document. The first document submitted was an ORIGINAL ANSWER OF DEFENDANT submitted by Allen L. Burditt, Individually. The second document submitted was the ORIGINAL ANSWER OF DEFENDANTS submitted by the remaining named defendants. However, both documents were voided by the court in a letter to the attorney dated May 20, 1992. This action was taken by the court due to the fact that the attorney representing the defendants was not a member of the Bar of the State of Kansas at time the submissions were made to the court. That attorney, then affiliated with the firm of Russell, Hoffman & Reed, Incorporated was Oliver H. Timmins, III. Mr. Timmins is presently the President and a Director of Oilex, Inc.
On June 12, 1992, the Plaintiffs submitted to the court a MOTION FOR DEFAULT JUDGMENT which reads, in its entirety, as follows:
BEGINNING OF TEXT OF PLAINTIFFS MOTION FOR DEFAULT JUDGMENT
MOTION FOR DEFAULT JUDGMENT
Plaintiffs George W. Wayman and Connie J. Wayman move, pursuant to K.S.A. 60-255(a), for default judgment against defendants Allen L. Burditt, II; Carancahua Resources, Inc.; Wellington Funding Corporation; Chartwell Holdings Ltd., Inc.; and Bristol Operating Co., Inc. granting plaintiffs the relief prayed for in their Amended Petition herein.
In support of this motion, plaintiffs state and allege as follows:
1. Plaintiffs filed their original Petition herein on December 30, 1991.
2. On March 27, 1992, upon the motion of plaintiffs and for good cause shown, the Court entered an Order extending the time within which to serve all defendants until April 26, 1992.
3. On April 17, 1992, plaintiffs filed their Amended Petition as allowed by K.S.A. 60-215(a).
4. Defendant Bristol Operating Co., Inc. ("Bristol") was properly served on April 21, 1992 by serving its registered agent in the State of Texas, Oliver H. Timmins, III.
5. Defendant Chartwell Holdings Ltd., Inc. ("Chartwell") was properly served on April 21, 1992 by serving its registered agent in the State of Texas, Oliver H. Timmins, III.
6. Defendant Wellington Funding Corporation ("Wellington") was properly served with process on April 22, 1992, by serving the Kansas Secretary of State and on April 24, 1992, by serving Allen L. Burditt, II.
7. Defendant Carancahua Resources, Inc. ("Carancahua" was properly served with process on April 22, 1992, by serving the Kansas Secretary of State and on April 24, 1992, by serving Allen L. Burditt, II.
8. Defendant Allen L. Burditt, II, individually, was properly served with process in person on April 24, 1992.
9. On or about May 15, 1992, Burditt and Carancahua, Wellington, Chartwell and Bristol attempted to file answers to plaintiff's Amended Petition. Those answers were rejected by the Clerk of the District Court due to the fact that the attorney representing the defendants was neither admitted to practice in Kansas nor did he have local counsel in Kansas.
10. To date, none of the defendants have filed an answer or other response to the plaintiff's Amended Petition and, pursuant to K.S.A. 60-212, are in default.
11. Pursuant to the allegations of the Amended Petition, plaintiffs are entitled to a money judgment against Burditt, individually, Carancahua, Wellington, Chartwell and Bristol, jointly and severally, in the principal amount of $100,956.63, together with prejudgment interest thereon pursuant to K.S.A. 17-1268(a), in the amount of $35,387.14 through and including the date of judgment.
12. Pursuant to K.S.A. 17-1268(a), plaintiffs are also entitled to a money judgment against the defendants for their costs and for their reasonable attorney fees. To date, plaintiffs have incurred the sum of $757.67 in costs. To date, plaintiffs have incurred attorneys fees in the amount of $8,522.50.
WHEREFORE, plaintiffs George W. Wayman and Connie J. Wayman request that their motion for default judgment be sustained and that a judgment in the total amount of $145,623.92, as itemized hereinabove, be entered in favor of George W. Wayman and Connie J. Wayman against each of the defendants, jointly and severally.
