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To: scion who wrote (10389)	7/3/2007 9:15:49 PM
From: scion	Read Replies (2) \| Respond to of 12518

b. James P. Toohey has agreed to be deposed in St. Louis, Missouri; however, the date and time may change due to an illness in his family.

To: scion who wrote (10389)	7/3/2007 9:18:25 PM
From: scion	Read Replies (2) \| Respond to of 12518

j. At the Meeting of Creditors on June 27, 2007, James N. Turek, Sr., refused to answer several questions including but not limited to: (1) who owns the patents that Debtor Pro Mold uses in its daily operations? and (2) who has a lien on the patents that Debtor Pro Mold uses in its daily operations? k. The Meeting of Creditors was concluded by the Office of the United States Trustee.

To: scion who wrote (10389)	7/3/2007 9:20:38 PM
From: scion	Read Replies (1) \| Respond to of 12518

d. Answering further, Pro Plas has requested on several occasions a copy of the exhibits attached to the Promotional Containers, Inc. Agreement for Purchase and Sale of Business Assets in order to determine if Debtor Plasticon or James N. Turek, Sr., or another related entity purchased the patents of Promotional Containers, Inc. that Debtor Pro Mold currently uses in its business. e. As of this date, Debtor Pro Mold and Debtor Plasticon have failed to produce those exhibits.

To: scion who wrote (10389)	7/3/2007 9:57:40 PM
From: scion	Respond to of 12518

Before the Motion to Quash was filed, counsel for Pro Plas confirmed for counsel for Debtor Plasticon that depositions would be taken in regard to one pending matter: Pro Plas’ Motion for Relief from Automatic Stay.

To: scion who wrote (10389)	7/3/2007 9:59:11 PM
From: scion	Respond to of 12518

c. Answering further, Pro Plas states that, if the Court requests, it will amend its Notice of Deposition to cite the pending contested matter in this case.

To: scion who wrote (10389)	7/3/2007 10:00:57 PM
From: scion	Read Replies (1) \| Respond to of 12518

d. Answering further, Pro Plas has requested on several occasions a copy of the exhibits attached to the Promotional Containers, Inc. Agreement for Purchase and Sale of Business Assets in order to determine if Debtor Plasticon or James N. Turek, Sr., or another related entity purchased the patents of Promotional Containers, Inc. that Debtor Pro Mold currently uses in its business. e. As of this date, Debtor Pro Mold and Debtor Plasticon have failed to produce those exhibits.

To: scion who wrote (10389)	7/3/2007 10:08:59 PM
From: scion	Respond to of 12518

Before the Motion to Quash was filed, counsel for Pro Plas confirmed for counsel for Debtor Plasticon that depositions would be taken in regard to one pending matter: Pro Plas’ Motion for Relief from Automatic Stay. [...] f. Answering further, prior to the Motion to Quash being filed, counsel for Debtor Plasticon notified counsel for Pro Plas that Debtor Plasticon would object to the deposition of any party on any date in this case until Debtor Plasticon filed its’ Plan of Reorganization. Counsel for Debtor Plasticon would not discuss an alternative date for this or any other deposition in this case.

To: scion who wrote (10389)	7/4/2007 9:03:18 AM
From: scion	Read Replies (1) \| Respond to of 12518

j. At the Meeting of Creditors on June 27, 2007, James N. Turek, Sr., refused to answer several questions including but not limited to: (1) who owns the patents that Debtor Pro Mold uses in its daily operations? and (2) who has a lien on the patents that Debtor Pro Mold uses in its daily operations? k. The Meeting of Creditors was concluded by the Office of the United States Trustee. Extract from: PRO PLAS, LLC’S RESPONSE TO DEBTOR’S MOTION TO QUASH NOTICE OF DEPOSITION OF JAMES P. TOOHEY