February 22, 2011

Lucious Conway, Jr.

HC 76, Box 54
Eagletown, OK 74734

Dear Lucious:

I apologize for still running so far behind. It is not that I do not regard this case as very
important and top priority, but it seems that I spend my days, nights and weekends working on
immediate deadlines. For the last 12 years I have been out of the office too much, for the last three
years way too much, and for the last year of Prudence’s life way, way too much. I say this from the
standpoint of the law practice because otherwise I do not regret being out of the office way, way too
much at all.

Even though I am trying to get out of so much litigation, I am still involved in more than 100
filed jury trial cases. With your legal background, you will understand just how tremendous that
burden is. To make matters much, much worse, I have lost Prudence as a law partner who was
number one in our class and brilliant as a brief writer and researcher.

Enough of my complaining and moaning. Let me discuss the specifics of this case. I had
been planning to come to Idabel the evening before our hearing on February 9 which would have
given me the chance to have visited in person with Gary and Jane Huffman and with Ken Farley
before the hearing the next morning. I hope to do so before the hearing of March 9, but hopefully
we can make progress before that hearing.

Let me just share thoughts and possibilities as a settlement letter. I disagree with your
contention that Laura Ayers or Essie Conway or you own anything through adverse possession on
the eight acres or the 15 acres other than what you all would have inherited or purchased from other
family members, but I understand that it is your belief and contention that Essie Conway and/or you
own the entire 23 acres primarily through adverse possession. Enclosed is an article on Oklahoma
adverse possession which I have found to be well written and well researched. The article has the
obvious advantage of having been written by a third person with no involvement in this case.
 If I have time, I will mark the relevant portions, but in all likelihood I will just send it to you
without have reviewed it for several years.

Regardless of who is right or who is wrong on the legal issues, hopefully we can work out
a practical solution which will get everybody out of the courthouse and which will create a win-win
situation from this time forward.

It is my understanding that based upon your affidavit you are not married and do not have
children. Therefore, in some ways your involvement in this property may be limited to your lifetime.
Just because of the fact that you have chosen to move to this place near Eagletown, which is a far
cry from where you have been living, I would assume that it is very important to you that you be able
to live the rest of your life on this place in peace and without the threat of litigation or ejectment or
partition. It would be agreeable with me for you to live there in peace for the remainder of your life
and to receive all and any income related to the 23 acres for the remainder of your life.

From Gary Huffman’s standpoint, I do not know for certain, but I would assume that Gary
just wants to use the gate and the road as in the past and to get out of the courthouse. If it was a
friend of yours using the gate and road in the same manner as Gary or his employees have been or
would be using the gate and the road, I would guess that the use would not interfere with your use
of the property and would be agreeable with you. It is my understanding that this road is not used
that often as to create any type of noise or heavy traffic nuisance. As part of a settlement agreement,
an agreement could be set forth whereby Gary and Jane Huffman would recognize that they do not
own any of the surface or minerals under the eight acres or 15 acres and that you would not object
to the same use of the gate and road as in the past before these problems arose. Just to sweeten the
pot, if Gary would be willing to do so, Gary could pay you $1,000.00.

From the standpoint of Sagacity, Inc., the settlement agreement could provide that Sagacity
would convey to you a life estate on those interests purchased by Sagacity, Inc. and any future
purchases and that Sagacity, Inc. would not file any type of partition lawsuit as long as you were
alive and living on the place. In regard to any interest which you or Essie Conway have purchased
from any family members, I would be willing to pay you or Essie the same as paid to other family
members and would grant you the life estate on those interests. Sagacity, Inc., would grant you the
life estate and the right of any and all income related to the land during your lifetime.

As you are probably already aware, Sagacity, Inc. has purchased the undivided interests from
the following persons:

A. Quit Claim Deed from Frank Nolen, Jr. and Gladys M. Nolen to Sagacity,
Inc., dated April 26, 2010, recorded May 4, 2010, at Book 827, page 378, for
1 net acre

B. Quit Claim Deed from Cleo Moore, Jr. to Sagacity, Inc., dated May 12, 2010,
recorded May 24, 2010, at Book 828, page 270, for .3333 net acres
 C. Quit Claim Deed from Lucile Moore Wilson to Sagacity, Inc., dated May 12,
2010, recorded May 24, 2010, at Book 828, page 271, for .3333 net acres

D. Quit Claim Deed from Betty Moore to Sagacity, Inc., dated August 12, 2010,
recorded August 25, 2010, at Book 832, page 437, for .3333 net acres

E. Quit Claim Deed from Erma Moody to Sagacity, Inc., dated September 3,
2010, recorded September 16, 2010, at Book 833, page 199, for .3333 net
acres

F. Quit Claim Deed from Alberta Stewart to Sagacity, Inc., dated October 7,
2010, recorded October 22, 2010, at Book 834, page 722, for .3333 net acres

G. Warranty Deed from Allene Moore Middleton to Sagacity, Inc., dated May
6, 2010, recorded May 24, 2010, at Book 828, page 272, for the 15 acres and
one undivided acre under the eight acres, for a total of 16 acres

Again, to sweeten the pot and to facilitate settlement, Sagacity, Inc. would also be willing to pay you
$1,000.00. As part of the settlement agreement, the lawsuits would be dismissed, mutual releases
granted and written permission to Huffman to use the road and gate but no other part of the 23 acres.

Lucious, please understand that this is a settlement letter in which I am just sharing my
thoughts. I do not represent Gary and Jane Huffman in these lawsuits and cannot in any way speak
on their behalf. If you and I can reach agreement, however, I would be hopeful that the Huffmans
and their attorney, Ken Farley, would be willing to follow my recommendations.

I hope all is well.

Cordially yours,

LITTLE, LITTLE, LITTLE, WINDEL, OLIVER,

LANDGRAF & GALLAGHER, PLLC

Dan Little

DL\cy

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