Respectfully submitted,
Evan J. Olson, #9663
David E. Bengtson, #12184
Hershberger, Patterson, Jones and Roth
100 South Main
Suite 600
Wichita, Kansas 67202-3779
/s/
Attorneys for Plaintiffs
George W. Wayman and
Connie J. Wayman
END OF TEXT OF PLAINTIFFS MOTION FOR DEFAULT JUDGMENT
On June 19, 1992, the court ordered the following JOURNAL ENTRY OF DEFAULT JUDGMENT.
BEGINNING OF TEXT OF JOURNAL ENTRY OF DEFAULT JUDGMENT
JOURNAL ENTRY OF DEFAULT JUDGMENT
NOW on this 19th day of June, 1992, the above-captioned matter came before the Court upon the plaintiffs' Motion for Default Judgment. Plaintiffs George W. Wayman and Connie J. Wayman appeared by and through their counsel Evan J. Olson of Hershberger, Patterson, Jones & Roth. There were no other appearances.
Whereupon, the Court, having examined the pleadings and files in the above-captioned cause and having heard the statements of counsel, finds as follows:
1. That each of the defendants has been duly and legally served with process as provided by law, and such service is hereby approved by the Court.
2. That this Court has proper jurisdiction over the parties and the subject matter of this action and that venue is proper.
3. That defendants Allen L. Burditt, II, individually, Carancahua Resources, Inc., Wellington Funding Corporation, Chartwell Holdings Ltd., Inc., and Bristol Operating Company, Inc. have failed to answer or otherwise plead in response to plaintiffs' Amended Petition and are in default.
4. That, pursuant to the allegations of the Amended Petition, plaintiffs are entitled to a money judgment against defendants Allen L. Burditt, II, Carancahua Resources, Inc., Wellington Funding Corporation, Chartwell Holdings Ltd., Inc. and Bristol Operating Co., Inc., jointly and severally, in the principal amount of $100,956.63, together with prejudgment interest thereon pursuant to K.S.A. 17-1268(a) in the amount of $35,387.14.
5. That, pursuant to the provisions of K.S.A. 17-1268(a), plaintiffs are also entitled to a money judgment against each of the defendants for the costs of this action and for their attorneys' fees. Further, that plaintiffs have incurred costs in the amount of $757.67 and attorneys fees in the amount of $8,522.50 in connection with this action and that said amounts were reasonable and necessary.
NOW, THEREFORE, IT IS CONSIDERED, ORDERED, ADJUDGED AND DECREED that the findings hereinbefore made should be and hereby are made the orders of this Court.
IT IS FURTHER ORDERED that plaintiffs' Motion for Default Judgment should be and hereby is sustained and that plaintiffs George W. Wayman and Connie J. Wayman are granted a money judgment against defendants Allen L. Burditt, II, individually, Carancahua Resources, Inc., Wellington Funding Corporation, Chartwell Holdings Ltd., Inc., and Bristol Operating Company, Inc., jointly and severally, in the total amount of $145,623.92, as set forth above herein.
IT IS BY THE COURT SO ORDERED.
/s/
District Court Judge
END OF TEXT OF JOURNAL ENTRY OF DEFAULT JUDGMENT
On April 30, 1996, the Plaintiffs filed a SATISFACTION OF JUDGMENT with the Court as follows:
BEGINNING OF TEXT OF SATISFACTION OF JUDGMENT
Plaintiffs, George W. Wayman and Connie J. Wayman, hereby acknowledge the receipt from the defendants of an amount which plaintiffs will accept in full payment of the judgment and costs awarded to the plaintiff in the Journal Entry of Judgment, filed June 19, 1992 in the above-entitled action, and do hereby authorize the Clerk of the District Court, Sedgwick County, Kansas, to note satisfaction of the judgment of record.
Dated this 30th day of April, 1996.
T. Lynn Ward, No. 14609
Hershberger, Patterson, Jones & Roth, L.C.
100 South Main, Suite 600
Wichita, Kansas 67202
(316) 263-7583
/s/
Attorneys for Plaintiffs
George W. Wayman and
Connie J. Wayman
END OF TEXT OF SATISFACTION OF JUDGMENT
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